Here are my comments. I'll post them here and if I'm wrong on some things at least there will be some discussion before I submit my fax comments:
1) The beginning sentence in line 13 pretty much eliminates any changes in this document. It's either the same as the city of Ft Worth or it isn't. If it isn't, then the proposed BMP's might lose some of their Zing power because we aren't quoting an actual city's bmp.
2) Line 20 is a good line regarding "resulting in the lowest amounts of detergent..." What's lacking here is a study showing what our general runoff consists of in the normal course of our business. I spent some time on the phone this morning with Michael and one of the things about this Ft. Worth BMP is that it came in response to restrictions that were going to affect the fleet washing segment of the industry and testing and writing of BMP's were pointing in that direction. Plaza cleaning runoff wasn't even tested. I submit that they aren't even comparable and we need to 1) do our own testing for base numbers, then 2) have an independent lab do the testing. We are not polluting. We need to affirm that and just "saying" it without proof is not an affirmation.
3) Line 27 is good.
4) Line 31 could be changed from "Cosmetic Cleaning" to "General Health and Safety Cleaning"
5) Lines 62-69 - Why are we giving three options? What about evaporation? This is confusing the issue.
6) Lines 83-90 - Also confusing. This is good for training courses, but is too much information for simple BMP consideration. That's just my opinion, I'm open for comments. Maybe I'm missing something.
7) Lines 91 and 92 are awesome. We need some more lines like that.
8) Line 177+ why are we discussing recycled wash water? That opens up another can of worms regarding transport.
9) Line 135-137 is out of line. Where is the proof that hot water produces more pollutants than cold? Where are the studies showing this or is this just made up? Of course hot water cleans better, but does it introduce any more POLLUTANTS than cold water does? It's this kind if stuff that get's places like Houston started on hot water restrictions. We need to avoid it like the plague.
10) Line 142 - The clean water act only requires the use of technology that is economically feasible. (I'll cite it later if I have to) Disposing through and EWC or demanding methods that the market will not bear are not required under the CWA.
11) Line 173 - We need to emphasize that we are in the Health and Safety business.
12) Why is line 135 there?
13) Lines 190-197 shouldn't be in there at all - it's training material, not BMP material.
Skip the fleet and car washing sections. I don't know jack about fleet washing and will gladly defer to someone who does.
14) Lines 280-286 sound great. Maybe if we defined "frequently cleaned" we could get a lot more frequent contract work and use the "frequently" definition to discount services cleaned "frequently" and make them pay dearly otherwise.
15) Line 294 - We only do building washing for dirt out here. Why would that require sealing off the storm drains?
This is my "first glance" impulsive look at the proposed BMP's. I'd like to hear some discussion before sending any recommendations. Or, maybe this BMP shouldn't even be considered at all. What do you guys think. I'm open for any discussion.
Just going into a little bit of detail for those that wrote up this stuff and reasons why this is not really about "cosmetic cleaning" but "safety and healty cleaning".
I am not sure who wrote these but different parts of the country have different cleaning issues and for the most part, most of us don't do "cosmetic cleaning", we provide "safety and health cleaning". When you live close to the water you have lots of mold, mildew and algae problems that need to be kept clean. It grows everywhere, on the sidewalk (mold, mildew and algae, there is very little dirt there and becomes a serious slip hazard), on houses and buildings (mold, mildew and algae......health issues), grows on roofs (fungus, causes roof issues along with possible health issues) etc......
Most of the sidewalks here have mold on them, you know it is mold because if you pour bleach on dirt, most of the time the dirt does not change color but when you pour bleach on sidewalks, they change colors and get clean but it is cheaper to pressure wash and if you use hot water you are also killing the mold. Sidewalks and driveways that have a lot of shade on them or buildings that block the sun get lots of mold, mildew and algae growth which will become a serious slip hazard besides a general health issue. It would be stupid to say that the EPA will not let us clean the sidewalks so people will slip and fall because the mold and algae on the sidewalks and sue the owner because they were not allowed to clean. This is not cosmetic, this is for safety and health.
Fleet washing, this is somewhat cosmetic but it is to keep the vehicle clean so you can see the license plates, reflectors, warning placards, lights, etc....you can't just drive around with the vehicles black with road grime but it is also for safety issues like you have to clean the trucks and trailers to see if you have leaking seals, gaskets, etc... which can become a serious hazard if not fixed but if everything is dirty you sometimes cannot see the issues.
Houses and buildings here have mold, mildew and algae on them (just like the sidewalks and driveways) so again, this is a health and safety issue, not really cosmetic cleaning. I am not sure if any studies have been done but I don't think that it is healthy to have mold, mildew and algae all over your house, driveway, sidewalks and roof.
Drive thru lanes, parking lots and parking garages. This is not really cosmetic because you need to clean up the free-standing oil and dirt because again, this will cause silp and fall hazards which will result in people getting injured, lawsuits, lost time from work, bad publicity, etc.... these need to be maintained so that people are safe walking in these areas but also so they don't track the stuff all over the place and cause other slip and fall hazards where they track the stuff.
Lines 62-69 should be labeled for Fleet Washing as this is very vague, you cannot expect a property owner to install this into a parking lot, you cannot wash sidewalks onto this or even a portable wash mat. I agree with Tony, evaporation is also a good choice but you can also put down oil socks/pads to catch the oil and filter this and let it go onto grassy areas like it mentions in the clean water act.
Line 83...again, change this to "Safety and Health Cleaning", not "cosmetic cleaning".
Line 93... Most of us don't use much soap but when you consider when you are rinsing with typically 5.5gpm or more, the ph will usually be around 6-8 because of the amount of water being used so this really is not an issue here. The hot water....Someone needs to make a video with the heat gun showing how fast the hot water cools down. There is a lot of heat loss just with the water coming out of the nozzle hitting the air then the surface but then the more surface contact the water has, the faster it is cooling down because the surface is absorbing the heat and there is a lot of surface that we wash typically. I bet that the water does not have to travel very far before it becomes ambient so I am sure that before it reached the sanitary sewer it would be 100 degrees or less. As for the Houston morons, by the time you washed with hot water, it ran down the sidewalk or street and if it ever reached a creek, river, bay or any other body of water I seriously doubt it would be more than 100 degrees unless it is a very Hot Texas sunny day, I think that it would not have to travel even 50' before it was the temperature of the sidewalk or street.
Line 98.... Like Robert H. mentioned, you can use a 20 mesh screen, 5 micron filter bag, filter screen or just about anything that keeps the sediment out of the sanitary sewer. By listing Sand trap, grit trap, grease trap or clarifier you are giving the AHJ more reasons and info to make up ordinances to ticket you, keep it simple. Most mobile contractors don't have a sand trap, grit trap, grease trap or clarifier on their mobile pressure washing trailers so why even mention it?
Line 99 is good, it all will eventually go down the sanitary sewer.
Line 104 This should be option #1 or First Choice. With so many areas in the country in a drought, water restrictions, water shortages it only makes sense that contractors will be more water efficient than a homeowner but if we pump the wash water onto landscaping then we are helping the environment by keeping the landscaping hydrated, we are helping the landscaping absorb the sun's heat, the homeowner will not have to water that day we are there pressure washing, the sun is evaporating the water into the atmosphere so it can fall somewhere else (hopefully where they need it) and in some places like in Texas and Louisiana we are on a mud-flat meaning that the soil expands and contracts up to 40% so helping the soil stay hydrated we are helping a small amount to keep house and building foundations from cracking in the droughts. In the 80's we had a bad drought and lots of houses had foundations cracking because the soil was drying out too much and caused the foundations to crack. This was a good time for plumbers for re-routing and for foundation companies.
Line 109 I am sure that neighbors would not mind having wash water put onto their landscaping, especially during a drought so they will not have to water that day.
Line 114 I would like to see proof or studies that back up this claim that off-property discharge will cause serious harm to ground water. The dirt, sand, gravel and clay is a natural filter and will filter out the dirt as it gets deeper into the soil and it takes a long time, not hours or days.
Line 120 This just does not make any sense at all. If you are going to re-use the wash water, you will typically have an oil water separator and a filter system so that cleans up the water so it does not damage the pump. This line 120 makes it sound like you are going to dump millions of gallons of wash water. Most guys don't haul water and if you are re-using the wash water it is going to be used for cleaning and the little bit that you might end up dumping will probably go onto the landscaping or sanitary sewer. Again, we are not talking millions of gallons of re-used wash water.
Line 122 This also does not make any sense at all. Who is going to store their recycled wash water when they are a mobil contractor????? If guys re-use the water, it is for the cleaning job, typically concrete and will be used up, not stored. Tested annually and reported??????? I wonder who makes up this crap?
Line 124 Recycling wash water is not concentrating pollutants. Again, who made up this crap????? Anyone that is going to re-use their wash water through their pump will filter it down to about 5 microns or so, so that it will not damage the packings. If you are filtering the water, how are you increasing the contaminants?????
Line 126 Refer back to the above comment as this is another load of crap. Again, anyone that is going to re-use the wash water through their pump will be filtering the wash water and if you are continuously filtering the water for the job you are doing, there will always be a loss due to absorbtion and evaporation so you will have to have fresh water going into your tank or you will eventually run out of water and have to stop working at the job. If you are adding fresh water, filtering the re-used wash water, how are you increasing the contaminants and eventually creating hazardous waste? Hazardous waste????? Really???? Who writes this load of crap???
Line 127 There is a lot more to hauling hazardous waste besides having a waste haulers permit. There is the CDL, X-endorsement with the CDL, there is the registering the tank, registering the vehicle the tank is on, there is a waste haulers license besides all the training to get the above. All this info should be there on line 127 so people really know what they are getting into if they believe the morons in Houston and want to be waste haulers just because the city tells them to. I would hate for a DPS officer or State Trooper pull them over with a load of wash water without having the above taken care of first.
I will be back tomorrow to tear into this stuff and type more, time to get some sleep. hahahahaha
