EPA Enforcement in 2012 Protects Communities From Harmful Pollution

810f250 said:
I agree on the independent analysis, if contractors want to present a strong case , we need to show beyond what we may consider logic, we need to present specific scientific evidence as a group IMO.






The effects of Option # 1 looks good on paper.

As you indicated their are three interdependent parties involved.


The contractor: I understand Option #1 benefits

The customers : They have to understand option #1 benefits, this decision is subject to factors/constraints on the owner, (attitude, budget, local ordinances, etc)

The Authority Having Jurisdiction: Ultimately they are the ones that have jurisdiction on the use of the storm water BMP use for option #1.

Tony, what can we offer/suggest to the AHJ's as "containment specific filters" and methods that may satisfy them?
We may also need to prove our claim of minimal effect on storm water BMP installation and it resulting outfall quality/improvement. The may also want a procedure for check and balances (maybe an NPDES permit for contractor)
The last challenge would be for AHJ's to change the ordinances on the books.
Click to expand...

Let me first address the NPDES permit for contractors. Nigel, I respect all your scientific knowledge, but you really need to go back and read the CWA. An NPDES for contractors would put us all out of business in one day. It is a large burden on big companies like 7-11 and auto repair chains. The costs involved would dwarf most of our annual incomes. We have to work within the NPDES permits held by our cities. There is no other option. Unless, we let the PwNA have it's way and only the few people on the board own all the powerwashing companies in the US and we just work for them.

Next, regarding the filters:

There are literally hundreds of filters on the market made to deal with just about any type of contaminant you can think of. The first thing you need to do is find out what contaminants they are concerned with from the type of property you are cleaning, then present them with a filter that deals with that contaminant.

After the BP oil spill there was an explosion of new technologies to deal with oil. Please observe the simplicity of this. The media in this example is less then $10.00:

Remember the claim that on quart of oil can contaminate 150,000 gallons of water?

 
Tony Shelton said:
Let me first address the NPDES permit for contractors. Nigel, I respect all your scientific knowledge, but you really need to go back and read the CWA. An NPDES for contractors would put us all out of business in one day. It is a large burden on big companies like 7-11 and auto repair chains. The costs involved would dwarf most of our annual incomes. We have to work within the NPDES permits held by our cities. There is no other option. Unless, we let the PwNA have it's way and only the few people on the board own all the powerwashing companies in the US and we just work for them.

Next, regarding the filters:

There are literally hundreds of filters on the market made to deal with just about any type of contaminant you can think of. The first thing you need to do is find out what contaminants they are concerned with from the type of property you are cleaning, then present them with a filter that deals with that contaminant.

After the BP oil spill there was an explosion of new technologies to deal with oil. Please observe the simplicity of this. The media in this example is less then $10.00:

Remember the claim that on quart of oil can contaminate 150,000 gallons of water?

Click to expand...

The NPDES Permits for Contract Cleaners take about 18 months to get, and then they are good only rural areas. They are not good within a city, or any place that has an NPDES Permit already, except in Oregon.
 
greg/sd said:
So what do you do while your waiting the 18 months go broke. Robert did you meet with any ahj's while you were in orlando at the pwna conventions.
Click to expand...

Not this time.
 
greg/sd said:
So what do you do while your waiting the 18 months go broke. Robert did you meet with any ahj's while you were in orlando at the pwna conventions.
Click to expand...

Unless you have a unique situation, NPDES Permits are a waste of time, except for Oregon.
 
810f250 said:
I agree on the independent analysis, if contractors want to present a strong case , we need to show beyond what we may consider logic, we need to present specific scientific evidence as a group IMO.






The effects of Option # 1 looks good on paper.

As you indicated their are three interdependent parties involved.


The contractor: I understand Option #1 benefits

The customers : They have to understand option #1 benefits, this decision is subject to factors/constraints on the owner, (attitude, budget, local ordinances, etc)

The Authority Having Jurisdiction: Ultimately they are the ones that have jurisdiction on the use of the storm water BMP use for option #1.

Tony, what can we offer/suggest to the AHJ's as "containment specific filters" and methods that may satisfy them?
We may also need to prove our claim of minimal effect on storm water BMP installation and it resulting outfall quality/improvement. The may also want a procedure for check and balances (maybe an NPDES permit for contractor)
The last challenge would be for AHJ's to change the ordinances on the books.
Click to expand...

Tony Shelton said:
Let me first address the NPDES permit for contractors. Nigel, I respect all your scientific knowledge, but you really need to go back and read the CWA. An NPDES for contractors would put us all out of business in one day. It is a large burden on big companies like 7-11 and auto repair chains. The costs involved would dwarf most of our annual incomes. We have to work within the NPDES permits held by our cities. There is no other option. Unless, we let the PwNA have it's way and only the few people on the board own all the powerwashing companies in the US and we just work for them.

Next, regarding the filters:

There are literally hundreds of filters on the market made to deal with just about any type of contaminant you can think of. The first thing you need to do is find out what contaminants they are concerned with from the type of property you are cleaning, then present them with a filter that deals with that contaminant.

After the BP oil spill there was an explosion of new technologies to deal with oil. Please observe the simplicity of this. The media in this example is less then $10.00:

Remember the claim that on quart of oil can contaminate 150,000 gallons of water?

Click to expand...


Good video. I use similar media but not under gravity

The NPDES permit was just one suggestion, ...............ok, no good.

Filters: lets narrow down what is suitable for specific types of cleaning situations, test/gather credible functional data

AHJ/EPA: Organize and make technology presentations as a substantial cohesive industry group to EPA,..... in addition local branches within the group can tackle local AHJ's.

Customers: Whats some of the best methods of approach to direct them to option #1? (higher frequency cleanings)
 
810f250 said:
I agree on the independent analysis, if contractors want to present a strong case , we need to show beyond what we may consider logic, we need to present specific scientific evidence as a group IMO.






The effects of Option # 1 looks good on paper.

As you indicated their are three interdependent parties involved.


The contractor: I understand Option #1 benefits

The customers : They have to understand option #1 benefits, this decision is subject to factors/constraints on the owner, (attitude, budget, local ordinances, etc)

The Authority Having Jurisdiction: Ultimately they are the ones that have jurisdiction on the use of the storm water BMP use for option #1.

Tony, what can we offer/suggest to the AHJ's as "containment specific filters" and methods that may satisfy them?
We may also need to prove our claim of minimal effect on storm water BMP installation and it resulting outfall quality/improvement. The may also want a procedure for check and balances (maybe an NPDES permit for contractor)
The last challenge would be for AHJ's to change the ordinances on the books.
Click to expand...
Excellent Nigel!!!! Best thought answers to the problems at hand I read yet.
 
810f250 said:
The last challenge would be for AHJ's to change the ordinances on the books.
Click to expand...
Great conclusion!! This is where we need all the real info and the available resources at our disposal to even get close to this one.
Keep thinking aloud Nigel-- your thought process is nailing the outline of what has to be done. Are you sure you don't have a degree in Philosophy? How about Negotiating?.. Love the way you think.
 
810f250 said:
Good video. I use similar media but not under gravity

The NPDES permit was just one suggestion, ...............ok, no good.

Filters: lets narrow down what is suitable for specific types of cleaning situations, test/gather credible functional data

AHJ/EPA: Organize and make technology presentations as a substantial cohesive industry group to EPA,..... in addition local branches within the group can tackle local AHJ's.

Customers: Whats some of the best methods of approach to direct them to option #1? (higher frequency cleanings)
Click to expand...


Hello Nigel, You are right, we need this data. That is why, about two years ago, when I asked Michael where the data on concrete cleaning was and he told me he only had done testing on Fleet Washing I was shocked.

We've had 20 years to get our own data. We are way behind. I have been working on this for a while with a university, but I have not come up with a cost yet. Being that the only people interested in it are contractors we will have to pool our money together to get it done. Anyone who would like to pledge a donation towards this should get in touch with Nicole at the UAMCC so we can determine how much we have to work with.

We (the UAMCC members) are also working on some presentations. I had hoped that the PW#A would not take this idea and run with it but thanks to this thread Robert has made it very clear that the last thing they want to do is present us any differently than the dozens of pictures he's posted presenting us as polluters. Any attempt at this point to change course would be seen, by anyone with a brain, as a shallow attempt to change how THEY (the PwnA) look to the contractors, not how the contractors look to the regulators.

Regarding the customers you would serve yourself well to simply listen to Ron Musgraves. Phoenix, as opposed to Houston or Ft Worth, is one of the cleanest cities in the nation. Ron was a pioneer in frequent cleanings and has been a major factor in the city's acceptance of frequent cleaning.

Are you going to get 8 cents a foot when you are cleaning once or even twice a week? No, but since Ron and Scott have been able to charge lower rates and still make plenty of money to travel all over the place helping contractors without asking vendors to pay their way, I'd say they have a winning combination with frequent cleaning.

You will have to ask Ron how to train your customers in that aspect. We are working on that here. My son now has almost as many weekly and biweekly accounts as he does monthly or quarterly.
 
Tony Shelton said:
Hello Nigel, You are right, we need this data. That is why, about two years ago, when I asked Michael where the data on concrete cleaning was and he told me he only had done testing on Fleet Washing I was shocked.

We've had 20 years to get our own data. We are way behind. I have been working on this for a while with a university, but I have not come up with a cost yet. Being that the only people interested in it are contractors we will have to pool our money together to get it done. Anyone who would like to pledge a donation towards this should get in touch with Nicole at the UAMCC so we can determine how much we have to work with.

We (the UAMCC members) are also working on some presentations. I had hoped that the PW#A would not take this idea and run with it but thanks to this thread Robert has made it very clear that the last thing they want to do is present us any differently than the dozens of pictures he's posted presenting us as polluters. Any attempt at this point to change course would be seen, by anyone with a brain, as a shallow attempt to change how THEY (the PwnA) look to the contractors, not how the contractors look to the regulators.

Regarding the customers you would serve yourself well to simply listen to Ron Musgraves. Phoenix, as opposed to Houston or Ft Worth, is one of the cleanest cities in the nation. Ron was a pioneer in frequent cleanings and has been a major factor in the city's acceptance of frequent cleaning.

Are you going to get 8 cents a foot when you are cleaning once or even twice a week? No, but since Ron and Scott have been able to charge lower rates and still make plenty of money to travel all over the place helping contractors without asking vendors to pay their way, I'd say they have a winning combination with frequent cleaning.

You will have to ask Ron how to train your customers in that aspect. We are working on that here. My son now has almost as many weekly and biweekly accounts as he does monthly or quarterly.
Click to expand...
Didn't we all wish we had your support.. But man when you disagree with someone it's like there the most awful person or group whoever existed..lol. The thing I admire about you Tony is your balls to the wall-- to bad we can't agree that Industry people aren't the bad guys here..
 
Clean County PW said:
Didn't we all wish we had your support.. But man when you disagree with someone it's like there the most awful person or group whoever existed..lol. The thing I admire about you Tony is your balls to the wall-- to bad we can't agree that Industry people aren't the bad guys here..
Click to expand...

Tell that to your friends who have demonized Ron, Scott and me. lol.
 
Well I hope you Scott and Ron can one day work out your differences with whoever you think demonizes them.
If & when I do my first RT since 2005, you Ron and Scott are welcomed to come.
Ron owes me a rematch in pool cause I let him win in Myrtle Beach..lol
 
Clean County PW said:
Well I hope you Scott and Ron can one day work out your differences with whoever you think demonizes them.
If & when I do my first RT since 2005, you Ron and Scott are welcomed to come.
Ron owes me a rematch in pool cause I let him win in Myrtle Beach..lol
Click to expand...

Thanks John, I will be glad to come. Can I carry you to protect me since we can't carry guns there? Lol

Sent from my DROID RAZR using Tapatalk 2
 
Clean County PW said:
Excellent Nigel!!!! Best thought answers to the problems at hand I read yet.
Click to expand...



Clean County PW said:
Great conclusion!! This is where we need all the real info and the available resources at our disposal to even get close to this one.
Keep thinking aloud Nigel-- your thought process is nailing the outline of what has to be done. Are you sure you don't have a degree in Philosophy? How about Negotiating?.. Love the way you think.
Click to expand...

LOL, no , far from it.


Tony Shelton said:
Hello Nigel, You are right, we need this data. That is why, about two years ago, when I asked Michael where the data on concrete cleaning was and he told me he only had done testing on Fleet Washing I was shocked.

We've had 20 years to get our own data. We are way behind. I have been working on this for a while with a university, but I have not come up with a cost yet. Being that the only people interested in it are contractors we will have to pool our money together to get it done. Anyone who would like to pledge a donation towards this should get in touch with Nicole at the UAMCC so we can determine how much we have to work with.

We (the UAMCC members) are also working on some presentations. I had hoped that the PW#A would not take this idea and run with it but thanks to this thread Robert has made it very clear that the last thing they want to do is present us any differently than the dozens of pictures he's posted presenting us as polluters. Any attempt at this point to change course would be seen, by anyone with a brain, as a shallow attempt to change how THEY (the PwnA) look to the contractors, not how the contractors look to the regulators.

Regarding the customers you would serve yourself well to simply listen to Ron Musgraves. Phoenix, as opposed to Houston or Ft Worth, is one of the cleanest cities in the nation. Ron was a pioneer in frequent cleanings and has been a major factor in the city's acceptance of frequent cleaning.

Are you going to get 8 cents a foot when you are cleaning once or even twice a week? No, but since Ron and Scott have been able to charge lower rates and still make plenty of money to travel all over the place helping contractors without asking vendors to pay their way, I'd say they have a winning combination with frequent cleaning.

You will have to ask Ron how to train your customers in that aspect. We are working on that here. My son now has almost as many weekly and biweekly accounts as he does monthly or quarterly.
Click to expand...



Move on Tony if the industry is behind. The UAMCC is moving to have independent sample testing done, thats great.

Building an industry position for sensible discharge to storm water BMP installations or storm drains via simple functional pre-treatment, will have its challenges and require facts that show the net positives.

As mentioned before, i have often wondered what is in the wash water from my cleanings, it may be a good starting point to review the water from various types of cleanings that AHJ's have some of the tightest ordinances . I have contacted product manufacturers that have labs, but they mainly experiment with their own flocculation solutions. I recall one of them mentioning that the estimated cost for constituent testing would be $50 per compound, and that they outsource the testing.


To answer communicating with Ron:
I have asked Ron, on a couple occasions , and he did respond to some of my questions, I met with him when he called and mention his family was visiting Maryland/DC last, he invited me and I listened to him speak with/to others at the informal contractor get together, I asked him "how do you get/convince a restaurant/dining/places to wash with a contractor weekly, biweekly" ; how to sell/how he sells in general,............ I will chalk up my lack of success to , poor techniques/incorrect target audience/inconsistency/task drive/focus,........most of last season I was engrossed with other focal points

I have settled out drive thu wash water, as I did in the "first flush rain event video" ; .....but the industries approach needs to be more scientific in determining what is in the wash water from varies typical washing circumstances and type of properties, also include storm runoff from inadequately serviced properties

The basic examinations I have performed last year was in part to aid in my wash water recovery plans, designs and filtration applications.......
 
We need you Nigel!

Let us know what you find out on your own and help us figure out some testing parameters.

The frequent cleanings take time and the customer needs to be trained on the value.

Many of us contractors are too small to understand the value of high volume work over high dollar work. That needs to be addressed also.

There is a time and place for high dollar contracting, but it is not everytime and everyplace.







Sent from my DROID RAZR using Tapatalk 2
 
Tony Shelton said:
We need you Nigel!

Let us know what you find out on your own and help us figure out some testing parameters.

The frequent cleanings take time and the customer needs to be trained on the value.

Many of us contractors are too small to understand the value of high volume work over high dollar work. That needs to be addressed also.

There is a time and place for high dollar contracting, but it is not everytime and everyplace.







Sent from my DROID RAZR using Tapatalk 2
Click to expand...
Now there's a potential workable solution. Working together to get to the end result. If we don't get the boot because sometimes we can argue for God knows when, every now and then there comes a post like the above..

One day maybe some of us can work with you as well Tony to get to where we have to go... Nigel is one smart dude who gives us guys here a ton.
 
I've been following this for the last couple days. I learned a few things here. First all of the small contractors need a group that will represent us. Second WE need to educate ourselves about these issues. Third don't let someone else dictate your future. PLEASE folks get educated. That's the only way to make informed decisions.

Sent from my Samsung Galaxy using TapaTalk
 
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