Steven:
When I got involved; the industry was basically required to recycle waste water; all of the vendors were selling some type of recycle equipment. RGF was a major vendor because Ron Fink and Jerry Boyd were out front of everyone else.
My approach was that the "easier was the compliance", "the higher the level the compliance would be". This was a radical and was not accepted. I did not have the finances to fight it in court. I knew it was a political situation; I was not a political person. The industry was in turmoil. The Miami and San Francisco Areas for a short time stopped power washing. I knew that what happened in CA would affect TX in about two years.
I discussed this with a local AHJ; he took me under his wings and schooled me the ways of Regulatory Community. He told me that the CWA was basically interpreted by everyone's economic revenue stream and that our Industry was being controlled by the "Coin-Op Carwash Association" and the "Liquid Waste Haulers"; I was invited to a lot of regulatory training meetings, which were open to anyone who wanted to attend.
He could not talk to me as an individual company owner but could as a representative of a National Trade Association. I tried to get the manufactures to open up their association to everyone, they would not.
Then I launched PWNA and in April, 1995; had about 225 attendees to full fill the role of a trade association . In the early years the purpose was to establish Environment BMPs. The industry was dominated by small businesses that could barely survive, these type of operators saw no reason to unite, the value of a trade association, or the advantages of numbers.
The Manufacturers establish BMPs to basically support their efforts; I was chastised for creation BMPs that were favorable to the Contract Cleaner. After PWNA was formed, my wife and I got on a crowded elevator at a Manufactures Trade Show and everyone crowded to the other side! My wife's response was "What did you do now?". Simple, I established PWNA, which I gave to the Contract Cleaners.
PWNA was not being able to get very much accomplished for the first 3 years. So I arranged a Compliance Conference that resulted in 40 Environmental Regulators (Federal EPA all the way down to local regulators) and 100 contract cleaners attending. There was a lot of discussion between everyone, AHJ to AHJ and contractors to AHJs. The Feds, State, and Locals decided what each would be responsible for and basic structure and BMPs. This Conference resulted in the EPAs Model Ordinance, which was a group effort of stake holders and government:
- The best place for the Waste Water was the Sanitary Sewer with some exception for "cold water and no chemicals" and Hot Water without chemicals with preauthorization from the AHJ.
- Hot Water was above 110F (Major fight with Phoenix over this).
- The amount of waste water delivered to the Sanitary Sewer was insignificant compared to the total amount of waste water the POTW are handling.
- Because of the statement about the contractor would not have to use any special chemicals, they could continue their present procedures.
- Recycling was to be avoided if at all possible, as this concentrates the waste.
- Hot Water and Detergents are emulsifiers and should be treated the same (I did not create this, the AHJs did. Having a technical background, I could not argue the truth of this statement. I never dreamed I would be accused of creating this, which I was not until the Ron Machine got started).
- The major problem for the Sanitary Sewers was the silt and sludge which will stop up the sewer line and filters at the POTW. Filtration for these items would be required through a screen which would be easy for contract cleaners.
- The CWA say no Oil-Sheen, and oil absorbent boom will remove this.
- The contractor should pre-clean silt, sludge, hydrocarbons, etc.
- Based on the above two statements, Always Pre-clean, and Always Filter for Hydrocarbons and silt/sand/sludge.
- BMPs for Storm Water were not designed for "processed water" or "Industrial Water" and should be used only under the exceptions stated above.
- High Pressure Power Washing dislodges more contaminates that a rain event and cannot be treated the same. The dislodged items need to be collected before being washed into the MS4 and is not through filters designed for Storm Water; which are not designed for the increased load. The extra dislodged items will increase the TSS and Turbidity of the water and impair living organism.
- Chemical are nutrients and when added to the MS4 unset the natural habitat.
- Established that the Ordinance should be Reasonable, Rational, and logical (not arbitrary by the Regulators)
- The Model Ordinance is a Model for the Municipalities to follows, but not a requirement.
- Discharge to the Sanitary Sewer at Ph range of 5.0 to 12.0 and below 150F; solids - less than 250 mg/L, petroleum - less than 250 mg/L.
- For discharges to landscape areas you must do the following:
- Obtain the property owner’s permission.
- Ensure discharge volume is small enough that it soaks into the ground without running off the property. Limit your discharge to 1,000 gallons/acre per month.
- On property, wash water discharge can only occur on the property where the wash water is generated
- Do not discharge repeatedly to the same landscape area because doing so may contaminate soil and groundwater, damage plants, and cause other nuisance conditions.
- Ensure pH of the wash water is between 6.0 and 9.0 by using pH test strips.
- Use biodegradable, non-toxic, phosphate-free detergents when practical.
- Biodegradable does not mean non-toxic, it only means that it can be easily processed at a sanitary sewer plant. It does not mean that it can be discharged to the storm drain.
- Discharging to landscaping, sanitary sewers or storm drains under these guidelines is not a release of liability to the contractor or customer if clean up or remediation is required.
- Your customer is responsible for Cradle to Grave, only Oregon is the exception to this rule.
- If there is violation, then everyone in the chain of events can be sited, the local AHJ decides based on the circumstances who get cited.
The result of the Model Ordinance is that Expensive Recycling Equipment was no longer needed, why I was chastised at the Manufactures Association. I showed contractors how they could comply for a few hundred dollars, not thousands. I gave out enough information that the average contractor could build his own equipment.
I just announced simple inexpensive equipment to meet the model ordinance, revealed plans that everyone with any talent could copy, published remediation basics so that contractors could have a guideline on how to build their own system. All of this information is free; I will only get orders from contractors who time is more valuable than the cost of the equipment.
Some contractors order their first unit from me, then copy and build their own the next time.
I made it obvious that the contractor being compliant is more important than money in my life. People who suggest otherwise are brain dead.
