EPA Enforcement in 2012 Protects Communities From Harmful Pollution
- Thread starter Robert Hinderliter
- Start date
Clean County PW
Active member
Ron who is this guy and do you have more footage of this video? What exactly is his title? The 3+ minutes was very informative.
I'll have Kory Chime in on his name, he is on NCE Tampa Florida Agenda www.nationalcleaningexpo.net
He is a County Storm water authority.
Tony Shelton
BS Detector, Esquire
Kory sounds just like the guys here in Las Vegas and like half the guys in California, Oregon, and Washington I visited this summer.
I was at the Stormwater Authority meeting today in Las Vegas. They brought up the court case that was just decided against the EPA for declaring stormwater to be a pollutant if there was too much of it. (I know it's crazy). They were happy about the decision and said that is just one of the many cases that are making it to the courts and the courts are turning against the craziness. Most Stormwater guys I've met would consider Robert overly restrictive and Jim to be an absolute loon.
Guy Blackmon
Roundtable Host 2009
Well thanks Tony, but my knowledge is a drop in the bucket compared to others like you, Scott, Ron, Mr. H, and others. Our collective knowledge together can make a difference when the time comes to stem the tide of over regulation disguised as nothing more than revenue streams by others, and change the misinformation that paints our Industry as "Polluters" & "Unprofessional".
8000+ views.....interesting!
Clean County PW
Active member
There's some points in here that need a little bit more clarification. I'll attach my thoughts on what I understand them to be
1- Are the PWNA BMP's being "Shopped" as a rule or as a model that can be added to or subtracted from to fit the location in question? I listened to Roberts video on www.PWNA.org site in the past and it looks like what he is saying is that these BMP's are more of a guide that can be restructed to fit the area you may need them for where the AHJ's accept them.
2 -Is the PWNA "Shopping" BMP's for the one side fits all mentality? this is answered in question 1 which I don't believe that's what there doing because of what Robert states in the video of how these BMP's can be added to or deducted from to help the contractors in their area's to construct there own that very well be acceptable there.
3-Just because in one area some people thinks it's safe to let your dirty wash water from a gas station flow into the retention pond and they may have there local AHJ's agreeing with this but does that mean it can be done in a different Jurisdiction without any repercussions? This is the reversal of saying Exact BMP's with no leeway are being shopped by the PWNA nationwide. Just because in your area it may be allowed to let your wash water flow into a retention pond it doesn't mean it's allowed anywhere else. This one here could get many guys in trouble if that's the thought process. Everyone needs to do there due diligence in there AOE.
Now in my next post here I'm offering some potential solutions that may be attainable to go along with reading other thoughts on my above questions.
1- Are the PWNA BMP's being "Shopped" as a rule or as a model that can be added to or subtracted from to fit the location in question? I listened to Roberts video on www.PWNA.org site in the past and it looks like what he is saying is that these BMP's are more of a guide that can be restructed to fit the area you may need them for where the AHJ's accept them.
2 -Is the PWNA "Shopping" BMP's for the one side fits all mentality? this is answered in question 1 which I don't believe that's what there doing because of what Robert states in the video of how these BMP's can be added to or deducted from to help the contractors in their area's to construct there own that very well be acceptable there.
3-Just because in one area some people thinks it's safe to let your dirty wash water from a gas station flow into the retention pond and they may have there local AHJ's agreeing with this but does that mean it can be done in a different Jurisdiction without any repercussions? This is the reversal of saying Exact BMP's with no leeway are being shopped by the PWNA nationwide. Just because in your area it may be allowed to let your wash water flow into a retention pond it doesn't mean it's allowed anywhere else. This one here could get many guys in trouble if that's the thought process. Everyone needs to do there due diligence in there AOE.
Now in my next post here I'm offering some potential solutions that may be attainable to go along with reading other thoughts on my above questions.
Tony Shelton
BS Detector, Esquire
Regarding #1 and #2 you are underestimating Robert, John. He knows from experience that the AHJ's love cut and paste and they will take the Bmp's just like they are, just like some places did with the Ft Worth Bmp's.
The big problem (among others) here is Robert's BMP's make EVERYONE who cleans have to reclaim (because just about everyone uses hot water).
He knew this when he put them out. I informed him of it and he chose to steamroll all over everybody's objections.
Give him an award John, and let's all try something different. Robert was unwilling to work with us.
Clean County PW
Active member
So what can we do as a group to help get more notice?
The first thing that comes to mind is if there is another Houston down the line invite as many different representatives from multiple orgs and associations within the Powerashing Industry to appear there. You would be surprise that we mostly think alike and having different groups involved gives us even more credibility. I know this once again when in Union activities it always helped to have for example other Dep't contracts to help my guys come to conclusions along with our attorney on what to negotiate for.
If there is no Houston in the near future then we need to "Organize" an event strictly for Environmental purposes. Its not for money making purposes but for "Ground breaking purposes". The goal here is to get this industry noticed. On the end scale here maybe one day there could be grants given to multiple orgs/associations for educational purposes that also shows that we can protect our environment through... Education. Private and public colleges get these obviously all the time... So why can't we if we have a mutual agreement to work together on this??
Take the hatred and finger pointing out and clear your mind because you need to get the mindset that we can organize enough to get to that level and we need all the resources as in brains and common sense thinkers to work together on this and go in together as one Industry that's based on Education first..
The people I would look to get involved here would be some of the very people in this thread and outside of it as well. They would have to be either a Powerwashing contractor,distributor,manufacturer or any combination of those three... But it must be specific that there involved with Powerwashing in one way or another.
So those people that should be offered invites and they can add who they think as well would be on this list that can be added to because as a group representing different groups who in turn represents there own groups as well, now you have the beginnings of a force to be reckoned with.
Ron Musgraves,Scott Stone, Guy Blackmon,Paul Kassander, Ty Eubanks,Charlie Arnold,Jim Gamble, Nigel,Tony Shelton, Michael Hinderliter,Jerry McMillen, Myself(to keep it all together),Jim Vanhandle,Tim Fields and of course Robert Hinderliter who is as qualified as anyone to be in here.
Most people above represents groups, multiple groups or just there powerwashing friends who are non affiliated with any group.
Sorry if I spelled some names wrong and also if I left anyone out...but the more especially group members the better.
This is very realistic and can happened but if it was to happened we would have to be more respectful of each other when you go to that next level..
Thoughts??
The first thing that comes to mind is if there is another Houston down the line invite as many different representatives from multiple orgs and associations within the Powerashing Industry to appear there. You would be surprise that we mostly think alike and having different groups involved gives us even more credibility. I know this once again when in Union activities it always helped to have for example other Dep't contracts to help my guys come to conclusions along with our attorney on what to negotiate for.
If there is no Houston in the near future then we need to "Organize" an event strictly for Environmental purposes. Its not for money making purposes but for "Ground breaking purposes". The goal here is to get this industry noticed. On the end scale here maybe one day there could be grants given to multiple orgs/associations for educational purposes that also shows that we can protect our environment through... Education. Private and public colleges get these obviously all the time... So why can't we if we have a mutual agreement to work together on this??
Take the hatred and finger pointing out and clear your mind because you need to get the mindset that we can organize enough to get to that level and we need all the resources as in brains and common sense thinkers to work together on this and go in together as one Industry that's based on Education first..
The people I would look to get involved here would be some of the very people in this thread and outside of it as well. They would have to be either a Powerwashing contractor,distributor,manufacturer or any combination of those three... But it must be specific that there involved with Powerwashing in one way or another.
So those people that should be offered invites and they can add who they think as well would be on this list that can be added to because as a group representing different groups who in turn represents there own groups as well, now you have the beginnings of a force to be reckoned with.
Ron Musgraves,Scott Stone, Guy Blackmon,Paul Kassander, Ty Eubanks,Charlie Arnold,Jim Gamble, Nigel,Tony Shelton, Michael Hinderliter,Jerry McMillen, Myself(to keep it all together),Jim Vanhandle,Tim Fields and of course Robert Hinderliter who is as qualified as anyone to be in here.
Most people above represents groups, multiple groups or just there powerwashing friends who are non affiliated with any group.
Sorry if I spelled some names wrong and also if I left anyone out...but the more especially group members the better.
This is very realistic and can happened but if it was to happened we would have to be more respectful of each other when you go to that next level..
Thoughts??
Clean County PW
Active member
Robert can you answer this and tell us if what Tony is saying is accurate and also what can we do about this-- Thanks
You can argue if you like. My point is to better help you understand what you are talking about. If you have a meeting onsite with an inspector and refer to an infiltration trench as a filter, you have failed.
It is designed as a structure to introduce water back into the earth. It is not designed as a filter.
If you want to use it to reintroduce rinse water into the soil, by all means do so. If you want to do it as a part of a discussion with the AHJ, inform him that you have used oil absorb, dry swept the area, you used an oil sock to reduce any oil residue and you are putting water back into the earth that has had many contaminates removed. You are helping mother nature do her job. As a matter of fact, that infiltration trench is likely to last much longer on a property that is regularly cleaned than it will on a property that is not cleaned.
You have the option to act like you know what you're talking about when you're dealing with an inspector, exercise that option.
810f250
Griffs Services PowerWash
We would not want me to fail in front of an inspector , thats part of the reason we are discussing the systems.
I agree it is not designed as a filter, no argument or further discussion needed there.
Indeed if the property is cleaned adequately/frequently , it would assist the installation to perform its intended function better/unimpeded and longer without maintenance.
I truly would like to not just "act", but know what I talking about when dealing with an inspector and I am open to being educated, hence the discussion and contributions to the thread.
Do you think the installation in the gas station video is an infiltration trench?
Robert Hinderliter
Hall of Fame Member
The structure that you reference is a percolation trench, an infiltration trench or an open top drywell. Neither/none of which are designed to filter. It is not a filter, it is not designed to act as a filter and it should not be used as a filter. Sweep, oil absorb and go to washing but do not confuse infiltration or perc with filtering.
Quick copy and paste from a VA state document.:
Infiltration practices are generally suited for low- to medium-density development (38% to 66%
impervious cover). Specific conditions such as drainage area size and development conditions for
each infiltration practice are discussed in the appropriate section of this Standard.
MINIMUM STANDARD 3.10 CHAPTER 3
3.10 - 4
Planning Considerations
Infiltration facilities are subject to clogging and, therefore, are not recommended for areas where
sediment, grease, or oil loadings may be high. Such areas include roadways, parking lots, car
service facilities, etc. To increase the life expectancy of an infiltration facility, a pretreatment
facility such as a settling basin or “cell”, or additional BMP in series should be used to remove
sediments or other substances from the stormwater runoff before it enters the infiltration facility.
Edit to post illustration found with copied text.
Very good, thanks for the references to back up what has been said.
Robert Hinderliter
Hall of Fame Member
Also, is it the the property owner or a contractor doing the work; different rules for each.
Robert Hinderliter
Hall of Fame Member
The structure that you reference is a percolation trench, an infiltration trench or an open top drywell. Neither/none of which are designed to filter. It is not a filter, it is not designed to act as a filter and it should not be used as a filter. Sweep, oil absorb and go to washing but do not confuse infiltration or perc with filtering.
Quick copy and paste from a VA state document.:
Infiltration practices are generally suited for low- to medium-density development (38% to 66%
impervious cover). Specific conditions such as drainage area size and development conditions for
each infiltration practice are discussed in the appropriate section of this Standard.
MINIMUM STANDARD 3.10 CHAPTER 3
3.10 - 4
Planning Considerations
Infiltration facilities are subject to clogging and, therefore, are not recommended for areas where
sediment, grease, or oil loadings may be high. Such areas include roadways, parking lots, car
service facilities, etc. To increase the life expectancy of an infiltration facility, a pretreatment
facility such as a settling basin or “cell”, or additional BMP in series should be used to remove
sediments or other substances from the stormwater runoff before it enters the infiltration facility.
Edit to post illustration found with copied text.
Here is the link for Tim's article
http://www.dcr.virginia.gov/stormwater_management/documents/Chapter_3-10.pdf
Yes, absolutely. But listen to what Ron says at the beginning of the video. This is a retention area. If it had trees, shrubs, and grasses planted on top of it it would be a bio-retention area.
Infiltration is secondary, first the structure must retain the water. And yes, a hole in the ground with crushed aggregate in it is a "structure" for purposes of SWM.
So when discussing this particular install, you would not call it an infiltration structure but would refer to it as a retention area.
-
To be correct, the illustration of the infiltration trench that you posted here earlier would typically have a grass buffer at less than 5% slope of at least twenty feet in length (or width) before the water from the impervious area entered the trench. This grassy area pre-filters the cig butts, sediment, etc. before the SW reaches the infiltration trench. Because the retention structure in Ron's video does not have a filter area, it should not be called an infiltration structure even though that is ultimately what it does.
Yes, we are splitting nits here but Nigel seeks a deeper understanding so I will do what I can to help him develop it. :smile:
As I thought Construction , these are temporary systems.
More confusion
These mean they would not recommend cleaning a D6 Cat onsite and then expecting a temporary system to handle it. Nor would a Permanent
John No one is telling you to Pollute , these systems are built to trap and contain the pollution on property. This is so the property owner can deal with there own pollution.
Watch the Video and you will see the sand Box, underneath the sand box is a retention Tank. No one has determined out fall or no out fall. I say no outfall, its a gas station. If that water goes into the storm then they have a pretty sophisticated system we cannot see with our eyes. what you can see with your eyes appears to be trapping OIL.
WATCH Maryland not Arizona
Watch the Video and you will see the sand Box, underneath the sand box is a retention Tank. No one has determined out fall or no out fall. I say no outfall, its a gas station. If that water goes into the storm then they have a pretty sophisticated system we cannot see with our eyes. what you can see with your eyes appears to be trapping OIL.
WATCH Maryland not Arizona
This Video is priceless, this is showing that they are making property owners responsible or they would not be building and designing these systems. When I did my research years ago Maryland your state was actually the leader in permanent retentions not detention systems. The figure was in the 90% , I cannot imagine its lower.
As I thought Construction , these are temporary systems.
More confusion
These mean they would not recommend cleaning a D6 Cat onsite and then expecting a temporary system to handle it. Nor would a Permanent
No confusion here. Temporary in this context means that the water is held temporarily in the infiltration trench until the soil is able to absorb it. The opposite of temporary would be permanent. How big would the trench have to be if it held the water permanently?
Robert Hinderliter
Hall of Fame Member
John:
You are exactly right in your comments; the others are not reading or listening; there is nothing I can do for them. The comment about “one size fits all” is based on ignorance; like Forest Gump said: …………
There has never been a jurisdiction that has copied all of the EPA’s Cosmetic Cleaning Model Ordinance, and they are not required to. It is to be used as a guide. If they agree that it is applicable for their area then they probably will, if not like Houston then they will not follow it. The Jurisdictions are not stupid; it is evaluated for application for their area along with many other documents and references. Some of the time a “Public Comment Period” is held for comments from the stakeholders.
Since that is the most reference document for Environmental Cleaning; the terminology gets duplicated in a lot of BMPs because it has been up since 1996. A lot of the time it if not from that document, but from a document that copied the wording.
It is a Model to start from for Reference.