Thank you Robert for taking the time to address these points.
The BMPs will comply the EPAs Model Ordinance, but it is not exactly what Fort Worth has in place. Some items are changed are made to make it easier to understand and solve some problems that has arisen since January 2, 1996. It is now harder to change the ordinance that it was to write the ordinance in 1995 because there was no standard to start from.
So you're saying that since the BMP is accepted by some municipalities, we need to keep it very close in order to use them as references. Am I understanding that right?
The State of Oregon did a study of the effluent from Power Washing several years ago. It was the most extensive I have ever seen, and because Oregon is a small state it was not acceptable to other states. A lot of work I have done is based on these results; I did not reference them because it caused a problem with other regulators. The study filled a 3-ring binder about 3 inches thick; it covered every scenario you could think of.
Where can I access this information Robert? In looking for it I came across this page which looks pretty good. I'd like to submit it here for comments from other contractors in this thread.
http://www.fortworthgov.org/dem/info/default.aspx?id=8016
RE: "Costmetic cleaning" vs "health and safety cleaning" ....
This is probably a good idea, but it is not what I came up with in 1995 trying to define our cleaning for the Regulators. Now it has been adopted by a lot of municipalities and trying to change it would be very hard and confusing. I came up with the term "Cosmetic Cleaning" and Fort Worth took my description and put it into Legalese.
Is there something we can do about this? Could we refer to anything new as "revised" BMP's based on the city of Ft Worth? I'm just throwing out suggestions.
4th Choice: Evaporation is acceptable as long as the evaporation occurs on property on a surface that will not absorb the contaminates. After the surface has dried the contaminates need to be swept or vacuum up so that when it rains the contamination will not be washed of property.
This one is going to require a little more thought. Out here in Las Vegas we time our powerwashing to coincide with the sweeping contractor.
This agrees with the EPA's Model Ordinance, and makes allowances for other municipalities. I'm open to suggestion for improvement in language.
I don't have any wording suggestions. The wording is good, I just questioned the fact that it was in there at all giving ideas to municipalities that aren't currently charging for permits.
That is not Recycled Wash Water. A lot of Municipalities have Grey Water at their POTWs that have been treated that is not Potable (drinking) Water.
I misunderstood that one. My mistake.
Hot Water is an emulsifier just like a detergent. Therefore, in the CWA Hot Water and Detergents are treated the same. I had problem in Phoenix where the Regulators were treating any water out of the tap that had been elevated even one degree as Hot Water.
I will say it another way, any water that has been raised in temperature out of the faucet is hot water. Hot water is not defined in the CWA but regulated. After a lengthy negotiation with the City of Fort Worth, 110⁰F was agreed upon as being Rational, Reasonable, and Logical for both parties. I wanted it higher and they wanted it lower. To my knowledge that is the first time it was defined.
Why can't we err on the side of the contractor and point out that we are "emulsifying" contaminants that shouldn't be on the sidewalk anyway? Also can we put a number on the temperature of the runoff entering the point source (storm drain) instead of a number on the initial temp of the cleaning water? Maybe we could skirt this entire issue since the fact is, we are not ADDING any contaminants with hot water and are doing our due diligence to keep from having to use soaps.
What you are experiencing here is a matter of interpretation. Everybody is an Environmentalist, how it affects their Economic Revenue Stream generally determines how they interpret the CWA. You say it is not reasonable, and the Municipalities say it is reasonable. Houston is a good example of this conflict.
Politics has a large part in this; this is why everyone needs PWNA. Organizations have a lot more clot than an individual does.
Robert, I just had a stroke last fall, I've had all the "clot" I need. (Just lightening the mood) 
I agree with you on the clout of an org. Unfortunately the org stands to profit from adopting these BMP's then suggesting to the municipalities that only 'certified' cleaners be allowed to work. What is your intention in this matter Robert? Would you and the BOD be willing to market the BMP's as a higher level of attainment or as a general requirement to work as the KEC certifications have become?
I disagree; it is BMPs for Contractors and Regulators. It explains how things work better than the average person understands.
You are probably right on that. What about simply removing this sentence?
In order to solve this problem some Contract Cleaners will choose to capture all of their wash water and haul it to a disposal site, like their own sand trap
The word “Frequently” was used here to help define the condition of the surface as not heavily laden with oil and grease.
It's probably not the best idea to define "frequently" except on local levels. My point was if we had guidelines for service i.e. 15 days minimum service on restaurants we could offer lower pricing if we can clean without soap.
You always want to Pre-Clean and Filter your Wash Water. You do not want to wash Dirt and Debris down into the Storm Drain. We can add:
3rd Choice: With no Heat or Chemicals on surfaces that are contaminated by atmospheric dust only, then the wash water can be discharged into the Storm Sewer.
This is what we do here. Our BMP's allow hot or cold Plaza runoff with capture required on grit and debris only.
More later. Thanks again Robert.
