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First I think the PWNA one BMP plan for the whole country needs to be stopped. We need a representative to get phone or face time to ask them to hold off going forward with this BMP. The PWNA & entire industry needs to work together on a master plan. The PWNA may have 250 members out of 10,000, 20,000 or more contractors this has to be discussed by more than the BOD and some PWNA members

IF the PWNA doesnt put a freeze on this we need to take any and every measure we can to stop them

I THINK we need to start a thread on EVERY SINGLE Business board to ask PWNA MEMBERS if they have given input to the PWNA and what their thoughts are. I think we need to start a campaign to educate PWNA members and get them involved in the coalition.

The Coalition is young that is what is going to hold us back some. We need to get up to speed and map out some kind of plan, just 5-10 steps on what needs to be done first

#1 I think the first step is to get a hold of PWNA members, I think that possibly is the best way to get the PWNA to listen to ALL contractors

Step#2
 
tomtucson said:
Where does one get this mythical npdes permit? Do cities themselves have them? if so we should be covered under theirs.
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You're exactly right Tom, the cities have the permit and you are covered under it. The law says that as long as the city is meeting it's minimum requirements under the permit the EPA can neither fine the city NOR you.

The reason you hear of these fines for large companies is because they are in a situation where they must have their OWN permit An example would be a chemical plant. Once you have your own permit you are under scrutiny and frequent testing is required. If the testing reveals that you are not meeting the minimum requirements under the permit then you are subject to fines.

Another myth is the huge fines. Many companies that get fined by the EPA get fines over 100k issued, but are settled for pennies on the dollar before it even gets to a judge. Usually under 20k.
 
Celeste, the place we need to start is in our own backyard. We need to get a university to test samples of our runoff in different aspects of pressure washing, determine the environmental impact and produce a study that we can take to these cities showing that we are not polluters.

We need a study showing that any impact at ALL is outweighed by the benefits of keeping our public areas clean and safe.

We need a study to show exactly WHERE the breaking point for paying for our services is along with a breakdown of the actual costs of doing business as a professional cleaning company and find that axis where cost and benefit of reclaiming meet and draw the line at that point and show that the CWA does not require ANY actions that aren't economically feasible.

Does anybody know anybody in college who can still read and do math? If so, let's see if we can get them to do some studies for us. :)

That's where we start, not by agreeing that we are polluters and responding by making BMP's that give them even more ideas and ways to restrict us in the future.
 
Are you.....Tonto?.... :)

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PWNC said:
Back during the drought, the PWNC was in communication with the DEHNR. They provided names of people at NC State University who can do just that Tony. We are waiting on the Coalition's direction. The PWNC is behind this effort 100% (by a majority vote of the Associate Contractors). We're not lone rangers though.
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The PWNC represents the NC & SC Carolinas, its really silly but has been more effective in the recent years than possibly both Pressure washing National Orgs.

Thats why we tell you to slow down sometimes and get your members involved.

By the way Celeste thanks for getting the PWNC on the team.

Together we can all stand stronger
 
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Painting over my sticker was probably a little over the top. I was attempting to get the attention of the PWNA to show how serious it was to presume that they could "vote" on something that will affect all us us before even asking ANYONE for suggestions.

The way we are coming at this is skewed.

Here is an example of what I mean. The sweeping industry has embraced the CWA and it has increased their business tremendously. Street sweepers use water to wet the ground as they clean. Inevitably "some" of the stuff on the streets, oil, metals, etc are going to be pushed right into the storm drains by the sweepers. BUT they have taken the stance that they are a necessary way to COMPLY with the CWA and these small amounts that they "disturb" are nothing compared to the savings municipalities have on storm drain cleaning maintenance and other spill cleanups. As a result street sweeping is no longer optional in cities and is now mandated by ordinance in many places. http://www.worldsweeper.com/Environmental/index.html

What we do is necessary too. We remove garbage, sludge, solids, algae, mold, grease, oil and other contaminants. When we are allowed to use hot water to do so and do so frequently enough we add absolutely nothing to the waste stream. Hot water is cooled before it even makes it to the storm drain grate. We're not protecting fish from hot water in the storm drains anyway. It would have to be some pretty hot water to make it the hundreds of yards to many miles from most streets to actual "waters of the US".

The most common soap on concrete is Sodium Hydroxide. It only takes 76 gallons of water to dilute a gallon of Sodium Hydroxide down to 1%. You can drink that. And so can a fish. To put this in perspective, imagine you are cleaning a shopping center and have hosed it down with 5 gallons of SH. How many gallons of water do you think it will take to clean that shopping center. I'll guarantee it's a lot more than 400 gallons which is what it would take to dilute it to 1%. http://www.powellfab.com/technical_information/tools/sodiumhydro_dilution.aspx

Now, if we used simple dams like the construction industry does we could keep sediment out of the storm drains while doing our part to keep our cities and businesses clean and safe. There are "catch all" berms that take out oils and greases leaving virtually nothing but clean water to go down the storm drain.

The EPA themselves have a list of possible contaminants from surface cleaning concrete here:

EPAsurfacecleaning.jpg


If we just worked on concentrating on filtering those substances AT THE entrance to the "point source" (the entirety of the storm drain is considered a "point source" by the EPA.) then we could arrive at a location, and throw down a berm filter. When we're done cleaning we could scoop up the stuff we've just cleaned so that it doesn't runoff during a storm and jam up the drain and be on our way. No added air pollution with more vacuum motors, no added chances of oil spills or electric shocks using electric pumps. It's clean, simple, green and it works. Meanwhile we've removed contaminates that would have normally gone right down the drain eventually during a storm and we have done it responsibly in and economically feasible way.
 
The single largest thing that is "grandfathered" in (I know for a fact in my area) that is a HUGE violation of the CWA...is the "flushing of fire hydrants". That makes me nuts. Every gum wrapper, cigarette butt, finished "chew" and heaven know what else are driven straight into the gutter system without a second thought. 10's of thousands of gallons of water, literally down the drain, taking everything in its wake with it :( And the new construction sites.....oh holy crap, the stuff that goes down those new gutters? What IS it about our tiny industry that has everyone so bent......other than the fines that generate revenue. Is that actually what it all boils down to - the money. They seriously can't be going at this from a tree-hugger standpoint. We just don't do the damage that they're implying! I'm with Tony on the just barrier and dispose in a reasonable manner. It's just not that hard.
 
Tony that is in part what we did at the past two garages we did. The drain inserts worked great what we didnt scoop up was caught in the insert. They are a bit costly but I actually cleaned them after the job so I can reuse them. They have flaps inside to absorb oil and what I did to clean it was use Doug Ruckers BT200 after we cleaned out and bagged all the sediment. It has a sleave to catch the sediment and let water run out the top. I caught everything >>> http://www.newpig.com/us/pig-reg-drain-insert-plus/FLT116?cm_vc=vc_static_browse

NEW PIG has some good products and other companies do also. NO RECLAIM EQUIPMENT Was used and I cleaned over 185,000+sq ft of concrete

This all can be done
 

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jlpressure said:
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Theres way to go at it is right Tony, we need to put this all in writing, get a study and work toward reasonable and rational and move forward past the horrible standard the PWNA is going for
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I would say that's quite a creative use for Celeste's hat, but I'm afraid where her broom would end up next time I see her!

Sorry Celeste, I couldn't resist and you're the only woman in the conversation :)
 
CarolinaProWash said:
The single largest thing that is "grandfathered" in (I know for a fact in my area) that is a HUGE violation of the CWA...is the "flushing of fire hydrants". That makes me nuts. Every gum wrapper, cigarette butt, finished "chew" and heaven know what else are driven straight into the gutter system without a second thought. 10's of thousands of gallons of water, literally down the drain, taking everything in its wake with it :( And the new construction sites.....oh holy crap, the stuff that goes down those new gutters? What IS it about our tiny industry that has everyone so bent......other than the fines that generate revenue. Is that actually what it all boils down to - the money. They seriously can't be going at this from a tree-hugger standpoint. We just don't do the damage that they're implying! I'm with Tony on the just barrier and dispose in a reasonable manner. It's just not that hard.
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You know stuff like flushing hydrants doesnt bother me. Its needed, they have to check them and I figure if some debris goes down a drain so what.

Now the big polluters that bothers me, when they are sending thousands millions of gallons of toxins etc etc out pipes right into the harbors and ocean I think there has to be a better way. Boston Harbor used to be a swill bucket, just totally gross and nothing but rats lived near or in it. The built new waste plants cut down on outfall from large polluters and now you can catch bass, see seals and even occasionally see a few dolphins

Its all about the money we are an EASY TARGET and when supposedly our own industry org like the PWNA is making us look like polluters why shouldnt we be an easy target Car Washers and other industry's have pretty strong Orgs and they fight this stuff, us we just keep shooting ourselves in the foot. Like I said easy target
 
Hey man :) I wear the reputation well, don't I? And I've yet to kill anyone with my broom!!
 
I know what you're saying Jeff.....the point I was trying to make is if they are so concerned with where water goes......that's just a big load of it that is going. Know what I mean?
 
CarolinaProWash said:
I know what you're saying Jeff.....the point I was trying to make is if they are so concerned with where water goes......that's just a big load of it that is going. Know what I mean?
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Ya I do. Theres so much we do to clean and we are getting the shaft
 
I passed 2 fire departments on Friday when the weather was nice washing the fire trucks, you could see the bucket of soap and the wastewater running into the storm drains. I'd bet theres a lot more fire departments than pressure washing companies.
 
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