EPA Enforcement in 2012 Protects Communities From Harmful Pollution

Tony:

Whos work do you think that work is based on? Because of my posting on the Internet, I have shaped almost every ordinance except for Oregon. A lot of them I reiewed and made comments, which were accepted about 80% of the time.

Read that language, a lot of it is copied. How do you think that everyone misteriously use the same verbage?


Tony:

Whose work do you think that work is based on? Because of my posting on the Internet, I have shaped almost every ordinance except for Oregon. A lot of them I reviewed and made comments, which were accepted about 80% of the time.

Read that language, a lot of it is copied. How do you think that everyone mysteriously use the same verbiage?

I am freakin confused. IMO there may be more to these multiple pages of epa brochures/rules than ust a bunch of babble.
 
Tony:

Whos work do you think that work is based on? Because of my posting on the Internet, I have shaped almost every ordinance except for Oregon. A lot of them I reiewed and made comments, which were accepted about 80% of the time.

Read that language, a lot of it is copied. How do you think that everyone misteriously use the same verbage?


Tony:

Whose work do you think that work is based on? Because of my posting on the Internet, I have shaped almost every ordinance except for Oregon. A lot of them I reviewed and made comments, which were accepted about 80% of the time.

Read that language, a lot of it is copied. How do you think that everyone mysteriously use the same verbiage?


Finally the truth......
 
With the popularty of this thread , I think this local AHJ may have received communication from other than myself about this property, .....anyway I received a recommendation from AHJ for location, they do not suggest that powerwash/pressure cleaning wash water from cleaning be allowed to runoff/discharged to this BMP which they indicated is for storm water.

I am awaiting their response to runoff/discharge with pre-treatment.

Good Job Nigel.........
 
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Robert with your experience in communicating with/and being in the atmosphere of local AHJ's and the EPA, do you think that the mobile cleaning industry can present a case that will allow the use of such storm water BMP's for use with rational, reasonable and logical discharge precautions?
Good question Nigel. I was wondering that myself. The beauty of this thread. Learning more on this thread then I did in college listening to my engineer teacher for a semester(man I can't wait to play fooseball memories)
 
Robert with your experience in communicating with/and being in the atmosphere of local AHJ's and the EPA, do you think that the mobile cleaning industry can present a case that will allow the use of such storm water BMP's for use with rational, reasonable and logical discharge precautions?

Nigel:

Certainly, a lot of the time this will apply. See MS4 Discharges above, all of those conditions should apply.

Depending on the hydrogeology at the MS4, a lot of other times would be applied also. This will have to be on a location based decision. Like Comparing Miami to Las Vegas; Las Vegas can be more tolerant because they are setting on top of a Giant Sand Filter, which Miami is not. Also Miami Ground Water Table is measured in inches, and Las Vegas Water Table is measured in hundreds of feet.
 
Robert with your experience in communicating with/and being in the atmosphere of local AHJ's and the EPA, do you think that the mobile cleaning industry can present a case that will allow the use of such storm water BMP's for use with rational, reasonable and logical discharge precautions?

Nigel:

Certainly, a lot of the time this will apply. See MS4 Discharges above, all of those conditions should apply.

Depending on the hydrogeology at the MS4, a lot of other times would be applied also. This will have to be on a location based decision. Like Comparing Miami to Las Vegas; Las Vegas can be more tolerant because they are setting on top of a Giant Sand Filter, which Miami is not. Also Miami Ground Water Table is measured in inches, and Las Vegas Water Table is measured in hundreds of feet.

Location would be an important factor, I did not consider .......

"hydrogeology" cant say I have used that word before

I should have been a little more clear, I should have asked

Robert with your experience in communicating with/and being in the atmosphere of local AHJ's and the EPA, do you think that the mobile cleaning industry can present a case that will allow the use of such storm water BMP's in the gas station video for use with rational, reasonable and logical discharge precautions?
 
Location would be an important factor, I did not consider .......

"hydrogeology" cant say I have used that word before

I should have been a little more clear, I should have asked

Robert with your experience in communicating with/and being in the atmosphere of local AHJ's and the EPA, do you think that the mobile cleaning industry can present a case that will allow the use of such storm water BMP's in the gas station video for use with rational, reasonable and logical discharge precautions?

Nigel:

Probably not, too many hydrocarbons (gasoline, oil, and grease). These contaminates would probably over whelm the Storm Water BMPs.

Sorry, I did it again: From http://en.wikipedia.org/wiki/Hydrogeology

Hydrogeology (hydro- meaning water, and -geology meaning the study of the Earth) is the area of geology that deals with the distribution and movement of groundwater in the soil and rocks of the Earth's crust (commonly in aquifers). The term geohydrology is often used interchangeably. Some make the minor distinction between a hydrologist or engineer applying themselves to geology (geohydrology), and a geologist applying themselves to hydrology (hydrogeology).
 
Nigel:

Probably not, too many hydrocarbons (gasoline, oil, and grease). These contaminates would probably over whelm the Storm Water BMPs.

And the BILLIONS of miles driven on thousands of miles of roads (made of hydrocarbons) generating 'untold amounts' of contaminates, will you cry for those pollutants?
 
Nigel:

Probably not, too many hydrocarbons (gasoline, oil, and grease). These contaminates would probably over whelm the Storm Water BMPs.

Nigels question includes:

"for use with rational, reasonable and logical discharge precautions?"

Your position
"Probably not, too many hydrocarbons (gasoline, oil, and grease). These contaminates would probably over whelm the Storm Water BMPs."
 

Everywhere you see the PWNA reference, that was me. That was what I asked for, and it was done about 30% of the time.

It will take a lot more effort to turn those BMPs around than build upon them. I think it is an excellent BMP, and we have a solid track record to back it up.

Yes, let’s get everyone’s comments.

Ron I have never seen you post a complete of documented BMPs, just criticize mine. Is that all you know how to do?
 
Everywhere you see the PWNA reference, that was me. That was what I asked for, and it was done about 30% of the time.

It will take a lot more effort to turn those BMPs around than build upon them. I think it is an excellent BMP, and we have a solid track record to back it up.

Yes, let’s get everyone’s comments.

Ron I have never seen you post a complete of documented BMPs, just criticize mine. Is that all you know how to do?

Robert Are you sure this was Yours?
 
Robert Are you sure this was Yours?
Robert I may be wrong here but I think Ron is driving at the idea that Kendra Tilley wrote some of these BMP's if not all.
What was here involvement with these besides teaching a class on Enviro cleaning at a PWNA Convention in the mid to late 90's?
 
Municipalities should be focusing on 'their' roads and accompanying discharges if there is even an issue of them meeting limits under their permit.
 
Robert Are you sure this was Yours?

Yes, I made a presentation to Gwinnett County and several surrounding communities in the Atlanta, GA area. At the time Atlanta was charging $350.00 for every load of waste water dropped off at the POTW. That was why I was called in.

Pete with Sunbite paid for my expenses. After the presentation and training Pete took over, as he was local and completed everything. With that as a basis he then built his own Environmental Program, which as Environmental Chairman that is exactly what I am supposed to do; empower the local person to be an expert and help write the BMPs.

As an Association that is what PWNA is supposed to do also. Give the local StakeHolder what he needs to go into the Local AHJ and be able to speak the language with authority. Normally they get 15 minutes which turns into 2 hours because they have information of real value based on experience since January 2, 1996.

In this case I trained a local Distributor. However, I have trained more contract cleaners to take over, than Distributors.

Presently we have a complete program for the Municipalities to build upon which makes the local person an expert. Most contractors make very few changes, if any; however, they are free to change whatever they want.


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I think this here says a lot about Powerwashing in general. A simple berm can be enough which has been stated here many times by different people.

The whole argument in here is "Are you protected if you get stopped by a code enforcer" at the place your Powerwashing at. What the least you should do to CYOA..

This says alot-----
The most common method of compliance with the CWA is to prevent process wastewater discharges to waters of the United States.* If your discharge does not reach waters of the United States, then there are no requirements under the CWA.* Examples of compliance without a discharge are vacuuming up the process wastewater or berming the process water and allowing it to evaporate.* An additional method of compliance is to discharge the water to an NPDES permitted sanitary sewer system (the municipality may have additional pretreatment requirements before accepting your discharge).* The most common form of non-compliance is to discharge the process water into a storm sewer system or into a city street that drains to a storm water inlet.* Most storm drainage systems in Region 6 discharge directly to waters of the United States without treatment, which means anything that discharges into a storm drain is the same as putting it directly into the waterbody receiving the storm drain discharge.*
 
Robert I may be wrong here but I think Ron is driving at the idea that Kendra Tilley wrote some of these BMP's if not all.
What was here involvement with these besides teaching a class on Enviro cleaning at a PWNA Convention in the mid to late 90's?

She contributed along with many others.
 
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