EPA Enforcement in 2012 Protects Communities From Harmful Pollution

Clean County PW said:

No what Robert is saying there has to be other acceptable solutions such as a simple method of using berms or landscape area at times...IMHO

Once again Robert can correct that if I'm seeing that incorrectly.

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Christopher said:

Those are great photos Tony!

It makes you wonder what would happen if things got so bad that more and more places just stopped cleaning like what happened in Houston.

The cities own the sidewalks and in those pictures it looks like they have not been cleaned in a long time, the store owners and business owners don't have to pay to get them cleaned, what if they just gave up and let them get worse and worse, especially in the downtown areas where you have homeless issues and restaurants that have grease building up continuously on the sidewalks?

What happens when they get worse and worse and worse?

What happens when they become a slip hazard and people get hurt?

What happens when it becomes a health issue because of all the filth?

Will the cities do it themselves? I don't think so as there are just too many sidewalks.

What happens when the sidewalks get so filthy that they start to get a nice glaze or slime buildup on them and people start sliding or falling down on them?

Makes you think.

Will the EPA come out and clean them? I would like to see them try, especially with video being recorded to see how they do it, if it is done right, how they process the water, if they are D.O.T. compliant (need D.O.T. officers there to make sure the vehicle and what they do are right and tickets will be enforced) and what happens next. hahahahahahaha

What happens when everyone just stops caring because of all this nonsense if we don't get things back on the right track and everything just gets worse and more filthy?

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Robert Hinderliter said:

What is UAMCC's Current BMPs. Do they even exist?.

Who is the Environmental Chairman?

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bigchaz said:

John, if the local laws and restrictions became such that you had to vacuum every drop of water, haul it off site with special license and pay $350 or more to dispose of the waste would you decide instead to take the waste and dump it in a river at night when no one is looking?

This is what Robert says you will do "Example: If a municipality charges $350.00 per load of waste water to dump at the POTW, then that is what will happen"
"the industry will go underground and discharge wastewater to the MS4s on nights and weekends when enforcement is at its lowest."


I don't know you John but think you are a responsible and professional contractor so I feel confident knowing that you would not do that. However, Roberts position is that in the face BMPs that are not rational that contractors will willfully take waste and dispose of it illegally.

I don't want to try to predict your actions John, but I think if that were the case you would probably try to comply, or if it became too difficult you would move on to another area of cleaning and simply not clean the structure anymore. This is like the pictures Tony posted, the powerwashers simply moved on.

John, there are two ways you can look at the industry as a whole. Either you believe that powerwashers are good and honest people who want to do the right thing and earn a fair living. Or you believe that powerwashers will do anything for a buck up to and including willful pollution and illegal dumping.

Right now, your blind devotion to Robert seems to put you square in the 2nd category. I believe that we as an industry are better than that.

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Tony Shelton said:

This is a three bay semi-truck fuel filling station at a petroleum plant.

Right in the middle of each of the lanes is a big grated hole, right behind where Chris is standing in this picture. The entire thing is covered by a huge roof. There is no rain event ever going to get a drop of rain inside this area unless it comes in on the wheels of the trucks.

I'd like to ask Robert, what the big hole is for? It is for floods in case God ever gets angry with us again and floods the earth? Because that is the only way this system will ever see rainwater.

Or, is it for US to be used when washing down the lanes?

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• Discharging to the Sanitary Sewer is allowed with a Cosmetic Cleaning permit.

• Discharge must be in compliance with local regulations and limits (Solids less than 250 mg/L, Petroleums less than 250 mg/L), and may require pre-treatment, sampling, and possibly other measures.

• Ensure pH of the wash water is between 5.0 and 12.0 (use pH test strips) and below 150˚F.

• Filter using the best available method that removes the largest amount of contaminants.

Ohio pressure wash said:

This was pretty much the topic of my ranting in 2010-2011.

As I said back then, and you hit on here in your post...is that the entire plan, the EPA and that of Robert's and the Orgs was and is built on a dysfunctional model. As regulations get stiffer....there is less cleaning. As there is less cleaning, there are fewer cleaners. The system as designed, makes "doing nothing" the smarter option for the property owner. They cut out the revenue stream and target the solution not the problem.

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So, what happens to the pollution if a pressure washer isn't around to be monitored, validated, verified, ticketed and fined?

It's still there.

It's not only still there but it's also transferred to different places by people and mother nature. The oil still makes it to the "waters of the US". The silt, litter and suspended solids still run down the drain. The oil still get tracked on shoes, into cars, into homes.

These Reg's and BMP's do not address maintenance. Since there is no "requirement under the CWA" to keep the area clean, nobody gets a ticket. These areas can get as bad as Tony's pics and even worse. The oils run off and down the storm drain every time it rains. The EPA has basically made polluting the least expensive option.....it's free! Yea...totally bass ackwards from the intent. This is what happens when a bunch of bureaucrats and lobbyists punch their time cards, draw their checks and dream of retirement. People have to live with their stupid ill thought out ideas.

It's simple math and economics

If the property owners were required by the same reg's to have maintenance cleanings (calling it cosmetic cleaning was stupid), there would be a revenue stream. Everything would then make sense. There would be not only a demand for cleaning but a demand for regulation compliant cleaning.

This is why I laugh at the phrase "rational, reasonable and logical". Nothing about this entire thing is rational or logical. It's a knee jerk reaction allowed to survive common sense and grow to adulthood....sprinkle in a bit of ego and greed from the industry "leaders" and what you have is our regulations and BMP's.

We need to start fresh...disavow the premise and begin from the ground up. We are not polluters...we clean pollution.

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Robert Hinderliter said:

Tony I cannot believe you would ask that! Obviously you have not been reading what I have been posting; or not understanding. Here I will make it easy for you:

"Discharge to the Sanitary Sewer - Preferred

• Discharging to the Sanitary Sewer is allowed with a Cosmetic Cleaning permit.

- Some cities require a permit others do not. Contact your Public Works department for your city's requirements. The Public Works department may need to direct you to another department.

• Discharge must be in compliance with local regulations and limits (Solids less than 250 mg/L, Petroleums less than 250 mg/L), and may require pre-treatment, sampling, and possibly other measures.

- This will depend on the municipality.
- The city of Fort Worth has never been able to detect wash water from Cosmetic Cleaning in their POTW (Publicly Owned Treatment Works).

• Ensure pH of the wash water is between 5.0 and 12.0 (use pH test strips) and below 150˚F.

- These limits are typically above normal Cosmetic Cleaning wash water.

• Filter using the best available method that removes the largest amount of contaminants.

- Sand Trap, Grit Trap, Grease Trap or Clarifier.
- If these options are not available then discharge to a mop sink, utility sink, kitchen sink, toilet, inside floor drain, or Sanitary Sewer clean-out stub.
- Never remove the Sanitary Sewer or Storm Drain manhole cover as these are City Property and require authorization to open."

You said reading was better for you than understanding a picture; apparently not. Do you need me to explain what those holes as you call them are.

On PowerWash.com there is a video that explains what they are, what they are for, and how to use them. Do I need to lead you there?

You might learn something if you had an open mind.

You need to go to PWNA.org, click on the environmental tab, for a new learning experience. If you would you would not be asking the stupid question above.

Is that how you are suppose to trick me up? Ask me about my own work to see if I understand my own work?

You answer is in the videos, which are understandable for most people.

You would also learn that almost every statement you have made is false; or maybe you cannot understand the information. Jim Gamble said he would be glad to tutor you. (My Daddy always said that it you told a tall one, it was not a lie.) (Do I need to explain that?)

I am waiting: Next Trick Question.

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Tony Shelton said:

You sir, have just proven beyond a shadow of a doubt that you have no business whatsoever instructing anyone on anything to do with environmental issues.

I knew the answer to this question before I ever put it out to you. And yes, Sir, it was a trick question and you failed.

But just for good measure (and because I was unaware of the nomenclature used on these systems) I called the head of maintenance at this facility who has used us for cleaning for over a year. He told me he was VERY aware of where this runoff goes because he is responsible for it.

This runoff goes into what he called a "slop tank". They have a service come out and remove and service the slop tank monthly or quarterly. (we clean it monthly and have for almost two years). He said under NO CIRCUMSTANCES could this go into the municipal sewer system and that NONE of these types of facilities nationwide are allowed to flow into the sewer system. I asked him "you mean the storm sewer?" (because I knew you would say something like that) and he replied "no, the storm sewer is an entirely separate issue, this cannot be put into the SANITARY sewer under any circumstances because of the the large undiluted spills that happen at places like this on a regular basis.

No, Mr, Hinderliter, the best way to educate the contractors on environmental compliance is to remove your videos, instructions, courses and virtually everything else you have spouted over the years, put it in a pile and burn it, and retire to Jim's Villa.

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Robert Hinderliter said:

We need more examples from Contract Cleaners.

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Robert Hinderliter said:

Obviously you do not understand SWPPP or the concept it is based on.

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Robert Hinderliter said:

What is UAMCC's Current BMPs. Do they even exist?.

Who is the Environmental Chairman?

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Tony Shelton said:

You sir, have just proven beyond a shadow of a doubt that you have no business whatsoever instructing anyone on anything to do with environmental issues.

I knew the answer to this question before I ever put it out to you. And yes, Sir, it was a trick question and you failed.

But just for good measure (and because I was unaware of the nomenclature used on these systems) I called the head of maintenance at this facility who has used us for cleaning for over a year. He told me he was VERY aware of where this runoff goes because he is responsible for it.

This runoff goes into what he called a "slop tank". They have a service come out and remove and service the slop tank monthly or quarterly. (we clean it monthly and have for almost two years). He said under NO CIRCUMSTANCES could this go into the municipal sewer system and that NONE of these types of facilities nationwide are allowed to flow into the sewer system. I asked him "you mean the storm sewer?" (because I knew you would say something like that) and he replied "no, the storm sewer is an entirely separate issue, this cannot be put into the SANITARY sewer under any circumstances because of the the large undiluted spills that happen at places like this on a regular basis.

No, Mr, Hinderliter, the best way to educate the contractors on environmental compliance is to remove your videos, instructions, courses and virtually everything else you have spouted over the years, put it in a pile and burn it, and retire to Jim's Villa.

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Robert Hinderliter said:

Tony:

Those BMPs are not for Hazardous Waste, which is stated several times.

DO NOT USE THE EPA MODEL ORDINANCE COSMETIC CLEANING BMPs FOR HAZARDOUS WASTE.

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Robert Hinderliter said:

Barry Posted:

I'm no lawyer but I think the answer to your questions is, the BMP's you have promoted as having been "developed jointly" are also the UAMCC's BMP's and thus open to modification by the UAMCC board of directors at their discretion.

Barry:

Those BMPs can be modified by anyone at their discretion. They are up there as a starting point for anyone. Be my guest and write your own to your liking.

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Tony Shelton said:

When we clean these pads they are no different than any garage. As a matter of fact, THEY clean up any spills immediately, so that when we come in to clean the only thing we have to deal with at all is a few drips near the buckets where they leave the connectors and the oil drips from the leaking semis.

For OUR PURPOSE we are doing the exact thing Jim is doing in a garage.

According to your BMP's we would have to pick this water up and put it in the sanitary sewer.

There are literally tens of thousands of places in this country that are perfectly capable of capturing our runoff onsite and dealing with is ON PROPERTY just like this one.

Your BMP's don't recognize that at all, and, in fact, work to convince the regulators that ALL washwater must be picked up and put in the santiary sewer. This is false. Period.

Please, go on and continue what you are doing. I've met with a lot of regulators who can easily see right through what you are doing. Keep on with it. In the end you will look just as foolish and defeated to them as you have looked in this thread. Only you won't have a clue because your ego glasses won't let you see.

The regulators you latch on to are the fringe, and they are the minority. They do not represent the good regulators who work hard to keep the environment clean and know that limiting health and safety cleaning is more detrimental than the tiny amounts of runoff that might make it past our gravity filtration equipment. They are also smart enough to know that coming down hard on us won't make our water any cleaner, nor make their coffers any larger, but will rather, simply, cause us to go on to different lines of work leaving the sidewalks of our nation filthy like a third world country.

Nostradamus almost eradicated the entire black plague by starting a program of cleaning the streets.

Now, your path is a trip back in time to where filth and garbage put our health in danger.

And for what? So a few large contractors can rule the market and you can sell a few vacuums and filters.

Sad and pathetic.


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1. Environmental Chairperson is, so I assume you do not have one that will take on the responsibility and admit who he is!
2. You have never published you BMPs as I have, so you probably cannot agree on these either.