EPA Enforcement in 2012 Protects Communities From Harmful Pollution

Ok that's a bit different then going into Jim's area knocking on doors. Question- isn't Jim Cooney's scope of employment in the same area as Scott and Rons??

He didn't have time Johnny....he was too busy trying to google where Suisun City was located at to meet with me :thumbup2:. Anyway, you all have fun with this topic!
 
You don't like the fact that Tony went to Jims area?What do you think Robert has been doing for years?
I was just going to post about what you said because personally I am not a fan on knocking on people's doors in someone else's area to name drop with the intent to probably hurt someone first.

Tony and Robert are stating that they didn't do that so.....good. That's s plus to come out of this debate so far.
 
He didn't have time Johnny....he was too busy trying to google where Suisun City was located at to meet with me :thumbup2:. Anyway, you all have fun with this topic!
We sure will Carlos. Best thread I seen in yrs if we can keep it civil....

Hey aren't you and I supposed to be somewhere in 20 minutes(smile)
 
We sure will Carlos. Best thread I seen in yrs if we can keep it civil....

Hey aren't you and I supposed to be somewhere in 20 minutes(smile)

Can't make it bro...heading out the door to my niece's 16th B day party. Give the guys a "hello" from me. Sorry I can't be there. Just waiting for the wife and daughter to come downstairs to head out!!
 
That would be a correct statement. Dinner was great Tony. However man you looked beat down tired when you and your family arrived. Appreciate you swinging out my way to hook up. My wife Bettye enjoyed the company!

Man I was beat! I reserved the last week of the trip for .family and had 5 days of disney/universal/Seaworld. Longest week of my life!

I don't think any individual should be going around suggesting bmps or rules to any regulator without the backing of an overwhelming consensus of contractors.

That was not what I was doing. I was on a fact finding mission to see how we are viewed by the regulators.

I was pleasantly surprised by the positive responses I received.

Hot water cleaning was not an issue.

Robert, if you had just worked with our suggestions and tweaked them a little more in favor of the contractors you wouldn't have lost credibility. Then your teaming up with Jim was the nail in the coffin for many contractors.

I wish it hadn't happened that way. We really do need a united voice but it looks like our vision for the industry is just as divided as the country is right now.





Sent from my Transformer TF101 using Tapatalk 2
 
Man I was beat! I reserved the last week of the trip for .family and had 5 days of disney/universal/Seaworld. Longest week of my life!

I don't think any individual should be going around suggesting bmps or rules to any regulator without the backing of an overwhelming consensus of contractors.

That was not what I was doing. I was on a fact finding mission to see how we are viewed by the regulators.

I was pleasantly surprised by the positive responses I received.

Hot water cleaning was not an issue.

Robert, if you had just worked with our suggestions and tweaked them a little more in favor of the contractors you wouldn't have lost credibility. Then your teaming up with Jim was the nail in the coffin for many contractors.

I wish it hadn't happened that way. We really do need a united voice but it looks like our vision for the industry is just as divided as the country is right now.





Sent from my Transformer TF101 using Tapatalk 2
Who said Robert lost credibility with the contractors? Your going by a net bb for your info Tony and as you know in person things are much different.

Robert got multiple applauses when he spoke in Florida and most people there were contractors. He's going to have an open invite in NY,PA,Vegas(still trying to close this deal) and probably multiple other places that contractors go to.

This is where your making a major blunder IMHO. You made it clear that you will forever dog Jim. (Man I would really hate to be truly on your bad side which I know I'm not or will ever be-personality trait).

Robert is our information hwy. He's done an absolute ton of positive things such as creating your very organization that your touting now. It's also thru his creation of the PWNA that many have done volunteering projects with the his creation the PWNA named on it.

The problem you guys are having is that Robert had the gumption and the fortitude to take on the regulators probably when most were still in diapers here.

If the goal here is to discredit Robert now because you or some others have a problem with Jim.... Your wasting your time. This industry will not move forward and will remain stuck in the mud.

Your trying to recreate the wheel and you yourself have to be close to 50. Then some upstart 22 yr old now will be looking to discredit you down the road. Your just continuing on a cycle that has not, will not work.

Confrontations with your own is a recipe for failure. Did you ever wonder why we as an industry have not moved forward enough, and every time we do it's 1 step forward and 2 steps back?? Just look at what I just said about the recipe for failure.

I've been studying this industry here from at least the yr 2000 and I was doing it from a place where we belonged to multiple groups including one that was 350,000 plus people strong.

Confrontational attitude instead of a proactive positive attitude is a train wreck. You'll see like we all will when our time now is done here.. and on this I hope I am dead wrong. Time will tell.
 
I realize my using the word credibility is probably confusing. A better word would be "trust".

Denying "shopping" the bmp's, asking for our help with the bmp's, but ignoring our suggestions, choosing Jim as a representative, and things of that nature has resulted in a loss of trust.



Sent from my DROID RAZR using Tapatalk 2
 
I realize my using the word credibility is probably confusing. A better word would be "trust".

Denying "shopping" the bmp's, asking for our help with the bmp's, but ignoring our suggestions, choosing Jim as a representative, and things of that nature has resulted in a loss of trust.



Sent from my DROID RAZR using Tapatalk 2
If that's yours and a few others assessment, Fair enough. Maybe one day there's a way to close that gap.. Maybe.
 
I received a call from someone who used to be active on here a few years ago. He told me I was being mean.

I don't hate Robert, Jim or anybody. But I do love freedom. I love entrepreneurs. I love the beauty of honest business and I love the contractors here at PWI.

I hate deceptive practices, cheating, lying and taking advantage of others.

I am not good at getting my points across in a gentle manner.

But all the time I have spent on this issue comes from a desire to do what is right.

Proverbs 27:12 A prudent person foresees danger and takes precautions. The simpleton goes blindly on and suffers the consequences.


I am sorry for being so offensive in the process.

Sent from my DROID RAZR using Tapatalk 2
 
City of Fort Worth, May, 2009

Storm Water Quality

Mobile Commercial Cosmetic Cleaning - Background

All Cities Must Have Storm Water Permits

All cities in the United States over 100,000 in population must now have a NPDES Stormwater Permit from the EPA to operate their municipal storm drain systems. One of the key elements of this permit requires the cities to create and enforce an ordinance which bans pollutant discharges to the storm drain. The City of Fort Worth ordinance reads; "A person commits an offense, punishable by a fine, if he introduces or causes to be introduced, any discharge to the storm drain system that is not entirely composed of stormwater." The EPA did grant certain exemptions to this rule in its regulations, and Fort Worth adopted numerous of these in its ordinance as defenses. Some of these defenses include discharges composed of runoff from lawn sprinklers, surfacing groundwater, air conditioner condensation and fire fighting water.

Cold Water Discharges by Power Washers

The Fort Worth ordinance contains a provision that may be used by cosmetic cleaners (power washers) under special circumstances. It states that a discharge or flow of cold water used in cosmetic cleaning that is not contaminated with any soap, detergent, degreaser, solvent, emulsifier, dispersant or any other cleaning substance may be discharged to the storm drain as long as the storm drain inlet is screened to catch debris and the discharge passes through an oil absorbent pad or boom. No oil sheen may be present in the discharge after it passes through the pad or boom. The City of Fort Worth Department of Environmental Management recommends screening the storm drain inlet with a 20 mesh or finer screen to catch the debris. Cleaning with hot water (over 110°F) is also allowed under this exemption as long as permission is obtained from Environmental Management prior to starting the job.

Cosmetic cleaners must be very careful if they choose operate under this provision. Even though they may be using water only, with no added detergents, degreasers, etc., they could easily wash off existing pollutants from the surface they are cleaning which could put them in violation of the ordinance.

Fort Worth Must Monitor its Storm Drains

Another element of the EPA Stormwater Permit requires Fort Worth to test selected areas within its storm drain system. Fort Worth has tested over 560 sites. Detergents were discovered in over 50% of these sites making detergents the most frequently encountered pollutant in City storm drains. Repeated field observations of cosmetic cleaning activities showed that a significant amount of detergents were being discharged into the streets and city storm drains. Because the City must show a decrease in the pollutants at the 560 sites over the five years of its NPDES permit, the city enacted specific regulations to limit these types of discharges. The regulations include banning cosmetic cleaning discharges to the storm drain and the implementation of a permit system for commercial mobile power washing activities.

The Cosmetic Cleaning Permit is administered by the Environmental Management Department because it is charged with implementing the city's EPA Stormwater Permit. Detergent in the storm drain is considered a stormwater issue. Other cities may regulate cosmetic cleaning activities through their Public Works Department, Water Department, Water/Stormwater Utility District or other agencies which oversee their EPA Stormwater Permit.

Disposal of Wash Water

The banning of cosmetic cleaning discharges from the storm drain left the operators with two disposal options. The first was to collect their effluent and haul it to an approved treatment facility. The second option was to discharge the effluent to the sanitary sewer, preferably at the job site. The City of Fort Worth chose to require the second option for several reasons. Hauling the waste water to a treatment facility proved too costly for most cosmetic cleaners due to the high per-gallon disposal cost charged by the treatment facilities. Limited testing performed by Environmental Management, in addition to data supplied by the power washing industry, revealed that the average cosmetic cleaning effluent tested below the city's numerical standards (i.e., temperature, pH, oil & grease, metals, etc.) used for approving discharges to the sanitary sewer as long as liquid accumulations of oil, gasoline, grease, etc., were pre-cleaned using an absorbent material.

Because it was determined that pollutant levels in the power wash effluents were low enough for discharge to the sanitary sewer, the Water Department was then concerned with volume. It was estimated that the total volume of wastewater generated by all the cosmetic cleaners operating in Fort Worth on any given day was not likely to exceed 20,000 gallons. The Director of the Fort Worth Water Department deemed this volume "insignificant" when compared to the City's total treatment capacity of 110,000,000 gal/per day.

The Water Department's final concern involved how the cosmetic cleaner was going to access the sanitary sewer. Everyone was in agreement that the waste water belonged to the property owner, not the cosmetic cleaner, so the waste water should be discharged on-site if possible. The ideal discharge point would be into a sand or grit trap such as those found in car wash bays. Unfortunately, few sites contain such facilities so the discharge options revert to sinks, toilets, floor drains and clean-out stubs. It does not matter which of these conveyances the cosmetic cleaner uses as long as the discharge does not contain grit, grease or other substances which could possibly clog the pipe, and the discharge meets the numerical standards discussed above.

Environmental Management recommends discharging through a 400 micron filter to remove the grit and sludge. It is up to the property owner to decide which conveyance to discharge into as they own the plumbing system located within their property lines and are ultimately responsible for what is in their system. It should also be noted that discharges into manholes are strictly forbidden, no matter where they are located. It is not only dangerous to remove the lid from a manhole but it is also illegal. Waste water that is pre-treated before discharge to the sanitary sewer is, by city definition, a process water and thereby subject to the rules and regulations of the Water Department's Division of Industrial Waste. Cosmetic Cleaners that utilize wash water recycling units fit into this "process water" category and must test their effluent at least once annually. The results of the tests must be sent to the Division of Industrial Waste to determine compliance with the numerical standards for discharge to the sanitary sewer.

The EPA requires that the Division of Industrial Waste have the ability to take samples from the effluent of all process waters, so cosmetic cleaners using wash water recycling units must supply a map of all of the discharge points they use as a part of their Cosmetic Cleaning Permit.
 
I received a call from someone who used to be active on here a few years ago. He told me I was being mean.

I don't hate Robert, Jim or anybody. But I do love freedom. I love entrepreneurs. I love the beauty of honest business and I love the contractors here at PWI.

I hate deceptive practices, cheating, lying and taking advantage of others.

I am not good at getting my points across in a gentle manner.

But all the time I have spent on this issue comes from a desire to do what is right.

Proverbs 27:12 A prudent person foresees danger and takes precautions. The simpleton goes blindly on and suffers the consequences.


I am sorry for being so offensive in the process.

Sent from my DROID RAZR using Tapatalk 2
Closing the gap already(smile).. Hey since where spitting personal truths on the net because being honest trumps in the end.. What you just did above there's very few people I know who would do the same.. Your a better man Tony and stronger for it..

Sometimes we push to hard.... Somewhere sometimes it works.. Sometimes as you seen with myself I got clocked for it(org related) and deservedly so. Helped tear something down all because a few of us went on a "Mission" searching for truths". It was IMHO a mistake so I took my lumps.

I rather have peace and fight something together that's worth fighting for. If it's unrealistic..so be it.

Either way it was the effort of a few in here and no doubt yourself at the core of it that brought this thread into the numbers I never seen anywhere since I been going on these PW bb sites for 15 yrs now. Also the topic of this thread is at the top of the heap of what this industry can be known for... Or...die for.. As far as uniting goes.

Thanks bro.
 
City of Fort Worth, May, 2009

Storm Water Quality

Mobile Commercial Cosmetic Cleaning - Background

All Cities Must Have Storm Water Permits

All cities in the United States over 100,000 in population must now have a NPDES Stormwater Permit from the EPA to operate their municipal storm drain systems. One of the key elements of this permit requires the cities to create and enforce an ordinance which bans pollutant discharges to the storm drain. The City of Fort Worth ordinance reads; "A person commits an offense, punishable by a fine, if he introduces or causes to be introduced, any discharge to the storm drain system that is not entirely composed of stormwater." The EPA did grant certain exemptions to this rule in its regulations, and Fort Worth adopted numerous of these in its ordinance as defenses. Some of these defenses include discharges composed of runoff from lawn sprinklers, surfacing groundwater, air conditioner condensation and fire fighting water.

Cold Water Discharges by Power Washers

The Fort Worth ordinance contains a provision that may be used by cosmetic cleaners (power washers) under special circumstances. It states that a discharge or flow of cold water used in cosmetic cleaning that is not contaminated with any soap, detergent, degreaser, solvent, emulsifier, dispersant or any other cleaning substance may be discharged to the storm drain as long as the storm drain inlet is screened to catch debris and the discharge passes through an oil absorbent pad or boom. No oil sheen may be present in the discharge after it passes through the pad or boom. The City of Fort Worth Department of Environmental Management recommends screening the storm drain inlet with a 20 mesh or finer screen to catch the debris. Cleaning with hot water (over 110°F) is also allowed under this exemption as long as permission is obtained from Environmental Management prior to starting the job.

Cosmetic cleaners must be very careful if they choose operate under this provision. Even though they may be using water only, with no added detergents, degreasers, etc., they could easily wash off existing pollutants from the surface they are cleaning which could put them in violation of the ordinance.

Fort Worth Must Monitor its Storm Drains

Another element of the EPA Stormwater Permit requires Fort Worth to test selected areas within its storm drain system. Fort Worth has tested over 560 sites. Detergents were discovered in over 50% of these sites making detergents the most frequently encountered pollutant in City storm drains. Repeated field observations of cosmetic cleaning activities showed that a significant amount of detergents were being discharged into the streets and city storm drains. Because the City must show a decrease in the pollutants at the 560 sites over the five years of its NPDES permit, the city enacted specific regulations to limit these types of discharges. The regulations include banning cosmetic cleaning discharges to the storm drain and the implementation of a permit system for commercial mobile power washing activities.

The Cosmetic Cleaning Permit is administered by the Environmental Management Department because it is charged with implementing the city's EPA Stormwater Permit. Detergent in the storm drain is considered a stormwater issue. Other cities may regulate cosmetic cleaning activities through their Public Works Department, Water Department, Water/Stormwater Utility District or other agencies which oversee their EPA Stormwater Permit.

Disposal of Wash Water

The banning of cosmetic cleaning discharges from the storm drain left the operators with two disposal options. The first was to collect their effluent and haul it to an approved treatment facility. The second option was to discharge the effluent to the sanitary sewer, preferably at the job site. The City of Fort Worth chose to require the second option for several reasons. Hauling the waste water to a treatment facility proved too costly for most cosmetic cleaners due to the high per-gallon disposal cost charged by the treatment facilities. Limited testing performed by Environmental Management, in addition to data supplied by the power washing industry, revealed that the average cosmetic cleaning effluent tested below the city's numerical standards (i.e., temperature, pH, oil & grease, metals, etc.) used for approving discharges to the sanitary sewer as long as liquid accumulations of oil, gasoline, grease, etc., were pre-cleaned using an absorbent material.

Because it was determined that pollutant levels in the power wash effluents were low enough for discharge to the sanitary sewer, the Water Department was then concerned with volume. It was estimated that the total volume of wastewater generated by all the cosmetic cleaners operating in Fort Worth on any given day was not likely to exceed 20,000 gallons. The Director of the Fort Worth Water Department deemed this volume "insignificant" when compared to the City's total treatment capacity of 110,000,000 gal/per day.

The Water Department's final concern involved how the cosmetic cleaner was going to access the sanitary sewer. Everyone was in agreement that the waste water belonged to the property owner, not the cosmetic cleaner, so the waste water should be discharged on-site if possible. The ideal discharge point would be into a sand or grit trap such as those found in car wash bays. Unfortunately, few sites contain such facilities so the discharge options revert to sinks, toilets, floor drains and clean-out stubs. It does not matter which of these conveyances the cosmetic cleaner uses as long as the discharge does not contain grit, grease or other substances which could possibly clog the pipe, and the discharge meets the numerical standards discussed above.

Environmental Management recommends discharging through a 400 micron filter to remove the grit and sludge. It is up to the property owner to decide which conveyance to discharge into as they own the plumbing system located within their property lines and are ultimately responsible for what is in their system. It should also be noted that discharges into manholes are strictly forbidden, no matter where they are located. It is not only dangerous to remove the lid from a manhole but it is also illegal. Waste water that is pre-treated before discharge to the sanitary sewer is, by city definition, a process water and thereby subject to the rules and regulations of the Water Department's Division of Industrial Waste. Cosmetic Cleaners that utilize wash water recycling units fit into this "process water" category and must test their effluent at least once annually. The results of the tests must be sent to the Division of Industrial Waste to determine compliance with the numerical standards for discharge to the sanitary sewer.

The EPA requires that the Division of Industrial Waste have the ability to take samples from the effluent of all process waters, so cosmetic cleaners using wash water recycling units must supply a map of all of the discharge points they use as a part of their Cosmetic Cleaning Permit.
Robert is an "Information Hwy"
 
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Robert- are you famiiar with BMP grants? I'll use this link for an example. http://www.in.gov/idem/nps/3384.htm
How about environmental educational grants to implement those type course that are recognized by the state Gov't or even on a national bases?
 
Robert- are you famiiar with BMP grants? I'll use this link for an example. http://www.in.gov/idem/nps/3384.htm
How about environmental educational grants to implement those type course that are recognized by the state Gov't or even on a national bases?
 
Robert- are you famiiar with BMP grants? I'll use this link for an example. http://www.in.gov/idem/nps/3384.htm
How about environmental educational grants to implement those type course that are recognized by the state Gov't or even on a national bases?

John:

No, I am not famliar with it. I will check your link. Do you know what we need to do to make that happen?
 
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