EPA Enforcement in 2012 Protects Communities From Harmful Pollution

[810f250]

Nigel, if a property is built to handle the pollution by design, your actually being less responsible by doing anything else other than practicing BMP procedures on property.

If it is built to handle the pollution buy design, great point,

hence I called the designers of the system installation and they recommended it was not.

I attempted to be as responsible as possible. The local authority mentioned they appreciated my efforts

 

[Ron Musgraves]

My answers in green.




Nor do ours, that was my devils Advocate Thread why didn't they do it. Here's what your not embracing, just do your best to clean whats existing on property. Do not allow your customers to create pollution, neglect of handing this more frequent is not and excuse either.

I do my best to clean what is existing on the property, but in doing so with pressure cleaning (even after practicing BMP's of dry clean up) I generate water that is now soiled, sometimes enough that it becomes a challenge to leave on property, without it escaping to area that I do not want it to go.

Sanitary is discharging it off property, long ago industrial sites delivered this waste to the city. The Clean water act is about no off property Discharge, Larger corporations had to start pretreating there own waste water prior to discharge off property. We do not fit into this category, we do not create waste. We only are reducers of pollution.

​I agree sanitary discharge is off property.

Some of the POTW's do not want to classify the type of pressure cleaning we provide into the category of "industrial discharge" and this would be awesome. This is what we collectively as pressure cleaners should be ensuring does not happen.

Lets look at an analogy of sweeping, I understand that sweeping activity does not created waste (**), ....in that its on the property and it would be collected and disposed of in a dumpster on the property, however it eventually makes it off property to the landfill.

(**)A problem could arise in the process of sweeping that may send some of the product being collected in the air. Thus the sweeping machines have air filters to minimize or reduce this release in the atmosphere.

With pressure cleaning we use the medium water to dissolve and dislodge the "trash" on a surface, we want to dispose of the resulting collection from pressure cleaning like we do when sweeping, since there is usually now soiled water dumpster on site for 3rd party to remove it, lets get it to the "soiled water landfill" the "water treatment plant".


Try talking to them differently, stop talking about this pollution you did not create but are cleaning up. ( Inside a contained area- Private property) Your local authorities have no jurisdiction over you unless you pose a threat. If you do not pose a threat they have no probable cause to enter the property. You might say well if I turn my machine on they would, in that case when it rains they should be over there handing citations to the owner of the rain water running off the property. Every property owner is responsible for there discharge if its happening. They would be the first sited....by your authorities as they are the largest violators and major offenders.


I dont say anything about pollution I create when communicating with the AHJ, however some of the authorities and citizens are often curious as to were the soiled water is going.

I can imagine the AHJ's are communicating with property owners/occupants after rain events for violations as a result of inspections or citizen reports.

This takes me back to Houston when I asked them why they have properties connected, they didn't have and answer. I asked lets go round up all the developers the building and Zoning manager and charge them all.

I only have one response , the off property discharge by the licensed solid waste hauler is legal. Therefore in compliance with government regulations. If I can practice this I'm doing what's right. Hauling waste to any place other than pretreatment by a licensed hauler is the only legal way. I don't care who you are or what state you reside. Take sludge off property without proper documentation and you could be far more criminally prosecuted than if you had left it.





Text me anytime for question 480-522-5227

 

[Ron Musgraves]

Then you should turn those criminals in!!!


Start asking your local politicians and Mayor why he is hurting our children.


The property owner should get a refund also, who is the design company? Love to talk to them on Camera


So your telling me they put a system to control pollution that was not adequate , but your local authority wants you who has no formal knowledge or education to become the pollution controller?

Love to have all the numbers of your local Authorities , love to talk to all of them on camera.

If it is built to handle the pollution buy design, great point,

hence I called the designers of the system installation and they recommended it was not.

I attempted to be as responsible as possible. The local authority mentioned they appreciated my efforts

 

[Tony Shelton]

NIGEL -My answers in green. I hope viewers understand that this was written in a calm tone, the written word is not always the best sole form of expression.


MY ANSWER - Nigel, this is the third time you have responded to me declaring that you are responding in a "calm tone". I don't know if you have been in some kind of counselling that has taught you to keep yourself calm by making this announcement or if you are somehow insinuating that I am not conversing with you in a "calm tone". If it is the latter, I'd invite you back to the conversations in my home and the conversations we've had on the phone and remind you that I have never spoken with you using anything other than a "calm tone".



NIGEL WROTE: Tony you read what I wrote, when you speak with John B, if he needs a refresher , ask him to reference his emails on the 08/14/12

MY ANSWER - I asked you for the data. If you had the data via emails, why didn't you just post them up? Please post them and save me a call to his boss.


I WROTE EARLIER - Anybody can make anybody say anything on the phone. I could ask "Is your system designed to deal with hundreds of gallons of gasoline and oil runoff while cleaning pads?" The obvious answer would be no.


NIGEL WROTE: Are you aware of my system?

MY ANSWER - I was not referring to your system I was referring to John B's system.

NIGEL ASKED - How do you handle the "soiled water" from the described cleaning?

MY ANSWER - I would keep everything on property. The are would be swept, dry cleaned with oil absorbents, cleaned with water, filtered with gravity filtration (if needed) as it leaves the pad, then I would allow the remaining water to enter the system installed by John B to take care of the rest. This way it remains on property. As a backup, it appears there is a retention pond (from your comments below) after that and probably a lot more vegetative filtration along the way before any water could ever get into a "water of the US".

NIGEL EXPLAINED HIS QUESTION TO MR. JOHN B. - I would like some information on a product that was installed on a property ,(he provided the design drawings), I then when on to explain that I am about to pressure clean the fueling pad and walks, can I direct the "wash water" to this installation for such activity?

You can inform all of us what his current response is.

MY ANSWER, No, Nigel, you can inform us of what his response was, according to your earlier statement your correspondence was via email. Let's see both your question and his response.


NIGEL -YOU WROTE
The other issue was the outlet of that installation lead off property to a storm pond.


MY RESPONSE - Apparently there is not only a built in filtration system, but also a retention pond, both specifically made to deal with runoff from gas stations and roads that somehow is incapable of dealing with 500 gallons of pre cleaned pad runoff? In this scenario you appear to be bringing in a vacuum filter to filter the filter before it gets to the landscape filter and makes it to the waterway (which filters itself in time anyway - see BP oil spill) And you think this is the most "Practicable" method for our industry?

NIGEL - YOUR RESPONSE ABOUT OFFICIALS:
I was told the calls that department often receives are from concerned citizens about illicit discharge. That local authority took matters very seriously and investigated a pressure cleaning contractor operation sometime recently prior to my call.


MY RESPONSE - Of course they get calls like that, The snake oil salesmen selling all kinds of filters and other contraptions don't "call". They come to the meetings and "shop".


NIGEL - YOUR STATEMENT -
I am not infatuated with fuel pads, it is something I have been interested in cleaning and have been asked to clean.

I have attempted to "dissect" the soiled water believe it or not, in the interim I have made what I believe to be educated summation of what the "runoff" contains, and hence identified some forms of filtration that reduces concentration of the initial contents in an attempt to comply with the pre-treatment requirements for sanitary discharge.
I will attempt again to have it scientifically analyzed, would you be interested in doing the same for a similar cleaning?
We both know the runoff would vary greatly on a host of factors, a few factors would be the initial type and quantity of ingredient, method of cleaning, detergents, etc etc

MY RESPONSE - Again, if you don't know what the runoff consists of how can you determine what filtration IF any further filtration prior to the on-site built-in system AND the retention pond is needed to comply?

Please try to follow the responses above. I didn't do colors because sometimes colors don't work on tapatalk.

 

[810f250]

I only have one response , the off property discharge by the licensed solid waste hauler is legal. Therefore in compliance with government regulations. If I can practice this I'm doing what's right. Hauling waste to any place other than pretreatment by a licensed hauler is the only legal way. I don't care who you are or what state you reside. Take sludge off property without proper documentation and you could be far more criminally prosecuted than if you had left it.





Text me anytime for question 480-522-5227

Some types of cleaning jobs do produce more "sediment" than others, I leave the majority of "sediment" on site from smaller area surface cleanings like, drive thrus , dumpster pads, ..........via either facility dumpster, or mulched bed if suitable.

 

[810f250]

Then you should turn those criminals in!!!


Start asking your local politicians and Mayor why he is hurting our children.


The property owner should get a refund also, who is the design company? Love to talk to them on Camera


So your telling me they put a system to control pollution that was not adequate , but your local authority wants you who has no formal knowledge or education to become the pollution controller?

Love to have all the numbers of your local Authorities , love to talk to all of them on camera.

All the contact information is listed for individuals in this thread.

The authority suggest that I minimize my impact of cleaning but following their outlined best management practices.

 

[Robert Hinderliter]

My answers in green. I hope viewers understand that this was written in a calm tone, the written word is not always the best sole form of expression.



So, Nigel, if I understand this correctly, you are saying that John Brown, from Contech Construction Products, Inc, told you on the phone that his products are so ineffective that they cannot handle runoff from a properly pre-swept and drycleaned, then deep cleaned Fuel pad? But rather, can only handle the occasional rain event?


Tony you read what I wrote, when you speak with John B, if he needs a refresher , ask him to reference his emails on the 08/14/12


I have screenshot this thread and will be sending it to him and his boss, Mr. Keating, on Monday to verify these claims.


I expected nothing less

Anybody can make anybody say anything on the phone. I could ask "Is your system designed to deal with hundreds of gallons of gasoline and oil runoff while cleaning pads?" The obvious answer would be no.


Are you aware of my system?

How do you handle the "soiled water" from the described cleaning?


But the question is deceptive. We may be dealing with a few hundred gallons of water, but the actual oil and gasoline content is only a tiny fraction of those gallons.

What question is deceptive?

To the best of my recollection the questions posed to John B was:

I would like some information on a product that was installed on a property ,(he provided the design drawings), I then when on to explain that I am about to pressure clean the fueling pad and walks, can I direct the "wash water" to this installation for such activity?

You can inform all of us what his current response is.


The other issue was the outlet of that installation lead off property to a storm pond.

It would be like calling and asking voters "Are you going to vote for Mitt Romney or that muslim guy wants to kill you if you don't convert to Islam.

As for the second part, The local water authority is the LAST place to find accurate information about any water filtration system. They are bombarded daily with a hundred guys like Robert who have "the best system" according to them. Most of them, like Robert, love to wrap the authorities around their fingers so that they can "shop" BMP's or rules that require contractors to use their products. Thankfully, most of the AHJ's, like mine here in Las Vegas already know this and laugh about them behind the scenes.


Surprising the local water authority of that jurisdiction had accurate information.

I was told the calls that department often receives are from concerned citizens about illicit discharge. That local authority took matters very seriously and investigated a pressure cleaning contractor operation sometime recently prior to my call.


Further, the local authorities don't want to deal with any runoff issues at all. Asking them about the abilities of a commercially available detention system is like asking PETA (the people for ethical treatment of animals) what are the kill shot capabilities of a 30-06 at 200 yards.


Like I said it was just the opposite of your experience with my local authorities.


You seem to be so infatuated with fuel pads why have you not dissected what is actually in the runoff before filtration to find out exactly what kind of filtration you need. In other words, we have no cottonwood here in Las Vegas. It would be stupid (and completely dishonest) of me to sell my customers cottonwood filters for their condensers.

I am not infatuated with fuel pads, it is something I have been interested in cleaning and have been asked to clean.

I have attempted to "dissect" the soiled water believe it or not, in the interim I have made what I believe to be educated summation of what the "runoff" contains, and hence identified some forms of filtration that reduces concentration of the initial contents in an attempt to comply with the pre-treatment requirements for sanitary discharge.

I will attempt again to have it scientifically analyzed, would you be interested in doing the same for a similar cleaning?

We both know the runoff would vary greatly on a host of factors, a few factors would be the initial type and quantity of ingredient, method of cleaning, detergents, etc etc

How do you know what is needed to filter this waste if you don't even know what is in it and in what concentrations?

I was involved with the study of what is in Power Washing Waste Water with State of Oregon in 1992 & 93. The results were published in 1994 and this is the basis the Power Washing Regulations to meet the Maximum Extent Practical.

They are now published under the PWNA Environmental Tab.

Resources for Regulators

The Oregon Study of Cosmetic Cleaning, June 1994

• Best Management Practices: (PDF)
• Characterization of Waste Wash Water: (PDF)
• Investigation of Washing Activities: (PDF)

Most everything comes down to Politics, lots of give and take; which does always make any sense!

 

[Robert Hinderliter]

Ill play devil advocate , why not hook the property directly to sanitary.


Text me anytime for question 480-522-5227

The only reason I am aware of is cost of doing so. Public is not willing to pay for it.

 

[Robert Hinderliter]

Thanks Robert, I have been trying to make heads or tails of this, lol, isnt easy though. when you say that contract cleaners are at the bottom of this chain how far down are we ? should I as a residential cleaner be worried about the federal epa? Should i pick up a reclaim system to have on board if the epa does show up?

Presently there is almost no enforcement for Residential Cleaning. However, I recommend putting down Oil Absorbent Booms which will remove the oil sheen and some silt. If possible direct the waste water to the yard for bio-remediation.

Watch our for Ground Water Contamination.

 

[Robert Hinderliter]

Tony Shelton I should have mentioned your name as well as one of the guys who post on PWI that has a ton of knowledge on environmental cleaning as well.

Since you do alot of reading and studying up on this topic and of course dealing with it out in the streets.. I'm curious if your going to rebut what Nigel posted since Nigel was told this by his local Storm system representative and also gives the persons name.

Because some may not agree with this spokesperson does it make it right let's say in Nigel's area to do do the cleaning the way we say it's right? Is that the direction this this thread will end up going do you think?

I'm interested to see what you would suggest Nigel should do since he was given his information.

Plain and simple: Doing it right is whatever your local AHJ says it is!

 

[Robert Hinderliter]

Here's the reality, my wash Process create no pollution. I reduce pollution existing in the contained environment. The minute I start practicing the fundamental principals of a BMP, sweep and collect Large Debris. I have reduced Pollution, take it another step if there are large amounts of contaminates use and absorbent prior to wash process.

I'm ready to begin my contained wash on this compliant property, next I look to see where I can use and absorbent sock or other device to allow the stream of water to further collect any existing pollution that already existed on this site. I'm further continuing to reduce pollution on this property through the entire wash process. If my water get to the collect system built on this property I could claim I reduced the pollution thats was already existing substantially prior to any rain event.

I used the most responsible method at least six water authorities regulators have deemed to be the most responsible. Hauling or using sanitary was not intended by design, every property owner is responsible for there own discharge, property are suppose to handle any rain event. There for the out-fall should not happen until the water has been filtered by there system if there is any. As the Educator mentions in this video man made Ponds are made to retain the water permanently.

Please understand this has nothing to do with Discharging into the MS4


Robert you have been or rep to this industry for about 10 years, I have been following You since 1996. I would say Lance, Kendra & a Gal from California who now herself is out of business.

These people have the same thing in common with the distributor in Houston that was pushing strict guidelines, they are all out of business.

Robert if you use the words responsible you need to talk first about containment. never entering the MS4, you will never because I have asked you many times over the years. I remember explaining it to you years ago and I know you understand and you get it.

Having Pressure washers hauling Waste water will never be a practical responsible method, Houston didn't this so.

Next all these people you are posting as violators have often millions of gallons of waste water, it doesn't compare even If I did ad contaminants to my wash process, which by the way i do not.

Ron: Since about 1989 I started representing the Industry because no one else would.

 

[Robert Hinderliter]

good post Ron.. I'll ask Robert myself again which I do believe I asked him this very question as well in the past. He post some of the stuff he does because these companies and circumstances he sometimes writes about are at the "top of the food chain" of companies that get hit with violations. These have a way to trickle down to what some people including prop. Management companies think about our services at times which is at the bottom of their list of importance-- us Powerwashers.

Robert makes us aware of this and where it starts from at times... At least that's my take on it. I'll have to ask him again since as I get older these challenges do become more interesting to me.

So Ron-- question for you.. What do you suggest for guys that do parking garages on how they should handle the massive sludge issues we run into and do we take that off of premises if the property doesn't have a place to dispose of it?

John: You are correct, sh?? flows down hill and if you will look you will see it coming. I targeted Miami/Fort Lauderdale and San Francisco in 1980 to know when it would hit our industry. I estimated that it would hit these places first, and made personal friends in these areas to keep track of enforcement. It started here just as expected! The suprise was Oregon, which went about things better than anyone else.

Their work was not generally excepted because they were a small state. They still have the best program in the US.

 

[Tony Shelton]

I was involved with the study of what is in Power Washing Waste Water with State of Oregon in 1992 & 93. The results were published in 1994 and this is the basis the Power Washing Regulations to meet the Maximum Extent Practical.

They are now published under the PWNA Environmental Tab.

Resources for Regulators

The Oregon Study of Cosmetic Cleaning, June 1994

• Best Management Practices: (PDF)
• Characterization of Waste Wash Water: (PDF)
• Investigation of Washing Activities: (PDF)

Most everything comes down to Politics, lots of give and take; which does always make any sense!

Robert, a couple of years ago I asked Michael to give me access to the testing you did on runoff water. Michael told me that the only testing you had ever done was on fleet wash runoff. Now, after a few years of saying it, you've proven that I tell the truth in these matters.

Armed with fleet wash runoff data you have been "shopping" Bmp's for the entire powerwashing industry as if we all wash fleets. My son cleans major, dumpster sized, grease spills for a large Biodiesel company. Would it be fair to take data from that runoff and try to impose BMP's on guys cleaning roofs??????

Yes, Robert, most everything does come down to politics. You have been operating as a moderate when we needed a hawk. Please change your course on this asap and start fighting for us. We are cleaners, not polluters. We can easily filter on the ground and go about our business making money at a fair rate without adding additional costs in order to raise rates and rape our customers.

Please use your experience to help us.

 

[810f250]

[FONT=Tahoma, Calibri, Verdana, Geneva, sans-serif]NIGEL -My answers in green. I hope viewers understand that this was written in a calm tone, the written word is not always the best sole form of expression.[/FONT]


[FONT=Tahoma, Calibri, Verdana, Geneva, sans-serif]MY ANSWER - Nigel, this is the third time you have responded to me declaring that you are responding in a "calm tone". I don't know if you have been in some kind of counselling that has taught you to keep yourself calm by making this announcement or if you are somehow insinuating that I am not conversing with you in a "calm tone". If it is the latter, I'd invite you back to the conversations in my home and the conversations we've had on the phone and remind you that I have never spoken with you using anything other than a "calm tone". [/FONT]


[FONT=Tahoma, Calibri, Verdana, Geneva, sans-serif]That statement was not for anyone one person in particular, ....I did it this time and others because, I have read post on forums and even others have mentioned to me about how they perceived/read post responses , that they/I on occasion have added a tone while reading the response that the author may have not intended.[/FONT]


[FONT=Tahoma, Calibri, Verdana, Geneva, sans-serif]NIGEL WROTE: Tony you read what I wrote, when you speak with John B, if he needs a refresher , ask him to reference his emails on the 08/14/12[/FONT]

[FONT=Tahoma, Calibri, Verdana, Geneva, sans-serif]MY ANSWER - I asked you for the data. If you had the data via emails, why didn't you just post them up? Please post them and save me a call to his boss.
[/FONT]

I do not have that data via emails, What I have via emails is literature of the type of system installed at property. I mentioned the date so if John B does not recall he has a reference, search is emails to jog his memory. I think it would be better for you to get the info from the source anyway, this would minimize any possible issues of....... he say they say.


[FONT=Tahoma, Calibri, Verdana, Geneva, sans-serif]I WROTE EARLIER - Anybody can make anybody say anything on the phone. I could ask "Is your system designed to deal with hundreds of gallons of gasoline and oil runoff while cleaning pads?" The obvious answer would be no.[/FONT]


[FONT=Tahoma, Calibri, Verdana, Geneva, sans-serif]NIGEL WROTE: Are you aware of my system?[/FONT]

[FONT=Tahoma, Calibri, Verdana, Geneva, sans-serif]MY ANSWER - I was not referring to your system I was referring to John B's system.

[/FONT]
I misunderstood what you wrote, (interesting, the written word may seam clear to one person but understood differently by another)


[FONT=Tahoma, Calibri, Verdana, Geneva, sans-serif]NIGEL ASKED - How do you handle the "soiled water" from the described cleaning?[/FONT]

[FONT=Tahoma, Calibri, Verdana, Geneva, sans-serif]MY ANSWER - I would keep everything on property. The are would be swept, dry cleaned with oil absorbents, cleaned with water, filtered with gravity filtration (if needed) as it leaves the pad, then I would allow the remaining water to enter the system installed by John B to take care of the rest. This way it remains on property. As a backup, it appears there is a retention pond (from your comments below) after that and probably a lot more vegetative filtration along the way before any water could ever get into a "water of the US".
[/FONT]

I have seen written many times "leave everything on property", I have tried to do this on drive thru and dumpster pad cleanings, but find it difficult to perform such a task without the water attempting to escape along the slopes of the hard surfaces and going to an area where I do not want it to go. example the storm drain.

I have seen your argument for gravity filtration, and I am aware that construction industry utilizes this type of filtration, and frankly I think it should be acceptable for some cleaning situations.

John B's system does not allow it to remain on property, but I feel it could be of benefit if it is in good working condition and directed to sanitary during the cleaning (note: it is up to the owner to maintain the system adequately).

There is a pond off property, it is open to the storm system. It has is a rock lined drainage (to prevent erosion) from John B's system to the pond.


[FONT=Tahoma, Calibri, Verdana, Geneva, sans-serif]NIGEL EXPLAINED HIS QUESTION TO MR. JOHN B. - I would like some information on a product that was installed on a property ,(he provided the design drawings), I then when on to explain that I am about to pressure clean the fueling pad and walks, can I direct the "wash water" to this installation for such activity?[/FONT]

[FONT=Tahoma, Calibri, Verdana, Geneva, sans-serif]You can inform all of us what his current response is.[/FONT]

[FONT=Tahoma, Calibri, Verdana, Geneva, sans-serif]MY ANSWER, No, Nigel, you can inform us of what his response was, according to your earlier statement your correspondence was via email. Let's see both your question and his response.[/FONT]


I answered this above in this post, our email communication does not contain his response, I got that verbally.

You may call and have him if possible indicate his current response/position in email. I can only tell you what was communicated to me.


[FONT=Tahoma, Calibri, Verdana, Geneva, sans-serif]NIGEL -YOU WROTE[/FONT]
[FONT=Tahoma, Calibri, Verdana, Geneva, sans-serif]The other issue was the outlet of that installation lead off property to a storm pond.[/FONT]


[FONT=Tahoma, Calibri, Verdana, Geneva, sans-serif]MY RESPONSE - Apparently there is not only a built in filtration system, but also a retention pond, both specifically made to deal with runoff from gas stations and roads that somehow is incapable of dealing with 500 gallons of pre cleaned pad runoff? In this scenario you appear to be bringing in a vacuum filter to filter the filter before it gets to the landscape filter and makes it to the waterway (which filters itself in time anyway - see BP oil spill) And you think this is the most "Practicable" method for our industry?
[/FONT]

I described to you what I was told the properties installed unit function was.
The pond is open to the storm water system, and AHJ says that is for storm water.

My suggestion on the most "practicable " method is to allow the pre-treatment and discharge of liquids to sanitary sewer, and the solids to dumpster


[FONT=Tahoma, Calibri, Verdana, Geneva, sans-serif]NIGEL - YOUR RESPONSE ABOUT OFFICIALS:[/FONT]
[FONT=Tahoma, Calibri, Verdana, Geneva, sans-serif]I was told the calls that department often receives are from concerned citizens about illicit discharge. That local authority took matters very seriously and investigated a pressure cleaning contractor operation sometime recently prior to my call.[/FONT]


[FONT=Tahoma, Calibri, Verdana, Geneva, sans-serif]MY RESPONSE - Of course they get calls like that, The snake oil salesmen selling all kinds of filters and other contraptions don't "call". They come to the meetings and "shop".
[/FONT]



[FONT=Tahoma, Calibri, Verdana, Geneva, sans-serif]NIGEL - YOUR STATEMENT -[/FONT]
[FONT=Tahoma, Calibri, Verdana, Geneva, sans-serif]I am not infatuated with fuel pads, it is something I have been interested in cleaning and have been asked to clean.[/FONT]

[FONT=Tahoma, Calibri, Verdana, Geneva, sans-serif]I have attempted to "dissect" the soiled water believe it or not, in the interim I have made what I believe to be educated summation of what the "runoff" contains, and hence identified some forms of filtration that reduces concentration of the initial contents in an attempt to comply with the pre-treatment requirements for sanitary discharge.[/FONT]
[FONT=Tahoma, Calibri, Verdana, Geneva, sans-serif]I will attempt again to have it scientifically analyzed, would you be interested in doing the same for a similar cleaning? [/FONT]
[FONT=Tahoma, Calibri, Verdana, Geneva, sans-serif]We both know the runoff would vary greatly on a host of factors, a few factors would be the initial type and quantity of ingredient, method of cleaning, detergents, etc etc[/FONT]

[FONT=Tahoma, Calibri, Verdana, Geneva, sans-serif]MY RESPONSE - Again, if you don't know what the runoff consists of how can you determine [/FONT]what filtration[FONT=Tahoma, Calibri, Verdana, Geneva, sans-serif][/FONT]IF any further filtration[FONT=Tahoma, Calibri, Verdana, Geneva, sans-serif] prior to the on-site built-in system AND the retention pond is needed to comply?
[/FONT]I have a reasonable idea of what filtration is needed based on the few science classes i have done, communication with my AHJ, storm water engineers, POTW, other contract cleaners in our industry, and others.



Please try to follow the responses above. I didn't do colors because sometimes colors don't work on tapatalk.

I did my best.

 

[Tony Shelton]

Nigel, if runoff could be gravity filtered so that no EPA listed contaminants made it to the storm drain and if you had a non toxic substance that would turn your sludge into an instant solid that could be disposed of in the dumpster would you turn your efforts towards that method and start putting your collected sludge in the dumpster instead of on youtube to frighten people with a visual that doesn't represent what we do?

Sent from my DROID RAZR using Tapatalk 2

 

[Ron Musgraves]

Nigel, if runoff could be gravity filtered so that no EPA listed contaminants made it to the storm drain and if you had a non toxic substance that would turn your sludge into an instant solid that could be disposed of in the dumpster would you turn your efforts towards that method and start putting your collected sludge in the dumpster instead of on youtube to frighten people with a visual that doesn't represent what we do?

Sent from my DROID RAZR using Tapatalk 2

Or you could allow the systems in place handle them?

 

[Guy Blackmon]

Arguing among ourselves gets us nowhere, and has allowed misinformation to spread. We as Contractors have not done our job in keeping our eye on the ball and we're letting this (regs.) get out of hand.

Lets work together, not fight each other.

 

[Tony Shelton]

Arguing among ourselves gets us nowhere, and has allowed misinformation to spread. We as Contractors have not done our job in keeping our eye on the ball and we're letting this (regs.) get out of hand.

Lets work together, not fight each other.

I hope you are talking to Robert. He is the one who refuses to work with us. We overwhelmingly asked him not to "shop" and to remove the new and overly restrictive "hot water" clause.

Sent from my DROID RAZR using Tapatalk 2

 

[Clean County PW]

Arguing among ourselves gets us nowhere, and has allowed misinformation to spread. We as Contractors have not done our job in keeping our eye on the ball and we're letting this (regs.) get out of hand.

Lets work together, not fight each other.

Couldn't have said this any better Guy. I find this thread interesting of course but I'm picking up the vibes in here and was thinking what you posted above.

 

[Tony Shelton]

Couldn't have said this any better Guy. I find this thread interesting of course but I'm picking up the vibes in here and was thinking what you posted above.

Somehow I am not so sure you and Guy were thinking the same thing John

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