John:
I have answered this many times, but I seem to be talking over everyone's head. Sorry for that, they do not seem to be able to relate to the statement that the interpretation of the CWA is directly related to everyone's "Economic Revenue Stream". This include public concerned citizens, contract cleaners, environmentalists, regulators and AHJs, vendors, tree huggers, etc.
What one person see as being environmental correct, is seen as a pollutant my another. Also it makes a difference of which political party is in office in this interpretation and enforcement.
In the Dallas Fort Worth Area there about 115 jurisdictions, each with a different interpretation, often from one side of the street to the other. The Feds set the discharge limits and the locals set the BMPs.
Since 1989 I have discovered that certain procedures and scenarios are generally accepted and will satisfy the AHJs most of the time. If the Contract Cleaner is familiar with these BMPs, then they are in a very good position.
For enforcement to be reasonable, rational, and logical it has to be a compromise between all of the stakeholders.
Also, you are required to remediate your waste water to the "maximum extent practical". You are not suppose to do as little as possible!
I have released plans for you all to copy if you like that makes complying to the "maximum extent practical" very inexpensive.
Just like the Mayor of New York City said: "if you do not have a basic understand, then there is nothing I can do for you".