Did anyone see this thread over on the grime scene

Tony Shelton said:
There are no minimum requirements for powerwashers in any way, shape or form in the Clean Water Act. The Clean water act allows for XXXX amounts of discharge.
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Tony...I Love You Man!!! Please explain these 2 sentences. Show me where in the CWA it says this. I am not in any way "Brainwashed" about reclaim, to even use that term about me is a little out there even for you. I'm talking about being "Compliant" in whatever part of "Mobile Washing" Contractors may be in. This doesn't mean "Vac Systems" this may mean Evaporation, Sump Pump, Screening, Diversion etc.

I do not agree with Robert H. being the "Environmental Chairman" of the UAMCC. I have nothing against Robert and respect the Man Tremendously. But the fact is he is a Distributor, Retired or not, first and foremost a Distributor. This does not bode well for an Org. that touts its self as "By Contractors For Contractors".
 
Scott Stone said:
Here is my response:
For the record, I was on the UAMCC transition team and was going to head up the environmental committee. After an "interesting" discussion, and some things I did not agree with, I resigned the UAMCC board. At the time, there was an effort made to make it look like I had family issues, which could not be further from the truth. Then a solid effort was made to discredit my name, because I would not do anything. Of course, when I asked for an assignment, I was told that they did not want to
Overburden" me.
Then, about a year and a half ago, I was asked to join the PWNA, and at the time, a specific request was made that I serve on the environmental committee. The first round of suggested environmental recommendations was done without my knowledge. I always thought that if you were asked to serve on a committee, it was because they wanted your expertise. I was evidently wrong, because a complete set of BMP's were developped, that were supposedly not going to be shopped around, but were going to be presented to government organizations. I don't know how the not shopping and presenting to government organizations works. It does not make sense to me.
I say all that trying to establish that I have a bit of experience with the environmental areas of this industry, and will also mention that I developped the hazardous materials disposal program, from scratch, for the largest electric utility in Arizona, with something like 3,000,000 customers.
As I look at the efforts to develop industry standard BMP's, I am looking at it as a fools errand. Here is the reason why, and I will use an illustration. If I were going to sell pants, I could not manufacture just one pair of pants, and have it fit every need. There would be people bigger, smaller, some would want shorts, because that is more comfortable in their neighborhood, others would not want to wear jeans, because they prefer slacks. There are a lot of different things that can influence those pants, and the purpose that needs to be filled.
With the environmental BMP's it is very similar. You have flat work, you have Parking garages, there are fleets, decks, kitchen hoods, and every other type of washing that can be imagined, and we, as entrepreneurs are an imaginative bunch. Then we could throw in some other parameters, we have coastal environments, we have deserts with dry wells, there are locations with large areas that are covered in grass on site, there are other areas that are solid asphalt and concrete. There are so many different types and needs of recovery situations, it borders on the ridiculous. There is ABSOLUTELY no way to regulate ever situation, with one standard set of BMP's, unless full recovery is advocated.
The problem with full recovery is another complete, and perfect bag of worms. Where is it going to be disposed of? Who is going to transport it? where is the chain of custody, after it leaves the property? Is it really the best and most effective method of waste water recovery?
I do not see how it can be done, and I have looked at a variety of ways and means to see if it could be accomplished. I am not sure that it could be done if it just applied to the Phoenix area, with the large variety of washing that happens here, and all of the different regulatory agencies involved, many of them that have no clue that there might even be an issue.
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Now I'm really confused. Hey I'm getting older maybe when I get real old instead of Depends adult diapers I can just buy a pair of Those RECLAIM PANTS you're talking about. Better try to get those patented before the PAWN Org does, I mean PWNA
 
jlpressure said:
Now I'm really confused. Hey I'm getting older maybe when I get real old instead of Depends adult diapers I can just buy a pair of Those RECLAIM PANTS you're talking about. Better try to get those patented before the PAWN Org does, I mean PWNA
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That might just solve your underware problem!
 
The CWA works with NPDES permits.

NPDES permits are issued to entities like cities and large producers of contaminants such as cement factories and other such manufacturing facilities and other stationary industries that produce waste that can and does enter into the "waters of the US". They are called "permits" because that is exactly what they do. They Permit predetermined levels of discharge as acceptable. It is the goal of the entity to try to remain within the limits of that permit. There are lots of loopholes and fines are rare.

Somewhere on the internet there is a searchable database of all fines levied by the EPA. (There aren't many) I've spent a few hours researching it in the past to refute the garage king's claims of huge EPA fines to contractors but don't have it in my favorites and don't have time to look it up today.

Say Fayetteville holds an NPDES permit. You, as a small contractor operating within the area are not a large enough producer of hazardous material to need a permit. That means that YOU are covered under Fayetteville's permit.

Now let's use a made up quantity of measure that's easy to understand. Let's say Fayetteville is allowed 10,000 barrels of grease/dirt/sludge/chemicals, etc per year on their permit to go into the water. IF they exceed that 10k barrels they MAY have a problem with the EPA. They have to monitor this and are audited by the EPA. So they in fact are ALLOWED a certain amount to go DIRECTLY DOWN THE DRAIN and it is 100% legal and proper.

Now, where did "nothing down the drain but rain" come from? I firmly believe the Robert is the author of that phrase. I've searched the internet using a few different search engines and the oldest such references are direct quotes from Robert. It is a catchy phrase if you are promoting picking up all the water you put down. I'm not saying he started that with a wrong motive, I'm just saying it is a false statement and it has had devastating effects on the industry and has led to the "brainwashing".

You see, the CWA allows for a lot down the drain. Each permit holder is allowed a certain amount. Many city officials themselves don't even quite understand this because of that incessant "nothing down the drain but rain" catchphrase ringing in their heads.

Our problem is not with the EPA. Our problem is with the local jurisdictions who have been exposed to the brainwashing and think they are either (a) protecting their environment by not allowing ANYTHING down the drain or (B) see this as an opportunity to collect fines.

It is our job to show them that our impact is POSITIVE on the environment. Cost effective cleaning around surfaces we walk on and touch is a necessary effort just like controlled burning of forests is necessary to save the whole forest. It's no more irresponsible to let the forest thicken to the point where a lightning strike takes the whole thing down than it is to increase the cost of surface cleaning to the point where no one can afford it.
 
Kory said:
That might just solve your underware problem!
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I always thought that would be a great idea, adult diapers big enough to hold a 12pak with team logo's, this way you will never miss a play again.
 
Tony Shelton said:
Say Fayetteville holds an NPDES permit. You, as a small contractor operating within the area are not a large enough producer of hazardous material to need a permit. That means that YOU are covered under Fayetteville's permit.

Now let's use a made up quantity of measure that's easy to understand. Let's say Fayetteville is allowed 10,000 barrels of grease/dirt/sludge/chemicals, etc per year on their permit to go into the water. IF they exceed that 10k barrels they MAY have a problem with the EPA. They have to monitor this and are audited by the EPA. So they in fact are ALLOWED a certain amount to go DIRECTLY DOWN THE DRAIN and it is 100% legal and proper.

You see, the CWA allows for a lot down the drain. Each permit holder is allowed a certain amount. Many city officials themselves don't even quite understand this because of that incessant "nothing down the drain but rain" catchphrase ringing in their heads.
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Tony this is wrong and misleading, I know what an NPDES permit is. The City per say, is not issued a NPDES permit, the Waste Water facility (Or Any Industry That Discharges To A Receiving Stream) of that City is issued and must have this permit. It is issued and enforced by the State and (To a certain extent) overseen by the EPA. You're talking about "Sanitary Drains" not "Storm Drains". Don't get people confused on this.

Yes the CWA does allow a lot down the drain, The Sanitary Drain Not The Storm Drain!!! The only way you can "Piggyback" an NPDES permit from your perspective City is to get permission to dump your wash water in their sewer for treatment.

To my knowledge there is no such a thing as a NPDES permit to dump untreated wash water in a Storm Drain that empties to a receiving stream . If you know something I don't please direct me to a website or something so I can look at this.

Other than that, please answer to 2 quoted sentences in my last post that you made. Just tell me where it says this anywhere.

Yes you are completely correct, it is the Cities not the EPA that we have to worry about. The head of the region (EPA) at the Houston meeting even said "Power Washers Are Not Even On Our Radar" The storm water people in Houston didn't know their butt from a hole in the ground, did you see the DVD?
 
Guy , that federal guy that said we are not on his radar.

They didn't even have him at the last meeting.

There program is changing , why because they simply got enlightened there city private properties are about 85% compliant. Property's are being retrofitted each and every month as pavement areas are remodeled. All based on permeable surface
 
Ron Musgraves said:
Guy , that federal guy that said we are not on his radar.

They didn't even have him at the last meeting.

There program is changing , why because they simply got enlightened there city private properties are about 85% compliant. Property's are being retrofitted each and every month as pavement areas are remodeled. All based on permeable surface
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Please Ron tell me that the person that "Enlightened" them was the Environmental Chairman of the UAMCC / P$NA??? I'm sure it was since he would surely know this seeing this is his home State and with his experience and credentials and all.
 
Guy, I know you are well versed in the wastewater industry. I am certain that you are mistaken in your assumption. And no, I'm not talking about the sanitary sewer system.

Here: http://www.epa.gov/lawsregs/laws/cwa.html

states the following:

The CWA made it unlawful to discharge any pollutant from a point source into navigable waters, unless a permit was obtained. EPA's National Pollutant Discharge Elimination System (NPDES) permit program controls discharges. Point sources are discrete conveyances such as pipes or man-made ditches. Individual homes that are connected to a municipal system, use a septic system, or do not have a surface discharge do not need an NPDES permit; however, industrial, municipal, and other facilities must obtain permits if their discharges go directly to surface waters.

Industries such as ours are covered by the city's GENERAL NPDES permit - http://cfpub.epa.gov/npdes/permitissuance/genpermits.cfm

You have heard of Phase II

Phase II is a federally mandated program that affects those municipalities with populations less than 100,000. On March 10, 2003, these municipalities were required to apply for and obtain a general permit for the stormwater runoff from residential, commercial and industrial areas into streams, lakes and rivers.

Guy, this is not a permit that only specifies wastewater runoff from treatment plants. This is a general permit that covers all runoff.

Are we in agreement with this?

You asked about these statements I made:

There are no minimum requirements for powerwashers in any way, shape or form in the Clean Water Act. The Clean water act allows for XXXX amounts of discharge.

I'd ask you the following. Please show me anywhere in the clean water act that says "nothing down the drain but rain". You won't find it on any epa documents or CWA document. You will, however find it all over the place on municipal BMP's - right above where it says "for more information contact - PWNA - CETA - and Delco".

We should have a posting contest to see who can post the most city or state sites that have PWNA, CETA or Delco on them. Ron, you up to put up a prize for the winner?
 
So lets see what the EPA says

[h=1]NPDES Individual and General Permits[/h] New permit links coming soon!
If you need a copy of an NPDES individual and general permit or a fact sheet for major facilities issued after November 1, 2002, contact your permitting authority for assistance.

  • An individual permit is a permit specifically tailored to an individual facility. Once a facility submits the appropriate application (s), the permitting authority develops a permit for that particular facility based on the information contained in the permit application (e.g., type of activity, nature of discharge, receiving water quality). Note: For individual permits, WWTPs can be found in the Electric, Gas, and Sanitary Services category.

  • A general permit is an NPDES permit that covers several facilities that have the same type of discharge and are located in a specific geographic area. A general permit applies the same or similar conditions to all dischargers covered under the general permit. Using a general permit to cover numerous facilities reduces paperwork for permitting authorities and permittees, and ensures consistency of permit conditions for similar facilities.
States may apply to EPA for authorization to issue general permits. Once EPA or a state has issued a general permit, a facility wishing to be covered under the permit submits a Notice of Intent (NOI) to the permitting authority. EPA or the State may still require the facility to submit an individual permit application and receive an individual NPDES permit if it determines that coverage under the general permit is inappropriate.
______________________________________________________________________________________________________________________

But guess what...Unless you abide by they're "Permit Standards" which they set (Pretreatment, BOD, COD, Heavy Metals Filtering, etc.) You Won't Get A Permit. You can apply for a permit all you want, they don't have to give you one. You still cannot "Piggyback" off a Cities NPDES permit, at least in N.C. might be different in Nev. Please PM me a list of "Power Washing Contractors" that have NPDES permits. I would like to obtain one myself. How many Contractors on this board have one, do you?

I never said there was any quote about nothing down the drain but rain in the CWA Tony, never have because I know it's not in there, never said it was! It's an insignificant (At least to me) catch phrase you keep jumping up and down about.
 
Guy Blackmon said:
So lets see what the EPA says

[h=1]NPDES Individual and General Permits[/h] New permit links coming soon!
If you need a copy of an NPDES individual and general permit or a fact sheet for major facilities issued after November 1, 2002, contact your permitting authority for assistance.

  • An individual permit is a permit specifically tailored to an individual facility. Once a facility submits the appropriate application (s), the permitting authority develops a permit for that particular facility based on the information contained in the permit application (e.g., type of activity, nature of discharge, receiving water quality). Note: For individual permits, WWTPs can be found in the Electric, Gas, and Sanitary Services category.

  • A general permit is an NPDES permit that covers several facilities that have the same type of discharge and are located in a specific geographic area. A general permit applies the same or similar conditions to all dischargers covered under the general permit. Using a general permit to cover numerous facilities reduces paperwork for permitting authorities and permittees, and ensures consistency of permit conditions for similar facilities.
States may apply to EPA for authorization to issue general permits. Once EPA or a state has issued a general permit, a facility wishing to be covered under the permit submits a Notice of Intent (NOI) to the permitting authority. EPA or the State may still require the facility to submit an individual permit application and receive an individual NPDES permit if it determines that coverage under the general permit is inappropriate.
______________________________________________________________________________________________________________________

But guess what...Unless you abide by they're "Permit Standards" which they set (Pretreatment, BOD, COD, Heavy Metals Filtering, etc.) You Won't Get A Permit. You can apply for a permit all you want, they don't have to give you one. You still cannot "Piggyback" off a Cities NPDES permit, at least in N.C. might be different in Nev. Please PM me a list of "Power Washing Contractors" that have NPDES permits. I would like to obtain one myself. How many Contractors on this board have one, do you?

I never said there was any quote about nothing down the drain but rain in the CWA Tony, never have because I know it's not in there, never said it was! It's an insignificant (At least to me) catch phrase you keep jumping up and down about.
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I don't know how to explain it any better Guy.

Here is their own PDF about Phase II : http://www.dep.state.fl.us/water/stormwater/npdes/docs/phase2/fact1-0.pdf

Here are some quotes:

Phase II is intended to further reduce adverse impacts to water quality and aquatic habitat by instituting the use of controls on the unregulated sources of storm water discharges that have
the greatest likelihood of causing continued environmental degradation.

Question Guy, if the EPA had jurisdiction over all sources of pollution, even those who did NOT hold NPDES permits prior to 2003 then what, pray tell, are these "unregulated sources" they were referring to?

Could it be that prior to Phase II and prior to 2003 there was literally NO jurisdiction over our type of industry by the EPA?

Could it be that Robert's pointing out reclaim to everyone who would listen (including municipalities)has put us on the map where previously no one even gave most of our industry a second look?

Guy, Phase II makes us all piggybackers to the city. the "Point Source" is the storm drain system and ditches, NOT the sanitary sewer. The city's permit covers the "point source" and everything that goes in it. That means us.

Listen to what it says construction runoff consists of:

In addition to sediment, construction activities yield pollutants such as pesticides, petroleum products, construction chemicals, solvents, asphalts, and acids that can contaminate storm water runoff.

And yet it offers a full waiver for small construction under one acre!

http://www.epa.gov/npdes/pubs/fact3-0.pdf

Here are some quotes:

Are Waivers Available for Operators of Regulated Construction Activity?
............A determination that stormwater controls are not necessary based on either:
(A) A “total maximum daily load” (TMDL) that address the pollutant(s) of concern for construction activities; OR
(B) An equivalent analysis that determines allocations are not needed to protect water quality based on consideration of instream
concentrations, expected growth in pollutant concentrations from all sources, and a margin of safety.......
Fact Sheet 3.0 – Construction Program Overview Page 3 Pollutants of concern include sediment or a parameter that addresses sediment (such as total suspended solids, turbidity, or siltation) and any other pollutant that has been identified as a cause of impairment of a receiving waterbody.

The intent of the waiver provision is to waive only those sites that are highly unlikely to have a negative effect on water quality. Therefore, before applying for a waiver, operators of small construction activity are encouraged to consider the potential water quality impacts that may result from their project and to carefully examine such factors as proximity to water resources and sensitivity of receiving waters.

IF THE CONSTRUCTION INDUSTRY CAN GET THIS WHY CAN'T WE?

Do you think the construction lobby went to the table with the claim that they KNOW they are contaminating the water and KNOW they are so irresponsible that they need nationwide BMP's that require them to suck up all the water in order to be environmentally responsible??????????

I'm not saying you have anything to do with that "nothing down the drain but rain" garbage, I was just concerned that you bought into it.
 
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