EPA Enforcement in 2012 Protects Communities From Harmful Pollution

Something to think about: No matter who tells you to haul away wash water, you should not do it UNLESS you are a LICENSED WASTE HAULER with the D.O.T. approved vehicle, D.O.T. approved tank, CDL with Hazmat endorsement, MSDS of what is in the tank (of the detergents, contaminants, wash water, etc.....), Proper Paperwork, etc........

It is easy for anyone to tell you to haul away wash water but what they have no clue about is the potential fines you will get if caught, or in an accident, someone tells on you or any other type of situation that the D.O.T. officers, State Police, or State Troopers get involved and start asking questions. This is where you can get a fine large enough to put you out of business and/or vehicle impounded or put out of service until you have a licensed waste hauler come and vacuum out your tank and haul it away properly after you give him the msds of what is in the tank and proper paperwork (manifest) so he can do his job the right way, legally.
 
Something to think about: No matter who tells you to haul away wash water, you should not do it UNLESS you are a LICENSED WASTE HAULER with the D.O.T. approved vehicle, D.O.T. approved tank, CDL with Hazmat endorsement, MSDS of what is in the tank (of the detergents, contaminants, wash water, etc.....), Proper Paperwork, etc........

It is easy for anyone to tell you to haul away wash water but what they have no clue about is the potential fines you will get if caught, or in an accident, someone tells on you or any other type of situation that the D.O.T. officers, State Police, or State Troopers get involved and start asking questions. This is where you can get a fine large enough to put you out of business and/or vehicle impounded or put out of service until you have a licensed waste hauler come and vacuum out your tank and haul it away properly after you give him the msds of what is in the tank and proper paperwork (manifest) so he can do his job the right way, legally.

Anyone, no matter who they are that tells you to just haul it away is setting you up for huge problems that could potentially get you in serious trouble, serious fines and/or lots of bad publicity if something happens.

Imagine the news crew reporting on you getting fined and finding out that you are hauling hazardous waste, not a hazardous waste hauler, no proper license, no D.O.T. approved vehicle or tank, no training, no certification, no CDL with hazmat endorsement, etc..... This can just about make you look like a terrorist if spun a certain way, especially if involved in an accident. Do you really want something like this to happen to you because you listened to someone that has no clue that told you to do the job you have to haul away the wash water.

God-forbid someone wrecks into your truck/trailer and you are not able to talk, they will call in the hazmat cleanup crew (charging about $1000.00 per hour or more most of the time) to clean up the mess and they find out that you have no msds on what is in the washwater tank or manifest, how do you think they will handle it? ? ? It will be treated as worse case scenario and you will be charged accordingly.

This is the time it only gets worse and worse, especially if the news is aware of this and wants to report about a toxic spill on a roadway and nobody knows what was spilled so they are thinking that maybe they need to evacuate the immediate area for safe precaution.

This is what happens when toxic cargo is spilled and they know what they are dealing with, not sure if you would be this lucky.

Not trying to make this out to be an end-of-the-world event but we all know how the news media is and how bad they like to make things sound for ratings, this could sound very, very bad on tv.

Imagine after all of this, what people would think about your company after you caused all of this to happen by hauling hazardous waste illegally, do you really think they want you on their property now? ? ?

Just some things to think about when you hear or read about people telling you to just haul away the wash water, they are not the people I want to be listening to as they not only have no clue but could be setting you up for a huge failure as they obviously don't have your best interest in mind.
 
Here is an example of how things happen when they know what is spilled: http://www.caller.com/news/2012/aug/02/oil-field-waste-spill-lingers-near-san-diego/

This was only drilling mud that was spilled, only about 40 gallons but the company kept running out of money to pay the cleanup crew, this is a trucking company that is spending thousands of dollars for a cleanup on something that was known, had proper paperwork, manifest, proper truck, container, CDL with Hazmat endorsement, etc..... This was not some contractor hauling hazardous waste in a tank to just get the job done.

The truck driver got a fine for illegally dumping, does not say how much the ticket was but was smaller than what it could have been if it was someone without the proper license, truck, etc.....

Just trying to show you guys out there that are listening to people telling you to haul away the wash water that fines do and will happen, especially when you are not hauling legally like the pro's out there are doing, your fines will be a lot larger.
 
Ron Musgraves said:
While your out here stop by Tony's and we can find a Garage and show you how to clean one properly.
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See this is where you get crossed up Ron. Why in the world would I want to go to a garage in Vegas learn how to clean a garage from either you or Tony? Neither one of you yourselves have ever clean a garage. So now your the parking cleaning experts as well? Is that what this is all about?

I already tried going thru Tony about sludge and parking garages FYI and here is part of his response"

" I have never cleaned a garage, and don't plan to".

Give me something better then promoting guys who never even did this type cleaning. This is in line with a conversation with you and some others yrs ago about guys teaching "how to powerwash buildings, do wood restoration" and they themselves have been cleaning for less then a yr.

So you want me to learn from you two on how to clean a garage and 1 of you have never done a parking garage and never plans to.

18yrs of owning a Powerwashing business the last thing I'm looking for is guys to teach me to do anything that I've been doing a few yrs now and they have never even done one.. Give me something better then that please.
 
Russ Spence said:
Nigel, my bad!

We know exactly who was the culprit and NO I never let your good name cross my mind.

Its all old news anyway and they guilty parties are but a distant memory as I dont think they post here any longer anyway.

Sorry for any confusion, I have nothing but respect for you!
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Hey Russ a couple of people told me this story when we were going to Maryland to do some Apartments. I was going to stop by the store and say hello to them, but Hurricane Sandy was coming and we had to beat it back to North Cacalacky.
 
Clean County PW said:
See this is where you get crossed up Ron. Why in the world would I want to go to a garage in Vegas learn how to clean a garage from either you or Tony? Neither one of you yourselves have ever clean a garage. So now your the parking cleaning experts as well? Is that what this is all about?

I already tried going thru Tony about sludge and parking garages FYI and here is part of his response"

" I have never cleaned a garage, and don't plan to".

Give me something better then promoting guys who never even did this type cleaning. This is in line with a conversation with you and some others yrs ago about guys teaching "how to powerwash buildings, do wood restoration" and they themselves have been cleaning for less then a yr.

So you want me to learn from you two on how to clean a garage and 1 of you have never done a parking garage and never plans to.

18yrs of owning a Powerwashing business the last thing I'm looking for is guys to teach me to do anything that I've been doing a few yrs now and they have never even done one.. Give me something better then that please.
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We do them, not as often as you John but we do them. I had the pleasure of utilizing the info I found on here and info that I got from Scott Stone in a meeting with engineers and maintenance guys, I was given the job because they said we were the first company in over 3 years to answer all of their questions and concerns on environmental issues, compliance and our best management practice for cleaning the garage.

I guess my point is my brother in washing, why sweat the small stuff? You guys have been going at it for the last couple of years. Your all getting worked up over the same old stuff, over and over and over. I have devoted pretty much the last year to making changes where I live and how I work and we tripled our business this year over last year. Life is good! Go live it!
 
Guy Blackmon said:
Hey Russ a couple of people told me this story when we were going to Maryland to do some Apartments. I was going to stop by the store and say hello to them, but Hurricane Sandy was coming and we had to beat it back to North Cacalacky.
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Funny, the rumors live! lol
 
Russ Spence said:
We do them, not as often as you John but we do them. I had the pleasure of utilizing the info I found on here and info that I got from Scott Stone in a meeting with engineers and maintenance guys, I was given the job because they said we were the first company in over 3 years to answer all of their questions and concerns on environmental issues, compliance and our best management practice for cleaning the garage.

I guess my point is my brother in washing, why sweat the small stuff? You guys have been going at it for the last couple of years. Your all getting worked up over the same old stuff, over and over and over. I have devoted pretty much the last year to making changes where I live and how I work and we tripled our business this year over last year. Life is good! Go live it!
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Yea buddy.

As far as EPA Enforcement is concerned, I have been through a handful of site visits by Waste Water Management in the Bay Area this past summer. My set up is nothing fancy but in all instances we have been giving the "green light" to proceed with our projects.

Bring it......
 

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Chris C, I understand your point, I dont want to transport any water whats so ever if possible clean or soiled.

I have to say I do not fully understand all of the issues that Huston contractors experienced.

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Appreciated Russ S for the clarification. Congrats on increasing business, what changes are you attempting to make in your area?


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Guy B, I would venture to say if it is a closed to any body of water of the US, and if it is utilized within its designed parameters then there is no infringement.


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Carlos G,

In what situation do you have to use your vacuum system?

What is your local AHJ opinion on the ownership of wash water that is used and picked up by wash operation ?

Where does your local AHJ recommend that you dispose of the picked up wash water?

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Ron M, in a garage pressure wash cleaning that is performed more frequent will most likely produce less sediment during cleanup, nevertheless how is the wash water and sediment managed?

I will look up the phone numbers for the fuel station in the video and get them to you.
 
810f250 said:
Chris C, I understand your point, I dont want to transport any water whats so ever if possible clean or soiled.

I have to say I do not fully understand all of the issues that Huston contractors experienced.

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Appreciated Russ S for the clarification. Congrats on increasing business, what changes are you attempting to make in your area?


----------------------------------------------------------------------------------------------------------------------------------------

Guy B, I would venture to say if it is a closed to any body of water of the US, and if it is utilized within its designed parameters then there is no infringement.


-------------------------------------------------------------------------------------------------------------------------------------------------------

Carlos G,

In what situation do you have to use your vacuum system?

What is your local AHJ opinion on the ownership of wash water that is used and picked up by wash operation ?

Where does your local AHJ recommend that you dispose of the picked up wash water?

----------------------------------------------------------------------------------------------------------------------

Ron M, in a garage pressure wash cleaning that is performed more frequent will most likely produce less sediment during cleanup, nevertheless how is the wash water and sediment managed?

I will look up the phone numbers for the fuel station in the video and get them to you.
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Nigel....how ya doing man?

I use the vacumn in any situation where there is more than likely chance that the waste water will either:

1. Go off site
2. Enter a storm drain

As far as the ownership of the water...never came up nor was discussed.

Waster water recommendation for discharge has come from 2 difference counties and they all said the same:

1. Landscape
2. Sewer Drain (see video) - I think you have seen this vid before Nigel. We are discharging in a sanitary sewer onsite.
3. Janitors closest.

On the landscape part there is a ratio of how much waste water per acre is allowed in the landscaped area. The recommendation is 1,000 gallons per month per acre, and not puddle up the water so that when it rains it will wash off the property. Make sure the waste water does not reach the ground water supply.

 
Russ Spence said:
We do them, not as often as you John but we do them. I had the pleasure of utilizing the info I found on here and info that I got from Scott Stone in a meeting with engineers and maintenance guys, I was given the job because they said we were the first company in over 3 years to answer all of their questions and concerns on environmental issues, compliance and our best management practice for cleaning the garage.

I guess my point is my brother in washing, why sweat the small stuff? You guys have been going at it for the last couple of years. Your all getting worked up over the same old stuff, over and over and over. I have devoted pretty much the last year to making changes where I live and how I work and we tripled our business this year over last year. Life is good! Go live it!
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Right on bro. "It's the close loop" as in conversation that goes round and round and round.. & never ends. Will all be retired and it will still be going round & round..

Congrats on you making the right decision and watching your business grow because of it. I like the bb's but nothing like getting things done by actually doing them.. No wonder why your business tripled--great advice!!
 
Christopher said:
Something to think about: No matter who tells you to haul away wash water, you should not do it UNLESS you are a LICENSED WASTE HAULER with the D.O.T. approved vehicle, D.O.T. approved tank, CDL with Hazmat endorsement, MSDS of what is in the tank (of the detergents, contaminants, wash water, etc.....), Proper Paperwork, etc........

It is easy for anyone to tell you to haul away wash water but what they have no clue about is the potential fines you will get if caught, or in an accident, someone tells on you or any other type of situation that the D.O.T. officers, State Police, or State Troopers get involved and start asking questions. This is where you can get a fine large enough to put you out of business and/or vehicle impounded or put out of service until you have a licensed waste hauler come and vacuum out your tank and haul it away properly after you give him the msds of what is in the tank and proper paperwork (manifest) so he can do his job the right way, legally.
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Chris, isn't this why the "Pumper Truck Companies" were all up in the Houston meetings?
 
By the way thee is a waste water disposal company that will sit on site here for $85 an hour, they will capture, remove and be responsible for all goop that comes from washing, they have huge vac trucks with 1500 gallon tanks, for 85 bucks an hour they also get all permits and have hasmat license's and proper paper work needed to do the job right. Usually they do the recapture from hydroblasters in shipyards and stuff like that but if you call a week in advance you can book them for however long needed.

Just my 2 cents but that is peace of mind, however, I am sure someone somewhere will find something to disagree with that too! LOL

I have not used them but I know some that have and I visited the job site while they were there and they do a fantastic job
 
Ron Musgraves said:
Steven here is the truth and the most Common Practice on the EPA own Website EPA SITE
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Ron:

Did it never dawn on you why that is posted in EPA Region 6! Region 6 Headquarters are in the Dallas/Fort Worth Metroplex. That was posted after the July 17, 1995 Environmental Meeting that I held and is 80% based on the BMPs that I handed out at the Environmental Conference with about 40 AHJs present.

EPA Region 6 was at the meeting and received a copy. After that I managed to get the Model Cosmetic Cleaning Ordinance Posted on the Federal EPA Website.

Michael and I made a trip to the EPA's Region 6 Headquarters to meet with the Regional Director of EPA. Region 6. It was successful meeting and fruitful.

While that statement of "No Off Property Discharge" does not come under the Jurisdiction of the Federal EPA it may come under the Jurisdiction of the Local Authorities. Their reasoning is this: The contaminates from your power washing may be washed off property during a rain even so they have authority. Kansas City is a good example of this and is one of several jurisdictions that enforce this.

Off Property Discharge can be: Surface Runoff, Ground Water Contamination, and Air Contamination. I have represented Contract Cleaners for all three of these to AHJs as PWNA Environmental Chairman.

I find it humorous that you have your crews carry around 80% of what I handed out.
 
Robert Hinderliter said:
Ron:

Did it never dawn on you why that is posted in EPA Region 6! Region 6 Headquarters are in the Dallas/Fort Worth Metroplex. That was posted after the July 17, 1995 Environmental Meeting that I held and is 80% based on the BMPs that I handed out at the Environmental Conference with about 40 AHJs present.

EPA Region 6 was at the meeting and received a copy. After that I managed to get the Model Cosmetic Cleaning Ordinance Posted on the Federal EPA Website.

Michael and I made a trip to the EPA's Region 6 Headquarters to meet with the Regional Director of EPA. Region 6. It was successful meeting and fruitful.

While that statement of "No Off Property Discharge" does not come under the Jurisdiction of the Federal EPA it may come under the Jurisdiction of the Local Authorities. Their reasoning is this: The contaminates from your power washing may be washed off property during a rain even so they have authority. Kansas City is a good example of this and is one of several jurisdictions that enforce this.

Off Property Discharge can be: Surface Runoff, Ground Water Contamination, and Air Contamination. I have represented Contract Cleaners for all three of these to AHJs as PWNA Environmental Chairman.

I find it humorous that you have your crews carry around 80% of what I handed out.
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Well Robert I know where all material is referenced from. Glad you handed it to them 95, been using it prior to 95.
By the way Phx bmps have been in place prior to 96



Text me anytime for question 480-522-5227
 
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