EPA Enforcement in 2012 Protects Communities From Harmful Pollution

Steven:

There are general guidelines, but nothing is fast and hard! The EPA sets the discharge limits and your local AHJ sets the acceptable BMPs.

There are jurisdictions that do not honor "If your discharge wash water does not reach water of the United States, there are no requirements under the CWA. No off property discharge." The only recourse against jurisdictions that do not honor this is litigation. And the AHJs normally have more money than does the Contractor.

It comes down to "you have to know your territory".

Thanks for addressing my comments Robert.

I think you have highlighted an issue that any outreach program for our industry in educating contractors and local officials should address. The universal application across all jurisdictions of this aspect of the CWA should be a goal for us all - if there is no off property discharge, no requirements. I am not arguing the minutia of methods, but if we are working towards a more contractor-friendly solution, this is one starting point.
 
Is it Professional to post so many items about Jim G, then block Jim from answer those statement?

I have talked to Jim and he disagrees with a lot of things said about him as they are not true.
 
Lake Tashmoo Storm Water Remediation Project: First Flush Leaching Basins More Effective Than Expected
Contact:
Jane Peirce
Massachusetts Department of Environmental Protection
627 Main Street
Worcester, MA 01608
508-767-2792 | Jane.Peirce@state.ma.us
Primary Sources of Pollution:
storm water runoff
Primary NPS Pollutants:
suspended solids
fecal coliform bacteria
Project Activities:
12 first flush leaching basins
Results:
91 percent decrease in fecal coliforms
98 percent decrease in total coliforms
elimination of oil, grease, barium, chromium, and lead
shellfish beds reopened

<tbody>
</tbody>
Contamination from storm water runoff, particularly suspended solids and fecal coliform contamination, has forced many shellfish beds and public bathing beaches along the Massachusetts coast to close. The closures can range from a few days to the summer to the entire year, depending on the type and level of contamination. The town of Tisbury on the Island of Martha's Vineyard has numerous "hotspots" where access to shellfish beds and public beaches has been restricted because of storm water contamination. The residents of Tisbury rely on fishing and tourism for their livelihood, so it is imperative for the town to find ways to effectively treat storm water contamination.

At 1 mile in length, Lake Tashmoo is one of the larger of the saltwater lakes on the island that feed into the sea. It is an ideal habitat and breeding ground for oysters, scallops, clams, mussels, crabs, lobsters, and a variety of fish species that serve as the food source for larger fish, all of which are commercially harvested as the backbone of the island's fishing industry. In addition, the lake has a major beach area, a town dock, and boat moorings and is used for swimming, sailing, wind surfing, boating, and sportsfishing.

Before 1994 hard shell clam, mussel, and scallop beds near the storm water outlet were showing contamination from fecal coliform bacteria, heavy metals, and oil and grease. The Division of Marine Fisheries routinely closed the beds after large rainfall events because of fecal coliform levels in the water. The contaminant levels were consistently high enough that the shellfish beds were on the verge of seasonal closure, which would have effectively put the resource off-limits to the local townspeople and to the large seasonal population that flocks to Martha's Vineyard during the summer months. Recreational use of the lake is a major tourist attraction, and the town considered maintaining the lake in a viable and usable state imperative.

Adding leaching basins

In 1994 Tisbury Waterways, Inc., and the Town of Tisbury received 319 funding to install a series of 12 "first flush" leaching basins along road drains to capture and treat the road runoff that was contributing to the contamination of highly productive shellfish beds at one end of Lake Tashmoo. The first flush basins, installed along a 1.6-mile stretch of road, were designed to treat the first ¼ inch of rainfall, which contains most of the contaminants.

Each basin consists of a 6-foot by 6-foot perforated cement vessel filled with limestone, surrounded by a gravel bed. The limestone in the basins is covered with hydrophobic, oil-absorbing pads, which help to separate the hydrocarbons from the runoff. The limestone in the pits raises the pH of the runoff, causing heavy metals to precipitate and accumulate in the pit. Finally, the first flush basins provide additional residence time for fecal coliform bacteria to oxidize and decay. The treated runoff then passes through the gravel surrounding the pits into the subsurface soil.

Exceeding expectations

Comparison of contaminant concentrations in Lake Tashmoo before and after installation of the basins showed significant improvement in water quality. Samples from Lake Tashmoo during rainfall events showed fecal coliform and total coliform levels going down by 91 percent and 98 percent. Oil and grease could not be detected in the treated effluent; barium, chromium, and lead, which had all been present before installing the basins, could no longer be detected in the effluent. The project was deemed a success and recommended as a model for other storm water hotspots around Tisbury.

The system is exceeding the town's initial expectations. Although it was designed to capture and treat the first ¼ inch of storm water runoff, the system appears to be capturing and treating the first ½ inch of runoff. The sandy soils that underlie the leaching catch basins allow the treated storm water to percolate into the ground more quickly than the designers anticipated, thus allowing the system to capture additional storm water.

As a result, since the basins were installed there has been no discharge at all to Lake Tashmoo during moderate rains. Even during heavy rainfall, less storm water is discharged into the lake and the water continues to be of significantly better quality than before the basins were added. The Massachusetts Division of Marine Fisheries has continued to monitor water quality at the shellfish beds. The beds have not been closed during the past several years, and there is no longer any thought of seasonal bed closure.

Robert Hinderliter Notes: I do not believe it is proper to add Power Washing Waste Water to these beds.

I believe is similar to Street Sweeping: If you sweep a street, then discharge our dirt into the MS4; is that good BMPs? Or does the dirt need to disposed of somewhere else?

So why would you discharge your Power Washing Water into these StormWater Remediation Devices when they are not designed to accept this concentrated waste?
 
Thanks for addressing my comments Robert.

I think you have highlighted an issue that any outreach program for our industry in educating contractors and local officials should address. The universal application across all jurisdictions of this aspect of the CWA should be a goal for us all - if there is no off property discharge, no requirements. I am not arguing the minutia of methods, but if we are working towards a more contractor-friendly solution, this is one starting point.


attachment.php
attachment.php
attachment.php
attachment.php
 

Attachments

  • Capture 20.JPG
    Capture 20.JPG
    102 KB · Views: 7
  • Capture 21.JPG
    Capture 21.JPG
    25.4 KB · Views: 73
  • Capture 22.JPG
    Capture 22.JPG
    70.2 KB · Views: 73
  • Capture 23.JPG
    Capture 23.JPG
    143.7 KB · Views: 77
  • Capture 24.JPG
    Capture 24.JPG
    143.4 KB · Views: 76
I want to be clear in that I would not advocate for any discharge to the MS4, unless under an approved NPDES related exemption/approval, I am solely discussing discharge and treatment on private property. With correct methods and an understanding of on-property structural BMPs, there should be no discharge to MS4 or US waters.

South Carolina Department of Health and Environmental Control:

http://www.scdhec.gov/environment/water/swater/ms4s.htm

"By definition an MS4 is a system of conveyances that include, but are not limited to, catch basins, curbs, gutters, ditches, man-made channels, pipes, tunnels, and/or storm drains that discharge into Waters of the State. For these conveyances or system of conveyances to be recognized as an MS4, a state, city, town, village, or other public entity must own them. These conveyances must also not be part of a Publicly Owned Treatment Works and may not operate as a combined sewer."

I understand that your guidelines are just that, but I would argue that these guidelines need to be separated into the different aspects of cleaning our industry covers. Sidewalk Cleaning, Fleetwashing, KEC, Boat Detailing, House Washing, etc. deal with different substrates, different contaminants, take place in different locations, where each location has varying characteristics as related to discharge, washwater control and contaminants.

I hope that an end result of this discussion can be a meeting of the minds in presenting an accurate account of our environmental impact and pollution control benefits of what we do. Granted, I do look at this primarily from the viewpoint of a commercial sidewalk and building cleaning contractor.
 
Is it Professional to post so many items about Jim G, then block Jim from answer those statement?

I have talked to Jim and he disagrees with a lot of things said about him as they are not true.
Just as many things, there are some things that are rights and some that are privileges. Jim lost the privilege to post on PWI a few years ago. Contrary to what many believe, I was not the admin that banned him. I avoided that because I had a personal grievance with him. BTW, the person that brought up Jim is not a perso n that is a mod or admin on this board, but someone that he is using, just like you, to plead his case so that he can come here and SEO his website and cause problems.
If you really look at him as an authority, anywhere, I think you are sorely mistaken. He is not what he portrays himself to be.
 
First off thanks for taking the time Nigel for filming these educational video's.

So from my take just the water run off from the rain it's carrying pollutants in it which will eventually reach the US waters via a storm drain. So now if that roadway was concrete and a surface machine was used on it and you collected the water from the runoff from that its probably going to be blackened even more.

This is why because of stringent rules if an AHJ were to appear and did a test on the run off there may be problems if there is at least no oil sock for example in there somewhere.

Where not talking about what we want to be allowed to do. Where talking about what could happen to us..

So that's my take.. Is it similar to yours at all?


Thanks John T,..... I often thought about the quality of roadway first flush storm water, and that of the roadway/parking lot storm water conditions in general, I wanted to inject this in the discussion as there has been mention of the affect of "rain event" on storm water quality.

I also wanted to visualize a sample , from there we can compare/discuss some of the 'process water' (as defined by AHJ) for various cleaning activities;

1)we can discuss on property systems that may be able to threat some types of our 'process water' under certain conditions.

2)and what I think maybe the majority of "product" that is removed during the concrete cleaning process for example: drive thru cleaning, fuel pad cleaning, and other concrete surfaces that are driven over by vehicles.

3)Discuss how much hydrocarbons is in the process water from these types of cleanings (not a spill but oil drips that have saturated into the concrete)

4)the effect of adequate frequency contractor cleaning these surfaces would have on storm water quality.

5)the quality of sidewalk wash water after practicing dry pre-cleanup BMP,s and adequate frequency sidewalk cleaning.

Here are 18 hour photos of the sample

DSCN3070.JPGDSCN3071.JPGDSCN3072.JPG
 
Just as many things, there are some things that are rights and some that are privileges. Jim lost the privilege to post on PWI a few years ago. Contrary to what many believe, I was not the admin that banned him. I avoided that because I had a personal grievance with him. BTW, the person that brought up Jim is not a perso n that is a mod or admin on this board, but someone that he is using, just like you, to plead his case so that he can come here and SEO his website and cause problems.
If you really look at him as an authority, anywhere, I think you are sorely mistaken. He is not what he portrays himself to be.

Scott:

I do not think that is the point, "what I think of Jim B". This country is founded on "free speech" and the right to face your accusers.

If you allow negative comments about Jim B. that he says are not true, and is not allowed to defend himself; then that is not ethical.
 
"If your discharge wash water does not reach water of the United States, there are no requirements under the CWA. No off property discharge."

Does this not pretty much end the conversation for the majority of sidewalk and building cleaning contractors using water only on regular maintenance accounts?

Can anyone cite studies (other than what is here: http://cfpub.epa.gov/npdes/stormwat...action=factsheet_results&view=specific&bmp=72) on effectiveness of bio retention areas?

Or information on on-site stormwater management building/development code standards for commercial new construction. I want to look at this from another point of view in that where the responsibility for waste water lies with property owner... Has treatment for discharge already been taken care of in the form of dry retention/detention ponds, interceptors, bio retention ponds (lined/unlined), grassed swales, etc.

Good resource for post construction BMP Factsheets: http://cfpub.epa.gov/npdes/stormwater/menuofbmps/index.cfm?action=min_measure&min_measure_id=5

So if these elements are incorporated onsite and the pressure washing contractor is applying reasonable methods in removal of debris and removing oil - where is the problem?

In looking for effectiveness of structural BMPs I found thisnresource - thorough breakdown of types and effectiveness, a must read for all contractors to further understanding of this topic.

http://www.lincoln.ne.gov/city/pworks/watrshed/educate/bmpguide/pdf/bmpguid3.pdf


Great informational links Steven, thanks


Ron, are you thinking the installation in the gas station video is similar to this :

http://cfpub.epa.gov/npdes/stormwat...ion=browse&Rbutton=detail&bmp=78&minmeasure=5
 
Scott:

I do not think that is the point, "what I think of Jim B". This country is founded on "free speech" and the right to face your accusers.

If you allow negative comments about Jim B. that he says are not true, and is not allowed to defend himself; then that is not ethical.
Robert your wasting your time. The admin who gave Jim the ban is not in this thread. The influences that caused Jim to get a "Life time" ban are in here and they know who they are. Those ones are deadlier because they don't want Jim to speak his mind freely here. He's the only one I know who got a "Life time" ban anywhere. Talk about stomping a guys freedom of speech.... Also Expect these influences now to notify tue admin who gave him the lifetime ban so he can respond---- that's what the "infuences do".
 
I hope that an end result of this discussion can be a meeting of the minds in presenting an accurate account of our environmental impact and pollution control benefits of what we do. Granted, I do look at this primarily from the viewpoint of a commercial sidewalk and building cleaning contractor.
BINGO!!!
Steve that's should be the goal. Some guys in there 40's-50's and further on up can not and will not let your thought process in there head. That gets worse with age. It's called "Stubbornness"

Everyone reading this should take heed of what you just posted above. That's the best way to get things done and if you look back in the Internet history you'll see it almost never happens---- reason why this Industry is stuck in the mud.

EXCELLENT POINT!!
 
Scott:

I do not think that is the point, "what I think of Jim B". This country is founded on "free speech" and the right to face your accusers.

If you allow negative comments about Jim B. that he says are not true, and is not allowed to defend himself; then that is not ethical.

Jim has an open forum at your son's board where he is allowed to belittle Ron and me. If he truly wants to respond no one is stopping them there.

I spoke with Tim Potter, the regulator in charge of Jim's area, at the Tri-State seminar a few months ago. He has known Jim since the 90's and likes him.

Tim seemed to be tough, but compassionate towards business. In contrast to Jim's horrific picture he paints Tim says they rarely every attempt to fine anyone unless they are multiple repeat offenders.

He said what has worked for them is to find the problems, and rather than fine the contractor, educate them and give them every opportunity to fix the problem. He stated that they are not out to hurt businesses and would rather work with them to help them become compliant. That is saying a lot because, in spite of the fact that their website points to the more relaxed BASMAA BMP's for training, their actual regulations are more strict than the BMP's.

Tim is also the POTW regulator in that area. Jim had said numerous times that the Contra Costa regulator told him that "one drop of caustic" would destroy the sewer system. That is why Jim made such a show of finding a hiding place on his trailer to take back a bag of caustic he bought here in Las Vegas so he wouldn't get "caught" in California with this deadly substance. lol. I asked Tim about that and he said it was absurd and that no one would have told him that. He went on to explain what I already knew about damage that could be caused to the plant if high concentrations of high PH substances made it to the plant.

I asked how much it costs for testing of contractors reclaimed water onsite. He said it is rarely done anymore, but contractors have not had to pay for testing since around 1996. Jim was one of those who paid for testing ONCE. And he even went on to say that Jim will never let him forget it, and that is why he remembers when it was.

Contrast that statement from the regulator with this statement a full twelve years after the last test contractors were required to pay for:

jimtest_zpsec9c47cb.jpg



Notice also that in 2008, according to Jim, in that tough area, contractors were required to filter "lightly" runoff from hot water/no chem cleaning before it goes into the STORM drain.

This all goes towards credibility Robert. Do we, as an industry want someone to represent us who has no problem playing fast and loose with the truth then it comes to something as serious as regulations that affect our industry? Do we want someone who could stand in front of people and make statements like the "one drop of caustic" statement? What happens to our credibility when the regulators start putting two and two together and realize that the "environmental chair" representing our industry has told them one thing on the phone and told one of their other staff something entirely opposite? It's about credibility Robert.

And for the record, you can ask any of the admins, I have asked numerous times for them to allow Jim back on this board. I just asked on New Years Eve. I would love to have him answer some of the accusations because he will just tie himself up in the process because one thing I learned a long time ago is, it's a lot easier to just tell the truth than to try to remember all the details of deception.
 
I can't say I like the fact that you went into Jim's area to talk about him to one of the regulators Jim knows. Makes me think your next stop could be MD or NY or maybe even Mesa AZ. I guess your willing to go that far to prove your point and in all fairness hopefully you were fair and honest talking about Jim and you didn't bring your emotions in on this.

Also, like you, Jim should be allowed back in here. A lifetime ban is harsh. Talk about over regulating..lol but it's not going to happened because of..... Well let's not go there.

I have to commend you Tony for speaking up against a lifetime ban on him. Also when you know who flies in here soon to defend himself as not being an "influence" with this lifetime ban-- I spoke out in someone's behalf who had a health issue recently..... So everything obviously on the net is not what it seems... It all connects clearer on the outside.
 
I am a voice against Jim G coming back here - admin and staff have got enough baby-sitting to do... I supported Russ in this decision when he was admin.

But let's not turn this into a different topic of conversation. As an official representative of an industry organization, his past proclamations and comments are up for discussion as it relates to finding an amicable solution.

Many of us have objections with how we, as a group, are being presented to authorities.
 
You don't like the fact that Tony went to Jims area?What do you think Robert has been doing for years?

Sir:

I cannot remember going to a local regulator unless invited by a local contractor or the AHJ themselves.

What I have done is to speak at conferences and industry trade shows, sometime by their request and sometimes at my request.

It has taken too much time to do one on one solicitation. However, considering today's environment this may have to change.
 
For the record I skipped Contra Costa County on my trip. I met with Carlos Gonzales and had dinner there but refrained from meeting with any regulators in that county specifically because it was Jim's back yard.

I told Carlos at the time that I was going to avoid Contra Costa to avoid looking like Hilborn or Jim and Jim Cooney who stated that they came to Ron's and Scott's county and met with regulators in secret.

I did, however, meet with some of the surrounding counties and got a good feel for their attitude towards our industry.

I met Tim, Jim's regulator, at the Tri-state water conference in Primm, Nevada where he was a speaker. I was there as a guest of another speaker and was unaware of who Tim was till I saw his title on the program.

I spoke with him for quite a while in the hallway between sessions.

Sent from my DROID RAZR using Tapatalk 2
 
For the record I skipped Contra Costa County on my trip. I met with Carlos Gonzales and had dinner there but refrained from meeting with any regulators in that county specifically because it was Jim's back yard.

I told Carlos at the time that I was going to avoid Contra Costa to avoid looking like Hilborn or Jim and Jim Cooney who stated that they came to Ron's and Scott's county and met with regulators in secret.

I did, however, meet with some of the surrounding counties and got a good feel for their attitude towards our industry.

I met Tim, Jim's regulator, at the Tri-state water conference in Primm, Nevada where he was a speaker. I was there as a guest of another speaker and was unaware of who Tim was till I saw his title on the program.

I spoke with him for quite a while in the hallway between sessions.

Sent from my DROID RAZR using Tapatalk 2

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!
 
For the record I skipped Contra Costa County on my trip. I met with Carlos Gonzales and had dinner there but refrained from meeting with any regulators in that county specifically because it was Jim's back yard.

I told Carlos at the time that I was going to avoid Contra Costa to avoid looking like Hilborn or Jim and Jim Cooney who stated that they came to Ron's and Scott's county and met with regulators in secret.

I did, however, meet with some of the surrounding counties and got a good feel for their attitude towards our industry.

I met Tim, Jim's regulator, at the Tri-state water conference in Primm, Nevada where he was a speaker. I was there as a guest of another speaker and was unaware of who Tim was till I saw his title on the program.

I spoke with him for quite a while in the hallway between sessions.

Sent from my DROID RAZR using Tapatalk 2
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??
 
I am a voice against Jim G coming back here - admin and staff have got enough baby-sitting to do... I supported Russ in this decision when he was admin.

But let's not turn this into a different topic of conversation. As an official representative of an industry organization, his past proclamations and comments are up for discussion as it relates to finding an amicable solution.

Many of us have objections with how we, as a group, are being presented to authorities.
I know Russ's stance on this and he has his reasons. The lifetime ban I thought was a bit much and I felt that there were outside influences with 2-3 main guys in the middle of it.. Tony asking for Jim's ban to be lifted here so that takes him out of that 2-3.
Either way Russ and I agreed to disagree on this when we worked together on the UAMCC bb and we worked together fine.

Back on topic Steve your bringing up some great points on this thread topic.
 
Back
Top