EPA Enforcement in 2012 Protects Communities From Harmful Pollution

Ron Musgraves said:
One from each state John 60 somthing total
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K gotcha-- I misunderstood your post because I've always been a numbers man which is always one of the first things I like at.
Question-How come Tony Shelton is not part of the UAMCC enviro team--- he seams to be the most informed one on the net at least.. I never spoke to Scott Stone about much of anything on this subject but I did speak to Jerry M. And he told me what his idea's were. I thought they were fascinating and if he does what he plans on doing I very well may fly there to sit in. I wish I did this In Houston. I love being at the place even if it's at the ground floor where there's unlimited potential...and as you know Ron I want to be there as well when it come to things when decisions are made and hopefully I was a positive influence there.

So Can u explain more about this Enviro strategy the UAMCC has?? I no longer sign into the UAMCC Site and to me PWI is light yrs ahead of that site....
Maybe we should start another thread on this.. Either way- what is the strategy here?
 
junker1 said:
What does this have to do with Tonys question? Robert, before you mention that I lack any knowledge on this whole thread let me say that i agree with you. so please shed a little light as to what I have been seeing/reading for the last 12 months.

95% percent of the p/washers on this board believe that you have met with represenetives from multiple agencys and proposed rules and or changes that would adversly affect the commom pressure washer and his work.

It is alleged that you wrote, proposed, touted, shopped, etc, these rules /changes while acting as the enviromental chairperson for a certain org.

It is said that you used your powers as an advocate, for the pressure washers your org represents, and proposed these changes to these agencys in order to sway the way these agencys think/thought of pressure washing , which in turn would mandate most pressure washers to buy reclaim equipment and It just so happens that you build design reclaim equipment.

So far individuals are making a strong case that this is true, and you have been asked certan questions that could clear everything up but your respnses have been a bunch of nothing. whats going on here? make a case for yourself or step away from being a represenitive to the pressure washers.
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Steven:

I am still working on your requested information, have 3 pages written so far. One problem I am having is that some of the EPA Links have been moved, deleted, and scanned in so that they are not searchable, particularly the CFRs published before the internet. They are scanned in and not searchable.

The information here will help you get familiar with terminology:

Terms of the Environment

http://www.epa.gov/region4/rcra/bfl...lds/glossaryofenvironmentalterms-2010july.pdf
 
John I will explain all our intentions , no false promises. Just what we intend to do.
Please start another thread

Clean County PW said:
K gotcha-- I misunderstood your post because I've always been a numbers man which is always one of the first things I like at.
Question-How come Tony Shelton is not part of the UAMCC enviro team--- he seams to be the most informed one on the net at least.. I never spoke to Scott Stone about much of anything on this subject but I did speak to Jerry M. And he told me what his idea's were. I thought they were fascinating and if he does what he plans on doing I very well may fly there to sit in. I wish I did this In Houston. I love being at the place even if it's at the ground floor where there's unlimited potential...and as you know Ron I want to be there as well when it come to things when decisions are made and hopefully I was a positive influence there.

So Can u explain more about this Enviro strategy the UAMCC has?? I no longer sign into the UAMCC Site and to me PWI is light yrs ahead of that site....
Maybe we should start another thread on this.. Either way- what is the strategy here?
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To answer John's question. I have 40 hour Hazwhoppper training. I designed and built my first recovery rig in 1995. I designed and implemented the hazardous waste program for the largest public utility in Arizona. When I designed the program, I was handed the federal regulations, and said, go to work and tell us what we need to do. I set up the program, and the disposal and tracking process and made it easy enough for the Boss' secretary, who was practically incompetent to be able to do. After I did the program, a consultant that had worked with multiple utilities in the past was hired to redesign the plan, and they took mine, without modification, and implemented it with all of their customers because it was so easy and effective.
I understand the whole environmental thing and am able to break it down into dumb components. As in simple enough that even a New York cop could understand it.
 
Once again we take one step forward and 2 steps back. Here Scott look up this phrase so you can learn something. It might help you out a little when where talking serious threads. "Transactional analysis".

Us "Dumb" cops were taught this in the worlds best academy so when we come up to an obnoxious person who may not be the sharpest tool in the shed we don't get dragged down to there state of mind. You may want to brush up on that one because it could help you out a ton---just sayin.
 
Robert, I don't know what you are preparing with 3 pages of information. Emulsification is an easy concept to understand. Virtually all references to emulsification worldwide refer to soaps and how they help "emulsify".

The question I asked is why did you introduce this concept into BMP's?

Sent from my DROID RAZR using Tapatalk 2
 
Tony Shelton said:
Robert, I don't know what you are preparing with 3 pages of information. Emulsification is an easy concept to understand. Virtually all references to emulsification worldwide refer to soaps and how they help "emulsify".

The question I asked is why did you introduce this concept into BMP's?

Sent from my DROID RAZR using Tapatalk 2
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Tony didn't Robert answer this in post # 322?
 
Doug Rucker-- I know you said if you have to remove any of my post I'm banned. In case your thinking that because of my Post #346 in reply to Scott Stones # 345 I'm only teaching Scott a term that he's probably not familiar with and it's something that can can have a positive affect on him if he applies it.. And it's only a suggestion that I do not expect him to understand it anyway.
 
Tony Shelton said:
I don't know how to ask more professionally.

I just want to know why you introduced emulsion and the verbiage that makes hot water the same as soap effectively removing all the exemptions we already had.

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Tony:

Here is a link to your answer in one of these documents and searches, it took me 6 hours to find it. Now that you know where to look and with the help of 60 people, it should be easy.

Stormwater Management Manual for Western Washington http://water.epa.gov/polwaste/nps/upload/9914.pdf

WQ-95-056, “Vehicle and Equipment Washwater Discharges,” 11-2012 https://fortress.wa.gov/ecy/publications/publications/95056.pdf

CASQA SC-21 BMPs http://www.cabmphandbooks.com/Documents/Industrial/SC-21.pdf

Oregon Allowed by the Wash Water Permit http://www.deq.state.or.us/wq/pubs/guides/washwaterdemin.htm

Oregon BMP
http://www.deq.state.or.us/wq/pubs/bmps/washactivities.pdf

CITY OF FORT WORTH ENVIRONMENT CODE CHAPTER 12.5 ARTICLE III - STORMWATER PROTECTION http://water.epa.gov/polwaste/nps/upload/nps-ordinanceuments-fort-worth-sw.pdf

Vehicle Maintenance and Washing Areas at Construction Sites
http://cfpub.epa.gov/npdes/stormwater/menuofbmps/index.cfm?action=browse&Rbutton=detail&bmp=63

Stormwater Program http://cfpub.epa.gov/npdes/home.cfm?program_id=6


National Menu of Stormwater Best Management Practices http://cfpub.epa.gov/npdes/stormwater/menuofbmps/index.cfm

NPDES Training Courses and Workshops http://cfpub1.epa.gov/npdes/outreach.cfm?program_id=0&otype=1#stormwater

Stormwater Basic Information http://cfpub.epa.gov/npdes/stormwater/swbasicinfo.cfm


Vehicle and Equipment Washwater Discharges http://nlquery.epa.gov/epasearch/ep...areapagefoot=epafiles_pagefoot&stylesheet=&po=
 
Ok, I finished the first one listed here http://water.epa.gov/polwaste/nps/upload/9914.pdf


First I read the entire thing (about 100 pages!!!) There is no mention of hot water, or emulsification by hot water anywhere in that document. I am a speed reader and it is highly doubtful that I missed it, but I guess anything is possible. After that I did a search for hot, elevated, emul*, etc just as a backup check on my reading and it is no there.


I will continue on to the next one. I hope I don't waste my whole day on a scavenger hunt. Is there anyway you could start quoting the relevant sections so it can be found without wading through 85 pages of industrial plant info?

I will move on to number two now.
 
Tony Shelton said:
Ok, I finished the first one listed here http://water.epa.gov/polwaste/nps/upload/9914.pdf


First I read the entire thing (about 100 pages!!!) There is no mention of hot water, or emulsification by hot water anywhere in that document. I am a speed reader and it is highly doubtful that I missed it, but I guess anything is possible. After that I did a search for hot, elevated, emul*, etc just as a backup check on my reading and it is no there.


I will continue on to the next one. I hope I don't waste my whole day on a scavenger hunt. Is there anyway you could start quoting the relevant sections so it can be found without wading through 85 pages of industrial plant info?

I will move on to number two now.
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Its there if you are looking for it, it took me 6 hours because I had forgotten where the information came from.
 
Ok, done with the second one located here: https://fortress.wa.gov/ecy/publications/publications/95056.pdf


First, Robert, you have looked up some of the most ridiculous BMP's in the nation. When I was in Seattle I didn't come across anyone who was implementing these BMP's. As a matter of fact, Seattle is one of the cleanest cities I have ever seen due to the frequent rainfall. As a matter of fact I was amazed at the fact that there was VERY little gum on the streets.

That comes from FREQUENT cleaning from GOD in the way of rain. If other parts of the country had that much rain their sidewalks would be clean too.

Ok, on to the substance of the link -

This document is against pressure washing at ALL. There is no mention of cold pressure washing being preferable to hot because of any kind of "emulsion" issue. As Matter of fact, they say NO PRESSURE WASHING AT ALL.

pressurewashinghot1_zps6f15894d.jpg


pressurewashinghot3_zpsbc1e5489.jpg



Are you saying that this document is supposed to answer my question about emulsification?


That document is from 2001. In Seattle I didn't come across ANY of that kind of archaic thinking with regulators.



IMG_2262_zps8cb9e732.jpg
 
Ok, finished number three which is here: http://www.cabmphandbooks.com/Documents/Industrial/SC-21.pdf

This document has nothing whatsoever to do with concrete cleaning.

It is all about car/fleet washing and it does not allow "steam" cleaning. Everyone knows what they are talking about here. The only "steam" cleaning that any regulator would ever be referring to would be the steam cleaning of engines which already is covered under separate BMP's.

Still, there is no reference whatsoever to "hot water is the same as so#p" or "hot water is an em&lsifier"

On to number four. If nothing else you have succeeded in wasting a good portion of my day.
 
Ok, now number four Below is the whole text.

So, finally we get to any mention whatsoever about hot water. Here, in Oregon, the state that is going to tax you for every mile you drive, we have found another draconian BMP.

Looking at the highlight in yellow you will see that, similar to the BMP that you are trying to force on us, this BMP calls for runoff from heated water cleaning can go in the storm drain.

But if you will look up a little higher, underlined in red, it also says NO RUNOFF FROM HEATED WATER CLEANING can go ANYWHERE ELSE EITHER. How is that going to work out for Jim if he is cleaning garages with 300 degrees?????

A better use of time than taking horrible bmp's like this and trying to craft a similar BMP for us would be for you to have spent a little time in Oregon convincing these people how ridiculous this Bmp is.

But that's ok Robert, We, at the UAMCC will take up the cause and fight Bmp's like this rather than use them as guidelines.

Still, there is no reference to hot water being considered an emulsifier, but I will go on to the next one.

pressurewashinghot4_zps9493a530.jpg
 
I am very familiar with this one.


The sections below actually say the opposite of what your BMP's say:

(b) It is an affirmative defense to any enforcement action for a
violation of subsection (a) that the discharge was composed
entirely of one or more ofthe following categories of discharges: ...

For the record this is talking about PERMITTED activities. It is saying that you are not breaking the law and you may use in your defense the fact that your discharge contained only the following:

(15) A discharge or flow from cold water (or hot water with
prior permissionof the Director) used instreetwashing or
cosmetic cleaning thatis notcontaminated with any soap,
detergent, degreaser, solvent, emulsifier, dispersant, or
any other harmful cleaning substance; or

Notice, you MAY use hot water and it may go into the storm drain, but you may not ADD an emulsifier.

IF hot water WAS considered and emulsifier, this entire paragraph would make no sense.

I will move on to the next one and try to get an answer to my question there.
 
Robert, this is unbelievable. The next five are just links to the EPA's different regs and bmps.

Really?

I've spent literally WEEKS reading through that information.

If there is ANYTHING there pertinent to my question could you please reference it?

I know it is not there, because I have already searched the entire EPA site for about 40 different keyword combinations that could have anything to do with considering hot water to be an emu#sifier and connecting that to cleaning plazas in any way.

It simply is not there.

Prove me wrong.

On to the last one.
 
Robert Hinderliter said:
Tony:

Here is a link to your answer in one of these documents and searches, it took me 6 hours to find it. Now that you know where to look and with the help of 60 people, it should be easy.

Stormwater Management Manual for Western Washington http://water.epa.gov/polwaste/nps/upload/9914.pdf

WQ-95-056, “Vehicle and Equipment Washwater Discharges,” 11-2012 https://fortress.wa.gov/ecy/publications/publications/95056.pdf

CASQA SC-21 BMPs http://www.cabmphandbooks.com/Documents/Industrial/SC-21.pdf

Oregon Allowed by the Wash Water Permit http://www.deq.state.or.us/wq/pubs/guides/washwaterdemin.htm

Oregon BMP
http://www.deq.state.or.us/wq/pubs/bmps/washactivities.pdf

CITY OF FORT WORTH ENVIRONMENT CODE CHAPTER 12.5 ARTICLE III - STORMWATER PROTECTION http://water.epa.gov/polwaste/nps/upload/nps-ordinanceuments-fort-worth-sw.pdf

Vehicle Maintenance and Washing Areas at Construction Sites
http://cfpub.epa.gov/npdes/stormwater/menuofbmps/index.cfm?action=browse&Rbutton=detail&bmp=63

Stormwater Program http://cfpub.epa.gov/npdes/home.cfm?program_id=6


National Menu of Stormwater Best Management Practices http://cfpub.epa.gov/npdes/stormwater/menuofbmps/index.cfm

NPDES Training Courses and Workshops http://cfpub1.epa.gov/npdes/outreach.cfm?program_id=0&otype=1#stormwater

Stormwater Basic Information http://cfpub.epa.gov/npdes/stormwater/swbasicinfo.cfm


Vehicle and Equipment Washwater Discharges http://nlquery.epa.gov/epasearch/ep...areapagefoot=epafiles_pagefoot&stylesheet=&po=
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Ok, I'm done. I am beside myself. You did a search for "Vehicle and Equipment Washwater Discharges" on the EPA's website and pull up 1,120 documents and somewhere inside there there is supposed to be the answer to my question as to why you added to your BMP's that hot water is the "same as so#p".

Everybody knows that cleaning a truck engine with steam will make oil and dirt come off the truck's engine.

Yet no one, anywhere, has stretched that so far as to say the cleaning a sidewalk with some gum and soda pop spills on it with hot water is in the same category as cleaning a truck engine on a dock over the lake.

Only you Robert.

You have wasted another day of my time and 20 years of the time of our industry.

Whatever good you have done in the industry over they years is going to be eclipsed by this sleight of hand you have tried to perform with these BMP's that, with the addition of the "hot water" caveat, would cause all of us everywhere to have to reclaim in every situation. And for what? To sell some vacuums? To sell some filters? Is there anything you will do for the industry that doesn't require a payoff on your end to be worth your time?

I would suggest you start working on some gravity/ground filters and hope that people have enough trust left in you to even buy anything at this point.




Guys, It's time to move on. There will be no answer forthcoming.

There is only one answer for why.

That answer is, Robert wants ALL cleaning to be reclaimed even if the government doesn't.

To do that, ALL cleaners that actually CLEAN something (hot water), instead of just hosing off MUST be classified as polluters, and they must reclaim.


We should give Jim Gamble and any other guys on the environmental team an opportunity to jump ship now that the reason for all this is clear. If they stay with him, they are guilty by association and should be considered just as trustworthy.

Please help the UAMCC turn back the clock and mop up this mess.
 
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