Continued from the other post about what needs to change with the PWNA BMP's.
Line 135 Again the hot water issue, most of the places where you have a storm water drain and the hot water is running toward it, I seriously doubt that by the time it hits the storm water drain it has significantly cooled off because of the air, surface being cleaned then the ground. By the time the water goes into the storm water drain and finally reaches the creek, lake, bay, whatever, it will be about the same temperature of the pipes that it is carried in and those are usually in the ground which is usually cooler than the surface of the parking lot, roads, asphalt, etc....
Line 137 Water can help clean better but if you have degreasing issues or oily surfaces the common sense thing would be to use oil socks to grab onto the oil so using hot water is not an issue again since the oil socks will grab onto the oil and keep it from traveling further. Perfect example is the picture that Deluxe shows using the oil sock, the sheen and no sheen after the water passes the oil sock, so again, no problem using hot water.
Line 138 I agree, no foam or oil should get into the storm water drain, use oil socks.
Line 139 I agree, an oil sock will remove foam and oil so you can still use hot water as the oil sock will catch the foam and oil and the water is constantly cooling as it travels to it's destination.
Line 149 I don't see how the ph levels can be so far out of range if you are pressure washing. Using a 4gpm or larger flow machine you are giving lots and lots of water to whatever soap you are using so there should never be issues of a very high or very low ph to deal with. When you think about it say you use 1 gallon of bleach and you are washing a house and it takes you 60 minutes and using a 5.5gpm pressure washer. When you do the math you are using about 330 gallons of water to wash the house so the bleach to water ratio is about 1:330 but if you water the plants before and after washing the house that is even more water. I don't see how the ph level can be much higher than water when using enough water to do the job properly. I would like to know where they got their info from to say that the ph will be very high or very low.
Line 153 When pressure washing you typically will have more than enough water to control the ph so I don't see where the ph can be an issue.
Line 154 Flocking done with a mobile system can possibly be viewed as violating a certain company's patent, I would not advise flocking unless you have an attorney look over the patent and see if what you want to do will violate the patent so you don't get sued. Flocking is a great idea and not very expensive to do when doing a job according to what I have heard and after you get the right equipment but the thought of getting sued is scary.
Line 161 Just about everything on the planet is biodegradable given enought time, you, me, the trees, the house, etc.....
Line 170 This is really about safety and health cleaning, not cosmetic cleaning.
Line 173 This is very vague. Does this mean that we are supposed to contact the health department before each job we do to notify them since most of the cleaning we do here is for safety and health reasons, not really cosmetic. I am not sure what they meant with this line 173 stuff.
Line 177 You should mention that if you use gray water to pressure wash, it needs to be filtered so you don't damage your pump.
Line 178 We were in a drought back in the 80's and we were using gray water to water plants and people's gardens so they would not die as the city stopped all watering of yards. Nobody ever mentioned anything about notifying the health or environmental department. Maybe in some areas it may apply but not all.
Line 181 Where does it say in writing that you have to get permission to use gray water, whether it is trucked in or made on the job for use?
Line 190 There are different requirements for each city or municipality if you discharge to the sanitary sewer so you need to check with them to see what they will allow.
Line 193 This mentions that some contractors will choose to haul the wash water, this should not be recommended, advised or suggested unless you know the Federal D.O.T. requirements are met, they have the proper CDL, Hazmat Endorsement, D.O.T. registered vehicle, permitted and registered as a waste hauler, etc..... By suggesting that they haul wash water you are telling them to break many, many Federal D.O.T. regulations which the fines can easily be in the $1000's of dollars and possible jail time if caught without getting the proper things done first.
Line 209 This should be left up to the contractor's discretion because the AHJ's are following things to the letter without using common sense and are sometimes seen as mindless drones so if the area is in a drought like a lot of the country is in right now, the wash water could be used to water the landscaping to HELP THE ENVIRONMENT instead of saying it should go down the sanitary sewer. Helping out the environment is a good thing so we should try to help the environment as much as we can.
Line 213 This should be changed, nobody is going to wash down the wash pad after each vehicle, this is not only stupid, will take too much time, waste way too much water (we are trying to make money and save water, not waste water needlessly) and not be profitable for the contractor. He can wash down the pad when he is done at the end of the day to conserve water.
Line 218 Again, this is saying that the wash water needs to be sent down the sanitary sewer, we can help the environment by watering the landscaping as long as there is not too much water that will lead to runoff, in this case some needs to be sent to the sanitary sewer but with the amounts of water that evaporate, this should not be a problem.
Line 219 Directing to landscaping should be first after what evaporates, not second. We can help the environment with the wash water during the drought.
Line 226 This is very vague. Pretreatment is very vague and can lead to the wrong impression. The oil/grease needs to be removed from the water then the water can be sent to the sanitary sewer, this can be done with oil socks.
Line 232 When fleet washing you typically neutralize the acid solutions with a high ph solution as part of the process so this should not be an issue plus the amound of water being used to wash the vehicles will help bring the ph back to where it should be close to.
Line 239 Discharging the wash water to the landscaping after some evaporates should be first, not the second or third option or method, especially right now since parts of the country are in drought situations.
Line 241 This should be the preferred method, sending the wash water to the landscaping and sending to sanitary sewer should be the second.
Line 262 Discharging after filtering to the landscaping shoud be the preferred method since parts of the country are in a drought.
Line 266 Filtered wash water should be sent to the landscaping since parts of the country are in a drought.
Line 268 Consult the fire department??????? Please explain this as the loose paint/paint chips when dry can be sent to the landfill for construction debris, not sent to the fire station.
Line 275 Wash water can evaporate on the premisis or be sent to landscaping since part of the country is in a drought. Most commercial locations have dry wells that can handle the wash water without needing pumping to other areas for those that know what they are doing.
Line 292 Wash water can evaporate and the rest sent to landscaping after using oil sock since parts of the country are in a drought.
Line 295 Preferred method should be sending wash water to landscaping as most house washing that is where the wash water already goes, it goes into the dirt. How are you going to recover the wash water out of the dirt? Sending wash water to the sanitary sewer does not make sense when house washing, building washing, roof washing, etc..... a lot will evaporate and the rest will soak into the soil.
Line 299 Building or house washing is not lead abatement, it is not paint prep, it is not blasting the paint off the surface, this is cleaning the mold, mildew and algae off the surface with softwashing methods. We are not painters that blast the paint off the surface so they can paint the surface again, we are cleaning the surface safely.
Line 301 Since we are building/house washing and not removing paint, letting the wash water soak into the ground or direct to landscaping should be the preferred method, we are not blasting paint off the surface like they did 30 or 40 years ago, we are using current and safe cleaning methods for safety and health cleaning, not paint prep.
Line 303 Pre clean???????? We are softwashing houses and buildings, not blasting paint off the surface or paint prep so there is no need for this nonsense.
Line 305 This should be removed, we are not painters, we are not lead abating, we are not doing paint prep or anything like that so there should not be a mention of this as it can put wrong ideas into simple brains of the AHJ people and cause problems later on.
Line 309 Wet Sandblasting?????? Really?????? Who makes this stuff up? Nobody wet sandblasts graffiti off surfaces.
Line 311 Preferred method should be sending wash water to landscaping since parts of the country are in a drought.
Line 312 Second method should be sending wash water to sanitary sewer.
Ok, I am done with this one. I hope that they read this, open their eyes, listen with some common sense and make the correct and needed changes like Tony, I and others mentioned.
