EPA Enforcement in 2012 Protects Communities From Harmful Pollution

I will not take those pictures down. They are public pictures available to anyone with an internet connection.

John, maybe it would have been better if I had used org money to travel to Ft Worth and called some competitors before taking pictures over the fence and that would have been more to your liking. Michael sure liked it when Hilborne did it to Ron, but didn't the guts to step down like Hilborne.

That property in the pictures apparently belongs to a PWNA Board Director, Michael Hinderliter. Robert, his father is the Environmental Director for the PWNA.

I think pictures say 1000 words (and that is even more words than Robert's presentations! Or your posts! Lol)

Robert is trying to force regulations on everyone but himself.....oops, let me rephrase that...everybody but his son and their PWNA buddies.

See, they are the "Elite" Contractors (or so they say, now that they accepted Jim into their group I can only assume that, in reality, they are all broke and in debt and inflate their incomes)

Guys with that mentality have just enough money to put up a good front, slap a vacuum on some trailers, report all their competitors till they run them, scare them, or sue them out of business.

10 million per year Robert says Michael is making. Is that supposed to make all of us who work for a living feel inferior? At least he didn't say $XX,XXX,XXX.

I am tired of trying to show the light. I hope at least a few guys have been paying attention to all of this



Sent from my DROID RAZR using Tapatalk 2
 
For anyone who is still left here, there is still time to turn this thing around. Robert isn't going to stop his quest.

Our only option is to counter his misinformation with with a truth campaign.

That campaign needs to consist of information that shows how beneficial we are to society.

It needs to consist of showing how our services provide a net positive to the environment.

I have been working on this locally for over a year. Last year I spent close to two months spreading the word all over the West Coast as an Environmental director for the UAMCC.

I know this is just a drop in the bucket compared to the time Robert has spent, but I'm a lot younger than he and I don't have a son making 10 million a year to give me the time and finances. (He's getting there though!)

It would be wrong for me to do it by myself anyway. The UAMCC needs help. We need some more guys to help spread the word in their own areas.

Keep coming with the questions and lets start a new direction based on the answers we come up with and quit laying down and giving up without a fight.

We can do it!
 
I support a program written by my comrades together. By our leaders in this industry collectively
Tony Shelton said:
For anyone who is still left here, there is still time to turn this thing around. Robert isn't going to stop his quest.

Our only option is to counter his misinformation with with a truth campaign.

That campaign needs to consist of information that shows how beneficial we are to society.

It needs to consist of showing how our services provide a net positive to the environment.

I have been working on this locally for over a year. Last year I spent close to two months spreading the word all over the West Coast as an Environmental director for the UAMCC.

I know this is just a drop in the bucket compared to the time Robert has spent, but I'm a lot younger than he and I don't have a son making 10 million a year to give me the time and finances. (He's getting there though!)

It would be wrong for me to do it by myself anyway. The UAMCC needs help. We need some more guys to help spread the word in their own areas.

Keep coming with the questions and lets start a new direction based on the answers we come up with and quit laying down and giving up without a fight.

We can do it!
Click to expand...
 
ScreenShot2013-01-03at113706PM_zps5fcacbd5.png


John I do think your statement are a bit over the top, but I'm with you on this one.
 
I just saw this Nigel in the middle of this other Stuff, its late so I will get to you likely fri or sat am. Fri I do not work, wife has plans but right at the moment I'm sleeping in. I wanted you to know I will answer this. Most likely by video to have you better understand.
810f250 said:
I dont tell them that I am creating waste, they seem to classify water runoff negatively other than if it is occurring during a rain event or form sprinkler/irrigation/hydrant/water main break without sediment wash carry off.

Thats why I have ask how do you accomplish "leave on property", when I have the issue of , AHJ's wanting to hold me to,

"It is unlawful for any person to introduce soil or sediment into waters of the State or to place soil or sediment in a condition or location where it is likely to be washed into waters of the State."

I agree that sediment quantity is small with frequent or infrequent store front , sidewalks, and drivethru cleaning, etc especially when dry clean up BMP's are utilized.

Help Ron.

I asked a series of questions prior,

what is your opinion of commercial properties that are "not built compliant" ?

What does "not built compliant" mean?

What is your opinion of a scenario where a mobile wash contractor picks up their generated wash water form one area of "compliant property", to avoid it reaching a storm drain (because of the volume of wash water produce and location of storm), and having to transfer the wash water to an area on property where it will comply with the CWA?

How do you suggest we handle instances where there are no property systems in place for the contractor to be compliant?

For example, where there is a graded in the drive thur "smack" to a STORM WATER INLET ,I know you mentioned earlier most likely I am wrong and that it "may not be storm inlet", but just for discussion , lets say I was correct,...........................you indicated your opinions about a responsible landscape discharge option, ..................so how would you suggest I handle my scenario???

I dont want to seem like a impermeable individual,

here is a proposal

If we can be exempt for certain types of cleanings with "practical" solutions maybe no detergents.

1)like oil socks at storm inlet (3 tiers) ,
2)settling of 3 to 5 minutes,
3) Final stage a Metal zorb filter for heavy metals possibility.

What are your thoughts??, now how do we propose this to the AHJ's?
Click to expand...
 
Posted by Nigel:

What is your opinion of a scenario where a mobile wash contractor picks up their generated wash water form one area of "compliant property", to avoid it reaching a storm drain (because of the volume of wash water produce and location of storm), and having to transfer the wash water to an area on property where it will comply with the CWA?

Nigel:

If asked most Regulators do not want you mixing waste water between customers, because if there is a violation it is hard to identify where the violation came from. However, I have never heard of it being enforced.

What is hard about this industry is that there is one set of rules on the books, and another set of rules being enforced. Often this varies from AHJ to AHJ in the same jurisdiction. This creates a situation similar to if you do not like what Mommy said ask Daddy.

Also an AHJ pointed this out to me: The Interpretation of the CWA is basically related to everyone's "Economic Revenue Stream".

The EPA's Model Ordinance allows this in that it is not prohibited and is practiced by most contractors.
 
John, I am moving this thread again.., Do this one more time, Post another post that has been moved and I will ban you. No other warning will be given..
 
Posted by Nigel:
I agree that sediment quantity is small with frequent or infrequent store front , sidewalks, and drive thru cleaning, etc especially when dry clean up BMP's are utilized.

Nigel:

This was a controversy several years ago within the Regulatory Community about all of the small discharges adding up to be significant sources of contamination. The final result was the establishment of the "Total Municipal Daily Load" (TMDL) which now is part of the Permitting Process.

The EPA has changed their training process from Regional Conferences to Online Training (webcast). This means that you can attend the same training sessions as the AHJs. I have taken several of the courses over the last 20 years that pertain to our industry.

Presently you have to attend the courses when they are given inter­-interactively to get a Certificate of Completion from the EPA. However, they are archived and you can view them after the fact for no credit.

Here is an example when Searching the EPA's Website for this training: "Waste Water Webcast"

Here are some links if interested:

http://www.epa.gov/gateway/learn/wastes.html

http://www.epa.gov/gateway/learn/water.html

http://water.epa.gov/polwaste/wastewater/index.cfm

http://nlquery.epa.gov/epasearch/ep...reapagefoot=epafiles_pagefoot&stylesheet=&po=

http://nlquery.epa.gov/epasearch/ep...areapagefoot=epafiles_pagefoot&stylesheet=&po=

 
Listen, I am assimilating the current events of the thread.

I would truly like us all to work together (AHJ's included); I believe if our industry would like to be a respected voice for authorities to 'listen to' and 'recon with' ....there is be better strength in numbers even if within those numbers there is private disagreement.


While I was out I took some photos of the systems at a local store parking lot.



DSC_0313.JPGDSC_0312.JPGDSC_0311.JPGDSC_0310.JPGDSC_0308.JPG
 
Those are Vary Cheesy systems, most of the better ones you cannot even detect
810f250 said:
Listen, I am assimilating the current events of the thread.

I would truly like us all to work together (AHJ's included); I believe if our industry would like to be a respected voice for authorities to 'listen to' and 'recon with' ....there is be better strength in numbers even if within those numbers there is private disagreement.


While I was out I took some photos of the systems at a local store parking lot.



View attachment 22879View attachment 22880View attachment 22881View attachment 22882View attachment 22883
Click to expand...
 
What do all of these solutions have in common?

They are all gravity fed filtration solutions. They all work towards cleaning the water the eventually end up in our streams.

Nigel, I spent part of this morning listening to the Webcasts on Illicit discharge that Robert suggested while also looking up info on the guys who built the built-in system for your gas station.

Here is one of their systems designed to deal with a municipal auto repair facility that has all the same contaminants your gas station would have and more:

http://www.conteches.com/DesktopMod...yId=7418&PortalId=0&DownloadMethod=attachment


During my conversation with Travis he told me that ALL their systems "filter" the runoff, then DISCHARGE into the MS4. (Under the city permit, of course)

That is what they are designed to do - filter, then release.

I have a question for you Nigel.

IF Contech can sell and install gravity driven filtration systems that produce runoff that is compliant, then why are we being told that we can't filter our runoff using the same discharge specific filtration and discharge the cleaned runoff into the MS4 just like Contech's customers. Wouldn't this be preferable and "practicable" in those rare instances where off property discharge is the only viable option?
 
Here is an interesting read from Prosco. One of the largest masonry restoration and water proofing materials providers. In many cases a neutral PH will lead to soil or sewar discharge. Meaning rinse water can stay onsite many times. In the case of hazardous toxic chemicals, we are not allowed to remove them. A third party would need to be involved, such as in the use of over 10% methalyne chloride. See page 5. In this case a licensensed Treatment, disposal and storage contractor for hazardous waste would be required. So in this case a contractor with reclaim would be in violation for removing the rinse water unless they were a licensed TSD.
http://www.prosoco.com/Content/Documents/General/d0f13702-2e28-49cc-9577-23afb5d551e1.pdf
 
Ron Musgraves said:
Those are Vary Cheesy systems, most of the better ones you cannot even detect
Click to expand...

Historically correct Ron, but I believe that Maryland may be trending away from "out of sight, out of mind" systems. It is my understanding that they want the systems to be more visible for more awareness of the general public and easier detection of system failures. Plus, they are getting ever tighter and tighter with the regs and want many more interceptors than previously required. Maryland is so far up the feds butt on this issue that common sense no longer prevails. That is, if the Feds dream of a regulation, Maryland wants to beat California to the crazy table screaming for acceptance by the ruling party.

If anybody chooses to follow Nigel, please do so knowing that chances are his answers are going to be so much more restrictive than the answers you may receive from your local authority that Nigel's answers may not apply to you at all. Plus Nigel has an approach that is much different from many independent business men. It appears that Nigel desires to fully understand what the bureaucrats want so that he can fulfill their every desire. I believe, as Doug said earlier today, that we are all individuals and my approach is entirely different than Nigel's would appear to be. I am not saying that you are wrong Nigel, I am just saying that no one has to be in fear of their livelihood being stripped away because they can't meet Nigel's understanding of the propaganda that surrounds the now bastardized CWA.

YMMV.

I tried to stay out of it, I really did.
 
Hi Tim. A lot of this stems back to the Chesapeake bay foundation filing suit against the EPA for not enforcing it's own laws. Now the CBF blames the EPA who blames local regulators for the Chesapeake bay being a mess. It's largley a knee jerk reaction under the realization that non of the EPA, CBF or MDDOE where ever enforced. Furhter more that compliance was many times not possible due to a lack of facilities to accept waste water. I ran into this in the eastern shore, Delmarva Penninsula. There are a ton of trucks to wash over there, but no place to take the waste water. I called the MDDOE 4 years ago about it and was told to spread some hay around to minimize contaminants in the wash water. That's a far cry from the actual laws, but that is the best the state has come up with to provide compliance solutions for this problem in particular. But on 695, much farther from the bay, the MDDOE fought Baltimore truck wash for 5 years trying to prevent their station with full reclaim and filtration on site. It is very messy indeed.
 
apwasher said:
Here is an interesting read from Prosco. One of the largest masonry restoration and water proofing materials providers. In many cases a neutral PH will lead to soil or sewar discharge. Meaning rinse water can stay onsite many times. In the case of hazardous toxic chemicals, we are not allowed to remove them. A third party would need to be involved, such as in the use of over 10% methalyne chloride. See page 5. In this case a licensensed Treatment, disposal and storage contractor for hazardous waste would be required. So in this case a contractor with reclaim would be in violation for removing the rinse water unless they were a licensed TSD.
http://www.prosoco.com/Content/Documents/General/d0f13702-2e28-49cc-9577-23afb5d551e1.pdf
Click to expand...


I thought this was an interesting quote:

Biodegradability
For a chemical or substance to be biodegradable, it must
be capable of being broken down into its primary constituents
in the environment. An organic solvent, surfactant, or paper
based package can be biodegradable. A neutralized mineral acid
or mineral alkaline chemical like hydrochloric acid or sodium
hydroxide becomes a mineral salt. It cannot be degraded further
as it is already a primary constituent.

Most of us think of Sodium hydroxide as something toxic. Probably because we are trained, in this day and age, "if it works, it must be bad".

But neutralized SH is nothing but salt. It's really a beautiful thing and we should be promoting it as such.
 
This is why we have always needed varied input from various locales.

By the time I met Jim in 2008 he was already brainwashed into believing that "one drop of caustic" would kill all the fish in the sewer system. lol.

Jim has lived in a highly restrictive environment so long, he wants to make everyone's jurisdiction as restrictive as his. I don't know if it's bitterness or if it is an effort to try to make a fair playing field. But to me, making a fair playing field would be to take the most restrictive areas and teach them how to operate like the rest of the country.

Apparently the emigrants that came from California to Texas do the same thing in Texas. (They also do the same here, that's why all our parking lots are filled with ridiculous trees.......in the desert!!! lol) Robert apparently has had to deal with more restrictions and ill informed do-gooders in Texas. At least we know that was the case in Houston.

Nigel is going through the same thing.

We, here in Nevada, have avoided that and rejected the California influence here. Our Storm Water Authority is easy to work with and uses common sense. We've been building structures to take care of runoff and Lake Mead for over 15 years and the Lake is crystal clean, even near the wash. Heck there is a Launch Ramp at the wash and people ski and swim there all the time! For those who don't know - WASH=the place where all our runoff from the entire city goes into the lake.

It's just a shame that the leadership within our industry has taken the approach that we can't win.

We CAN win! We CAN work using common sense methods to do our jobs.....that job being REDUCING POLLUTION. That is what we do.

We don't generate ANY pollution other than the exhaust of our machines and trucks. So why would adding more machines and more weight for the trucks to haul around be the best solution to deal with the pollution we clean??????

In most of our cleaning operations we should be:

1) Cleaning FREQUENTLY!
2) Keeping dirt and anything toxic from making it to the MS4 (working under our city's permit)
3) Picking up anything that can cause real harm and filtering/hauling/dealing with it and charging appropriately.

Our industry would explode if we could keep our pricing reasonable and profitable.

I've said this before, for all you guys who think you are going to be that "elite" contractor, remember, there were many who thought they were going to be the "elite" in their industries (see "Tucker" automobiles) but once you mix the government into it, the worst contractors with the most money tend to take all the gold. (See "GM" automobiles)

In this case all the signs point to a concerted effort by the PW#A to crush us all with regulations to make room for a few to take over when we've all got on craigslist and sold the various contraptions we've spent thousands on to reclaim the water.

They are not going to stop. If anything they have dug their heels in by even considering Jim Gamble as an environmental representative. If there was any doubt as to their motives there should be none after that appointment.

So what does that leave us? What can we do? We are going to have to counter it, just like Ron did in Houston and I've been trying to do on the boards and in the field for the past year or so. Our only avenue of support is the UAMCC. Ron and I have not taken a dime for our efforts and speaking for myself I won't ever take a dime. But we need money and resources to make a campaign that will change the way our industry is looked at.

It won't be easy because now, not only do we have the wastewater transport guys, and sellers of various methods of "compliance" fighting against us, but we have an industry org fighting too! But we can do it.

Please join the UAMCC and help. And if you are a member please consider donating towards this effort.

If you don't have any money to work with now, please donate a little of your time and help us research your area and bring to our attention anything that might help us in this quest!
 
Ron, I appreciate the call and value the communication.




Tony Shelton said:
What do all of these solutions have in common?

They are all gravity fed filtration solutions. They all work towards cleaning the water the eventually end up in our streams.

Nigel, I spent part of this morning listening to the Webcasts on Illicit discharge that Robert suggested while also looking up info on the guys who built the built-in system for your gas station.

Here is one of their systems designed to deal with a municipal auto repair facility that has all the same contaminants your gas station would have and more:

http://www.conteches.com/DesktopMod...yId=7418&PortalId=0&DownloadMethod=attachment


During my conversation with Travis he told me that ALL their systems "filter" the runoff, then DISCHARGE into the MS4. (Under the city permit, of course)

That is what they are designed to do - filter, then release.

I have a question for you Nigel.

IF Contech can sell and install gravity driven filtration systems that produce runoff that is compliant, then why are we being told that we can't filter our runoff using the same discharge specific filtration and discharge the cleaned runoff into the MS4 just like Contech's customers. Wouldn't this be preferable and "practicable" in those rare instances where off property discharge is the only viable option?
Click to expand...



I concur that the systems are designed to handle/treat the wash water of the property be the most "practicable" solution Tony.

Look back at my earlier post when I wrote http://www.propowerwash.com/board/u...mful-Pollution&p=293562&viewfull=1#post293562

The system seemed in my opinion , large enough to handle the , responsible mobile cleaning wash water, (responsible, practice BMP's that would minimize contamination to the system). The only issues I have, is the owner going to be held responsible for or both the owner and mobile cleaner if there is any issue.


Timothy said:
Historically correct Ron, but I believe that Maryland may be trending away from "out of sight, out of mind" systems. It is my understanding that they want the systems to be more visible for more awareness of the general public and easier detection of system failures. Plus, they are getting ever tighter and tighter with the regs and want many more interceptors than previously required. Maryland is so far up the feds butt on this issue that common sense no longer prevails. That is, if the Feds dream of a regulation, Maryland wants to beat California to the crazy table screaming for acceptance by the ruling party.

If anybody chooses to follow Nigel, please do so knowing that chances are his answers are going to be so much more restrictive than the answers you may receive from your local authority that Nigel's answers may not apply to you at all. Plus Nigel has an approach that is much different from many independent business men. It appears that Nigel desires to fully understand what the bureaucrats want so that he can fulfill their every desire. I believe, as Doug said earlier today, that we are all individuals and my approach is entirely different than Nigel's would appear to be. I am not saying that you are wrong Nigel, I am just saying that no one has to be in fear of their livelihood being stripped away because they can't meet Nigel's understanding of the propaganda that surrounds the now bastardized CWA.


YMMV.

I tried to stay out of it, I really did.
Click to expand...


Thanks Tim for joining in the conversation, I appreciate it, I agree with some of your statements in the first paragraph,but I really dont know if Maryland is trying to out do California .

For the record readers, I dont advise that anyone follow me, I have shared what a few local AHJ's have communicated with respect to particular instances.

I advise that individuals check with their local AHJ's and determine what they require and recommend.

After all the input recommended by anyone it comes down to an individuals choice.

Tim I dont think you are saying that I am wrong,...............

and honestly I am the one in fear; fear of being informed that because of my operating action I am going to be held responsible for such.

I would be great if you would continue to communicate your views/experience in the thread, thanks



apwasher said:
Hi Tim. A lot of this stems back to the Chesapeake bay foundation filing suit against the EPA for not enforcing it's own laws. Now the CBF blames the EPA who blames local regulators for the Chesapeake bay being a mess. It's largley a knee jerk reaction under the realization that non of the EPA, CBF or MDDOE where ever enforced. Furhter more that compliance was many times not possible due to a lack of facilities to accept waste water. I ran into this in the eastern shore, Delmarva Penninsula. There are a ton of trucks to wash over there, but no place to take the waste water. I called the MDDOE 4 years ago about it and was told to spread some hay around to minimize contaminants in the wash water. That's a far cry from the actual laws, but that is the best the state has come up with to provide compliance solutions for this problem in particular. But on 695, much farther from the bay, the MDDOE fought Baltimore truck wash for 5 years trying to prevent their station with full reclaim and filtration on site. It is very messy indeed.
Click to expand...


It is very messy. One local saying one thing and another within the region pushing/intimidating/enforcing for something completely different.
 
You must log in or register to reply here.
Back
Top