EPA Enforcement in 2012 Protects Communities From Harmful Pollution

[Robert Hinderliter]

All good Tony.. Cool video's.. Your doing something at least to be compliant probably enough where you shouldn't have a problem.. Isn't that what is being said in here all along?

This is why I think where all much closer then some realize.. "How this got turned into about saving the children" which is suggesting that others aren't here... I don't get that..

Also I still don't see how Robert is promoting us as polluters because he's giving us ways to do what you show above as a viable option. So where am I misreading this?

I have never promoted the industry as polluters, that people dreaming.

 

[Robert Hinderliter]

John, just try to follow along.

All this information Robert is putting out to regulators shows what horrible things we supposedly have to deal with as we "generate" pollution, according to him.

The fact is, even in worst case scenarios like the terrible 300 gallon grease spill, we can easily produce VERY clean water once we take the appropriate actions to do so.

The amounts of water we deal with on sidewalks is very minimal versus the amount of water that comes from a rainstorm. As a matter of fact, during the time I took to capture the video of the polyester gravity filtration, more rainwater passed through that filter than would pass through during a normal half hour of sidewalk cleaning.

In MANY cases, if we use the proper media on the GROUND we can do our jobs cleaning up the pollution leaving nothing more than water that is much cleaner than rainwater runoff. In addition, IF we come to the site, we pre-clean, which will eliminate trash and debris that would have otherwise washed directly into the storm drain.

We provide a pre-cleaning service for the storm water authority. We do not generate any pollution at all.

That is the point I am trying to make.

If you dispose of your waste water impropertly, then you as an individual are a polluter. This does not represent the whole industry.

 

[Robert Hinderliter]

 

[offdutyfireman]

We are not, and I explained what we are doing.

Then the problem cannot be resolved. If you do not realize that you are or will not admit that you are then you cannot help the industry.

 

[Scott Stone]

That is not true.

Then you are losing something in your message, because that is certainly how it is coming across. I would think that sometimes to represent the best interest of the contractors, that you have to make it more difficult for regulators to implement strict standards.

I do understand what you are claiming, but I do not see how proposing and including strict guidelines that require full recovery in the BMP's that the PWNA is using as a model ordinance, even when there is no off property discharge, is beneficial to the vast majority of the contractors.

 

[Scott Stone]

BTW, regarding the suggestion of Chris, if anyone would like me to blind post for them, I will do it, even if I disagree. Just send me a pm to this site, or send me an email to the-washer@msn.com. If you are someone that is banned on this site, but thinks you have a dog in the race, you can also email me, and I will post it unedited. If you have a problem with how I posted it, you can send a complaint to John, and he can verify if what I posted is accurate.
On your post, I will put that it is from an anonymous source, unless you are banned, then your name will be at the top of the post.

 

[Robert Hinderliter]

Then you are losing something in your message, because that is certainly how it is coming across. I would think that sometimes to represent the best interest of the contractors, that you have to make it more difficult for regulators to implement strict standards.

I do understand what you are claiming, but I do not see how proposing and including strict guidelines that require full recovery in the BMP's that the PWNA is using as a model ordinance, even when there is no off property discharge, is beneficial to the vast majority of the contractors.

What did I do wrong here? From http://www.lvstormwater.com/bmps_surfacecleaning.htm

 

[Robert Hinderliter]

Then you are losing something in your message, because that is certainly how it is coming across. I would think that sometimes to represent the best interest of the contractors, that you have to make it more difficult for regulators to implement strict standards.

I do understand what you are claiming, but I do not see how proposing and including strict guidelines that require full recovery in the BMP's that the PWNA is using as a model ordinance, even when there is no off property discharge, is beneficial to the vast majority of the contractors.

Why do you think so many people will not visit this board? You should read your comments.

 

[John Doherty]

Forget the attacks and politics. You see that's always the excuses from the other camps.

If it walks like a duck and talks like a duck..., maybe it's not an excuse, maybe it's true.

I would like to see some professional discussion and collaboration. Calling people out doesn't produce results, careful consideration and cooperation does.

You can stand in a room with a bullhorn and shout everyone else down, it won't make you right or make people agree with you, it just makes everyone else leave the room. Repeating the same thing ad nausem or trying to bury things in reams of technical documents, frustrates and also drives people away. I don't mean you personally, just referring to the tactics some seem to rely on.

My thoughts on moving forward are finding a consensus for all to operate within the bounds of the law without undue hardship and expense. Tearing each other down over different ways to accomplish this serves no one.

 

[Tony Shelton]

Why do you think so many people will not visit this board? You should read your comments.

Robert, if there was no audience here you wouldn't be here.

You are here reposting old regs for SEO because you know PWI is the authority when it comes to our industry and the surest way to get your message out.

PWI is filled with successful contractors who aren't afraid of getting the truth out.

Where we are different, here at PWI, is that we give you the forum to get your message out. In exchange for that freedom you are being made to back up your claims.

Other boards where the "people" are who "won't visit this board" do not allow free discussion such as this, but rather allows agendas, whether based on facts or falsehoods, to steamroll over everyone as long as the steamroller pays the forum's bills.

We can't be bought here.

Sent from my DROID RAZR using Tapatalk 2

 

[Tony Shelton]

What did I do wrong here? From http://www.lvstormwater.com/bmps_surfacecleaning.htm

There are two things wrong here Robert,

First, you didn't use these easy to work with BMP's as an example, but chose instead to make everyone reclaim by making BMP's that require reclaim when using hot water even though BMP's like this one do not.

Second, you presented this as the way to deal with ALL runoff. The BMP PRESUPPOSES that IF the water does not leave the property it DOES NOT FALL UNDER THE JURISDICTION OF THE EPA.

I know this because this is MY city's bmp's and I have spoken to them extensively about this.

For example, in the video below, runoff goes into a landscaped runoff area. That is the way most properties here have been built for years.

IF our water goes into something like this and remains on property OR evaporates ON property we have no further responsibility.

Why? Be cause these types of retention areas are designed for slow filtration INTO the ground when flows are slow. And anything left after evaporation is taken care of on a regular basis by the street sweepers that come in as much as 7 nights per week!

It's all very simple when you go to the regulators looking for ways to make it work instead of looking for ways to make it more difficult...

 

[Clean County PW]

BTW, regarding the suggestion of Chris, if anyone would like me to blind post for them, I will do it, even if I disagree. Just send me a pm to this site, or send me an email to the-washer@msn.com. If you are someone that is banned on this site, but thinks you have a dog in the race, you can also email me, and I will post it unedited. If you have a problem with how I posted it, you can send a complaint to John, and he can verify if what I posted is accurate.
On your post, I will put that it is from an anonymous source, unless you are banned, then your name will be at the top of the post.

Deal. If I don't get suspended or whatever it's called these days I'll work with Scott to make sure the truth gets out. I never have a problem with that.

Besides what Scott is saying I highly suggest for anyone to just send your post here without it going thru others. Step up and take the hits if they come.. That's where the answers come from.. Put them out exactly how you feel.. Let's hear your thoughts unedited.. If I'm gone before then.. I'll always be in the background reading & learning.

 

[Ron Musgraves]

If it walks like a duck and talks like a duck..., maybe it's not an excuse, maybe it's true.

I would like to see some professional discussion and collaboration. Calling people out doesn't produce results, careful consideration and cooperation does.

You can stand in a room with a bullhorn and shout everyone else down, it won't make you right or make people agree with you, it just makes everyone else leave the room. Repeating the same thing ad nausem or trying to bury things in reams of technical documents, frustrates and also drives people away. I don't mean you personally, just referring to the tactics some seem to rely on.

My thoughts on moving forward are finding a consensus for all to operate within the bounds of the law without undue hardship and expense. Tearing each other down over different ways to accomplish this serves no one.

Great join us and help www.uamcc.org

Will let you help with your area


Text me anytime for question 480-522-5227

 

[Robert Hinderliter]

If it walks like a duck and talks like a duck..., maybe it's not an excuse, maybe it's true.

I would like to see some professional discussion and collaboration. Calling people out doesn't produce results, careful consideration and cooperation does.

You can stand in a room with a bullhorn and shout everyone else down, it won't make you right or make people agree with you, it just makes everyone else leave the room. Repeating the same thing ad nausem or trying to bury things in reams of technical documents, frustrates and also drives people away. I don't mean you personally, just referring to the tactics some seem to rely on.

My thoughts on moving forward are finding a consensus for all to operate within the bounds of the law without undue hardship and expense. Tearing each other down over different ways to accomplish this serves no one.

I agree absolutely.

 

[Tony Shelton]

I agree absolutely.

My head is spinning.

You agree with what Robert?

You agree with moving forward and finding a consensus for all to operate within the bounds of the law without undue hardship and expense?


Because, if that is what you agree with, you had ample opportunity to find a consensus a year and a half ago when the overwhelming majority told you that your BMP's were on the wrong track and needed to be changed. But you chose to "stand in a room with a bullhorn and shout everyone else down," instead of working towards a consensus.

Here, let's nip this in the bud...... What needs to be changed in your Bmp's, your approach, and your presentation now Robert?

 

[Robert Hinderliter]

Posted:

"First, you didn't use these easy to work with BMP's as an example, but chose instead to make everyone reclaim by making BMP's that require reclaim when using hot water even though BMP's like this one do not."

The facts are:

"Hot water is defined as any water over 110°F.

Discharges to the storm drain using hot water cosmetic cleaning without any chemicals are approved provided that permission is granted by the Depart of Environmental Mgt prior to using the hot water. This exemption was designed for cosmetic cleaners washing objects such as sidewalks, headstones, walls and other things that are unlikely to be affected by the normal pollutants such as oil and grease.
Mobile commercial cosmetic cleaning means "power washing, steam cleaning, and any other mobile cosmetic cleaning operation, of vehicles and/or exterior surfaces, engaged in for commercial purposes."

Posted:

Second, you presented this as the way to deal with ALL runoff. The BMP PRESUPPOSES that IF the water does not leave the property it DOES NOT FALL UNDER THE JURISDICTION OF THE EPA.

The Fact is:

Discharges to Landscaped Areas: For discharges to landscaped areas (as indicated by “Yes” in the table below) you must do the following:

• (a) Obtain the property owner’s permission;
• (b) ensure discharge volume is small enough that it soaks into the ground without running onto paved areas, generally limit your discharge to 1,000 gallons/acre per month; collect waste water on property for distribution on property where discharge occurs, no off property discharge.
• (c) do not discharge repeatedly to the same areas because doing so may contaminate soil/groundwater, damage plants and cause other nuisance conditions;
• (d) ensure pH of the waste water is between 6.0 and 9.0 (use pH test strips).

 

[Robert Hinderliter]

There are two things wrong here Robert,

First, you didn't use these easy to work with BMP's as an example, but chose instead to make everyone reclaim by making BMP's that require reclaim when using hot water even though BMP's like this one do not.

Second, you presented this as the way to deal with ALL runoff. The BMP PRESUPPOSES that IF the water does not leave the property it DOES NOT FALL UNDER THE JURISDICTION OF THE EPA.

I know this because this is MY city's bmp's and I have spoken to them extensively about this.

For example, in the video below, runoff goes into a landscaped runoff area. That is the way most properties here have been built for years.

IF our water goes into something like this and remains on property OR evaporates ON property we have no further responsibility.

Why? Be cause these types of retention areas are designed for slow filtration INTO the ground when flows are slow. And anything left after evaporation is taken care of on a regular basis by the street sweepers that come in as much as 7 nights per week!

It's all very simple when you go to the regulators looking for ways to make it work instead of looking for ways to make it more difficult...

Tony:

Whos work do you think that work is based on? Because of my posting on the Internet, I have shaped almost every ordinance except for Oregon. A lot of them I reiewed and made comments, which were accepted about 80% of the time.

Read that language, a lot of it is copied. How do you think that everyone misteriously use the same verbage?


Tony:

Whose work do you think that work is based on? Because of my posting on the Internet, I have shaped almost every ordinance except for Oregon. A lot of them I reviewed and made comments, which were accepted about 80% of the time.

Read that language, a lot of it is copied. How do you think that everyone mysteriously use the same verbiage?

 

[Tony Shelton]

Tony:

Whos work do you think that work is based on? Because of my posting on the Internet, I have shaped almost every ordinance except for Oregon. A lot of them I reiewed and made comments, which were accepted about 80% of the time.

Read that language, a lot of it is copied. How do you think that everyone misteriously use the same verbage?


Tony:

Whose work do you think that work is based on? Because of my posting on the Internet, I have shaped almost every ordinance except for Oregon. A lot of them I reviewed and made comments, which were accepted about 80% of the time.

Read that language, a lot of it is copied. How do you think that everyone mysteriously use the same verbiage?

Robert, I wish you would make up your mind. Which is it? Are you the force behind all this or are you just a bystander?

Tony:

I did not create the "Hot Water Clause", the EPA Scientist did! I do not know for sure, but I think it was based on Oregon, San Francisco, and Miami/Fort Lauderdale Testing. This is the birth place of Mobile Cosmetic Cleaning Regulations.

I would like to take credit for everything you have alleged; but no one individual has that much influence on the EPA except the EPA Director and the President of the United States.

Sorry.

I ask you again, What needs to be changed in your Bmp's, your approach, and your presentation at this point Robert? Please answer with a written response and not some pages out of a pollution brochure.

 

[810f250]

19742 Germane Town Road

No water will ever Escape to the MS 4 US waters at that location. By LAW it is built compliant. Discharging into the grass there would be polluting, hauling water off would be increasing the liability of this owner. He paid money to have this system installed to keep him safe.

Any knuckle head picking up waste water here is a polluter unless they are permitted Licensed hauler to go directly to a pretreatment facility.


Welcome to the world of Ron Musgraves Enviro 101

A mobile cleaning operation should contact the local AHJ and obtain in writing that this installation can be used for commercial pressure cleaning wash water runoff, in my opinion.

Although it may appear obvious to a mobile cleaning operator who is aware of the EPA Region 6 wording and that it falls within the EPA's published guidelines, if the local AHJ says it cannot be used for such, it simply cannot be used for this purpose.

I can call and determine what is the AHJ's position on this installation.

The AHJ is who ensures that you will be in compliance within their local. Which in most cases I have experienced is on par with the EPA region 6 document or stricter

With the popularty of this thread , I think this local AHJ may have received communication from other than myself about this property, .....anyway I received a recommendation from AHJ for location, they do not suggest that powerwash/pressure cleaning wash water from cleaning be allowed to runoff/discharged to this BMP which they indicated is for storm water.

I am awaiting their response to runoff/discharge with pre-treatment.

 

[Ron Musgraves]

So let me ask this question......if my wash water goes to this interceptor am I violating? I know it doesn't go to a ditch or other body of water, so what's the answer?...And yes I already know the answer.



View attachment 22852View attachment 22853View attachment 22854

I'll answer, if you city has flipped its lid you could get sited.

Under normal washing adding no contaminates to your process, taking the proper BMP's to reduce what your able prior to entry your actually being more responsible than anyone Hauling or picking up.