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Environmental Law for Pressure Washers - The Clean Water Act - What the heck is it?

Tony Shelton

Environmental Consultant / Past Director
Chris, all your are doing is lying. I've asked repeatedly for to open your eyes and read what I have written. I have never in any of my post said a contractor was or is a polluter. I've used examples and said that we as people in general are polluters. If you read a little more slowly you might actually get it. I'm wasting my time explaining it like you're some kind of child, so go and educate yourself. I couldn't have been any more clearer in my posts and it is not my responsibility to hold your hand.


Still no questions?
 

Chris Chappell

New member
Chris, all your are doing is lying. I've asked repeatedly for to open your eyes and read what I have written. I have never in any of my post said a contractor was or is a polluter. I've used examples and said that we as people in general are polluters. If you read a little more slowly you might actually get it. I'm wasting my time explaining it like you're some kind of child, so go and educate yourself. I couldn't have been any more clearer in my posts and it is not my responsibility to hold your hand.

I quoted you and posted in red every post where you are calling contractors polluters, criminals or other.

Maybe you cannot read or cannot read colored words, either way the proof is right there in front of you. Again you are not seeing the proof right in front of you agin, like so many times in the past in other forums.

Other contractors see the truth also and have commented also, I guess you cannot see their posts either?

Here we are going again, the truth is there but you don't/can't see it again, like on the other forums.
 

Chris Chappell

New member
Still no questions?

He still does not want to see the truth that is right there in front of him, I quoted the posts for him to see but for some reason he cannot/does not want to see the truth that is there and I commented in red but he still does not see them. Why is that?

I think that whoever is coaching him cannot see the posts so he is just repeating that he cannot see because the person pulling his strings cannot see. Maybe he was not supposed to repeat that part? hahahahaha

Again we are going through the same nonsense that we went through over at PWI, he is acting like he cannot see the truth, is just mis-directing and bringing up or posting about stuff that has nothing to do with the CWA like you already pointed out Tony.

That same mentality sure looks like others we have seen in the past over at PWI where the truth was pointed out clear as day but they would not/could not see it even though everyone else could but good thing they are not there anymore so we don't have to deal with their nonsense either.
 

Tony Shelton

Environmental Consultant / Past Director
Chris, this isn't about Kristopher or his opinions. This is about what the law is.

The fact of the matter is, congress set out some goals to clean up our waters. The EPA was utilized to implement those goals on a federal level.

As with just about any government mandate there comes a point where they start seeing diminishing returns and have to start digging farther and farther to justify the funding for enforcement.

After years and and years of meeting goals they keep moving the goalpost.

Anyone in Los Angeles can see with their own eyes that the EPA has done a great job at cleaning up air pollution. Regulations are in place that, for the most part, were feasible and were implemented over time in a way that didn't cripple business, but still cleaned up the air.


Sadly, as with many government mandates, it sometimes reaches the point of the absurd as seen by this article:



http://www.cbsnews.com/2100-205_162-4651448.html


For farmers, this stinks: Belching and gaseous cows and hogs could start costing them money if the federal government decides to charge fees for air-polluting animals.

Farmers so far are turning their noses up at the notion, which they contend is a possible consequence of an Environmental Protection Agency report after the U.S. Supreme Court ruled in 2007 that greenhouse gases emitted by belching and flatulence amounts to air pollution.

"This is one of the most ridiculous things the federal government has tried to do," said Alabama Agriculture Commissioner Ron Sparks, an outspoken opponent of the fees.




[FONT=Helvetica, Arial, sans-serif]Gentlemen, we have been presented to regulators as the farting cow. Like the cow, any harm our industry may cause to the environment is so rare and so minuscule it is immeasurable. That is why many stormwater authority personnel haven't even heard of pressure washers. We keep hearing all these stories of contractors who have been fined, yet no one ever produces any evidence of such. Why? Because the situation where a powerwasher creates any harm to the environment is RARE. Very rare.

[/FONT]
We are at fault here because we allowed people who could benefit from stricter rules to represent us before the authorities. While other industries have had strong support for their contractors, we have, by our own laziness, sent in representatives who presented us as polluters.

We were too lazy to read the law for ourselves. We were too lazy to attend stormwater meetings and thus were blindsided when regulations were put in place that portrayed us as criminals.

[FONT=Helvetica, Arial, sans-serif]

Those days are over. Now we have a diverse group of over 40 committee members thus far who are actively working to change this false perception that has shackled our industry.
[/FONT]

[FONT=Helvetica, Arial, sans-serif]The Clean Water Act has worked and is working. The EPA has done its job from the federal to the state levels to implement regulations that have been successful in cleaning our waterways. [/FONT]

[FONT=Helvetica, Arial, sans-serif]WE, (powerwashers) are doing the job of trying to keep it that way. We are the first line of defense on the retail end. [/FONT]

[FONT=Helvetica, Arial, sans-serif]We remove trash, debris, sediment, grease, oils and other things that clog up the stormwater conveyances, put them in the landfill where they belong, and leave a clean environment to work, play, eat and live.


Without our service the "waters of the US" suffer
.

When methods that are impractical or too costly are implemented it results in a tendency for our customers to put our services off or stop cleaning completely as we saw when we were in Houston where ridiculous, cow fart type thinking and enforcement caused contractors to go out of business and retail stores and restaurants to look like third world countries.

That is not what the Clean Water Act is about. If you will read it you will find that the idea of practical solutions that aren't burdensome was the original intent of Congress when they passed the Act.

The original intent of the Law was that solutions be "practicable". That means that a solution that requires equipment that raises the cost of cleaning a garage from 5 cents a foot to 24 cents a foot is not a solution at all.

That means that a solution that leaves more debris and contaminants to wash into the waters of the US from neglect is no solution at all.
[/FONT]We are part of the solution. Any powerwasher who thinks differently does not have the heart of a cleaner and probably shouldn't be in this business.





 

Guy Blackmon

New member
Chris, all your are doing is lying. I've asked repeatedly for to open your eyes and read what I have written. I have never in any of my post said a contractor was or is a polluter. I've used examples and said that we as people in general are polluters. If you read a little more slowly you might actually get it. I'm wasting my time explaining it like you're some kind of child, so go and educate yourself. I couldn't have been any more clearer in my posts and it is not my responsibility to hold your hand.

Kris, just an observation, and I'm not in any way attacking you but........you seem to have a pattern of arguing just for the sake of argument.

Every human in the world contributes to a certain point to pollution or waste. Driving a car, buying clothes, flushing the toilet, the trash we produce, etc......but that's not what this thread is about, and you know it.

Tony just put out some good info on understanding the CWA, and then you come in and start splitting hairs. Again the CWA was at first created solely because of the unregulated discharge from Industrial & Municipal systems, and it grew from there with the environmental movement.

I won't list my qualifications on this subject (most know) but for 12 years I treated more waste water and protected my States waterways more than any other so called expert in our Industry to date........But that's just splitting hairs & has nothing to do with this thread.

Education doesn't come from copying & pasting quotes from here and there. Education comes from living it and doing it. Being new to pressure washing and or environmentalists regulations.....you have neither....again not a slight, just an observation.

Just Saying.
 

Chris Chappell

New member
Maybe we need to purge these useless posts where people call contractors polluters, criminals, keep on trying to poison this thread or just keep trying to misdirect it in other directions so it is not helping contractors.

It is obvious to many here that these actions are not helping but hurting the industry and need to be stopped, it is not a good thing to call contractors polluters, especially without any proof whatsoever.

I unfortunately am not a moderator here but maybe we need a moderator keeping an eye on these important threads to keep them in the right direction and those that want to poison it, misdirect it or accuse contractors of polluting or calling them criminals should be kept from posting in these important threads and/or get rid of those useless posts that distract, misdirect and accuse contractors from this important thread to keep it going in the right direction.

It really seems like there is an agenda here with all the accusations and misdirection that is happening here as it is not doing any good whatsoever and just poisoning the thread.

I agree with Tony's idea of helping the contractors understand the CWA as many have not really read it as it is obvious in this thread itself and posts but many contractors out there want to understand what it really is about and want to protect themselves from vendors and self-titled "industry leaders" from being taught the wrong thing, being lied to and manipulated and from buying equipment that is not needed.

Great things like this thread will help many contractors from around the country and around the world to understand the right thing to do and the truth of removing pollution when cleaning, not causing it when cleaning, there is a huge difference.

Thanks Tony!
 

Igor Zaric

UAMCC Board of Directors
Kristopher,
I recently posted some BMP's and regulation in your city where you live and work. Tony Shelton took a lot of time to go over them and we agreed that they are not bad at all. There is a lot of good information there and I suggest you to go over them.
Also, as Chris said, I highly recommend that you take Jerry's class and get certified as "pollution control specialist". That will help you understand government regulations and get you more high paying jobs. The next class is scheduled in San Diego , October 10th. We'll gladly see you there...
San Bernardino, CA
BMP's and regulations : http://www.sbcountystormwater.org/_PDF/SBC Mobile Vehicle Cleaning & Maintenance.pdf

http://www.waterboards.ca.gov/santa...rders/2010/10_036_SBC_MS4_Permit_01_29_10.pdf
 

Guy Blackmon

New member
This all goes back to our Industry being viewed as a major source of pollution by regulators.....I disagree highly with this and the people responsible for "Consulting" AHJ's that we are for the last 15+ years.

Want pictures of car wash with runoff to storm drains? I got them. Want pictures of charity car washes with runoff going to storm drains? Seen them. Want picture of fire hydrants flushing to storm drains? Got them some where.

Largest source of pollution to our water ways? Fertilizer run off from farming. Another large polluter? Fecal matter from septic systems, leaching from the ground to waterways. Did you know that fresh water fish have measurable levels of the hormone in women's birth control pills, or the antibiotics humans take?

COD? BOD? TSS? TDS? DO? etc..etc..etc.. Know what these mean and what effect they have on water quality?

Yea, educate yourself.
 

Chris Chappell

New member
Great post Guy.

Back at the refinery we had to pull samples of the tank firewalls to test for cod, tss, tds and many other things before we could drain the firewalls after a heavy rain.

It is amazing how just plain dirt with grass, insects, bugs, snakes, and wildlife living there in 2000 acres will affect the water after a rain but most of the time it passes. In the times the water did not pass, they just get a vacuum truck to vacuum out the water and take it to the waste water department of the refinery to handle it.

There is so much about the EPA and CWA that most people out there just don't know but they need to read the CWA so they have a clue and can understand what it is really about.

I agree about the people consulting with the ahj's, just to make things worse for us and to try to tighten regulations to sell more equipment that is not really needed to do the job in most cities.

People really need to read the older threads over on PWI, lots and lots of great info about the CWA, the real truth about the CWA, not what the liars and manipulators have been spreading for years to the regulators, city officials, newbies and people that have not read up on it.

Ron M. has also posted a lot of great info over there about environmentally compliant cleaning where you really don't need special tools or equipment to do most commercial jobs unlike the lies and manipulation that has been spread over the years, the worst part is that there are people still listening to those liars and manipulators and believing them without finding out what is true and what is not true.

People have been deceived, lied to, manipulated to buy non-needed equipment and had their cities lied to and manipulated for tougher regulations so that you would have to have certain equipment or have your rigs "approved by the city" or other nonsense like that to be working in a city like Houston.

When people understand the CWA, they realize how things should be and how it is easy to be compliant and not need to purchase extra machinery to do the same job they have been doing as many eyes have been opened, lies exposed and the manipulation exposed so that people can see the truth and now life is much better in Houston. Contractors are not worried about getting fined because now the city officials and regulators know the truth and understand the CWA so illegal fines are not happening hardly, you can wash and not worry about fines and other great things are happening now.

The truth about the CWA when you understand it answers a lot of questions without needing to even ask them. Common sense helps a lot also in understanding the CWA.

I hope more contractors read and participate in this great thread as it is showing the truth.
 

Tony Shelton

Environmental Consultant / Past Director
prac·ti·ca·ble
ˈpraktikəbəl/
adjective




fea·si·ble
ˈfēzəbəl/
adjective







SEC. 103 [33 U.S.C. 1253] Interstate Cooperation and Uniform Laws

(a) The Administrator shall encourage cooperative activities by the States for the prevention,
reduction, and elimination of pollution, encourage the enactment of improved and, so far as
practicable,



(l) Practicable means of treating municipal sewage, and other waterborne wastes to implement the
requirements of section 201 of this Act;


(1)(A) not later than July 1, 1977, effluent limitations for point sources, other than publicly owned
treatment works, (i) which shall require the application of the best practicable control technology


(7) to the extent practicable, the applicant has established a schedule of activities designed to
eliminate the entrance of toxic pollutants from nonindustrial sources into such treatment works;


Factors relating to the assessment of best practicable control technology currently
available to comply with subsection (b)(1) of section 301 of this Act shall include consideration of
the total cost of application of technology in relation to the effluent reduction benefits to be
achieved from such application,



From the beginning Congress authored the Act with the charge to do what we can to clean up the environment to the maximum extent practicable.

It is not practicable or feasible to rob Peter to pay Paul.

As an illustration it wouldn't be "practicable" to have each farmer force his cows to reside in a custom built enclosure with air scrubbing filtration costing hundreds of thousands of dollars to eliminate cow flatulence.

It is also not "practicable" to require pressure washers using $15k in powerwashing equipment to purchase $50k in reclaim vaccuum equipment to eliminate discharges that can easily be eliminated through inexpensive gravity filtration right on the ground.

It is not "practicable" to force contractors to double the emissions by having to use double the small engines needed to complete a job just to pick up the water.

It is not "practicable" to cause cleaning water to have to be picked up by a reclaim company tripling the cost of the cleanup and causing more emissions to transport the water.

Now that we are not longer represented to the authorities by those who stand to profit when these things are mandated, we can start the long process of showing regulators the net positive effect we, cleaners, have on the environment......in a practicable way.....as Congress intended in the Clean Water Act.
 

Chris Chappell

New member
That is a good point about having a company come and pick up the wash water.

I looked into this for a special project here where I live to show how ridiculous the cost would be to do things the way that some vendor up in north Texas told them they had to do things and to show them how it can be done legally without all that nonsense and had them call the right people to verify I was telling them the truth.

To haul away wash water would require a vacuum truck at $80.00 per hour plus an additional man in the truck (their policy of 2 guys in the truck for safety reasons) at the rate of an additional $30.00 per hour.

They are timing the job from the time they leave their yard to the time they return with a 4 hour minimum.

There is also the cost to dispose of the wash water at the rate of $0.50 per gallon, no minimum or maximum.

Then there is the truck wash out cost to clean the tank at the rate of $225.00 to be steam cleaned and sanitized and neutralized by their shop so there is no chance of cross-contamination and no possible reaction with anything else they haul later that day or week.

This is the average price of several companies that deal with waste water hauling/environmental cleanups so one is higher and one is lower than the other 2 companies.

When you do the math of a full day of cleaning concrete at 5.5gpm's for 8 hours (8 hour day but 30 minutes setup and 30 minutes teardown off the clock) minus 1 hour lunch and a couple of 15 minute breaks so 1.5 hours not washing. Let's do the math 6.5 hours washing at 5.5gpm (5.5 x 60 min x 6.5 hours) is 2535 gallons which will fit in the average vacuum truck plus you will have water absorbing into the concrete and a lot evaporating also before it reaches the lowest point of the property.

I usually work a lot more hours per day but this is just an example to show the math and ridiculousness from the info from a vendor up in north Texas.

They did not tell me who the company was and I did not ask but it was obvious that that vendor was lying to them and giving them a lot of mis-information that I proved to this company and showed them the truth and had them call some people to verify the truth and they got pissed at that vendor for lying to them and almost causing them a fortune to get a simple large job done.

So, we would have a vacuum truck on site for 8 hours but add in the 20 minute drive there and back but they deduct 30 minute lunch if they leave for lunch, if they stay there then lunch is on the clock as they will alternate between the 2 guys so one is watching the job at all times for safety reasons and company policy. So, 8 hours and 40 minutes they round up to the nearest half hour or hour) at $80 per hour and the additional guy at $30 per hour will be $110.00 per hour x 9 hours will be $990.00

Now add in the truck wash fee of $225.00

Now add in the cost of disposing the wash water at $0.50 per gallon x 2535 but let's say that a few hundred gallons absorbs and evaporates just for argument's sake, so $0.50 x 2235 gallons will be $1267.50 for disposal of the wash water.

Oops, I forgot to add in the time to drive to the disposal place which is about 30 minutes each way so that is another hour of $110.00 added to the bill, and that is no waiting hopefully, if they have to wait to dispose of the wash water, that is being charged to you, the customer.

Ok, let's look at the bill for handling and disposing of the wash water per day as this is a large concrete slab that needs to be washed but will take several days.

$ 990.00 for the vacuum truck and helper per day
$ 225.00 for the washout of the vacuum truck each day
$1267.50 for the disposal of the wash water each day
$ 110.00 for the additional time to go to and from the disposal facility each day

Total is: $2592.50 but that is not including the actual washing of the concrete, this is just to take away the wash water as recommended by the north Texas vendor, who does not even work here, has no clue of the job, has no clue of what is needed to do the job, that vendor is just regurgitating info that some idiot said or is just making up lies and other mis-information because he has no idea of the job or what it entails.

For a customer to pay this amount of money per day besides the cost to wash the concrete is going to be out of reach for a lot of customers and I would not ask them to pay that kind of money ever, that is why I talked to them about another method of dealing with the wash water that is legal and they called to check on my information and found me to be telling them the truth and actually impressed that I knew so much about this kind of thing as the other contractors did not mention any of this and when asked about the wash water they told them that they would have to look into it.

I know these numbers as I have done some of these projects on occasion and know the numbers from past experience, prices hardly ever go down, they usually go up as it is with the economy, prices usually only go up for most things.

I was able to do the concrete washing job with common sense and just brought some oil socks for added benefit but this job had no oil stains, just mold, mildew, algae and dirt so I had a vacuum and sump pump sending the non-oily wash water into the grassy area and the dirt we just shoveled into the grass with the permission of the owner so there was no big song and dance needed with this job, no hauling away wash water or other nonsense as was told to them by a north Texas vendor who did not have any clue whatsoever.

This is a perfect example of knowing the CWA (actually have read it and understand it, not just saying I did and acting like an expert afterwards), knowing what you can and cannot do and was able to do the job affordably for the customer and in their budget.

You don't need a huge investment to do the right thing most of the time in this industry but there are people out there that will lie to you and give you mis-information but it is up to you to know the truth and you will find a lot of truth here on UAMCC and over on PWI.

Thanks for what you are doing to help contractors here Tony. I hope some open their eyes and see how much you are doing for everyone and I hope that people will read the CWA so they will understand what it is about so they will not be lied to or misled as there is still a lot of that going around out there.
 

Tony Shelton

Environmental Consultant / Past Director
I'm going to start a series here doing my best to put all that legal mumbo jumbo we've seen screens and screens of into simple language that everyone except for some garage cleaners can understand.


Kristopher Pettit reported this post and said that I might have been referring to Jim Gamble.

Please allow me to revise it:

I'm going to start a series here doing my best to put all that legal mumbo jumbo we've seen screens and screens of into simple language that everyone except for some who are uneducatable, like Jim Gamble, the western environmental director for the PWNA can understand.

I hope that is more satisfactory to Mr. Pettit.
 

Doug Rucker

UAMCC Board of Directors
Kris and Tony Shelton--this thread is about the CWA and educating. Please keep the context of your private emails off here. Thanks
 

Chris Chappell

New member
I am not sure how many years ago there was an issue over in Georgia, and another city but I don't remember the cities.

Many contractors got together as the city was in a very bad drought but the contractors got together and helped out in that city, explained to them the CWA and what it really meant and talked with the city to help keep the contractors working for safety and sanitary reasons, not for other reasons which in the city's eyes would not be a good reason for cleaning.

I was not able to go there and help out but does anyone have information whether in electronic files, handouts or other information on what was said to the city so that the contractors can keep on working even in the drought?

I hate to alter the direction of this great thread but in a way it does involve the CWA as that is part of the education for the city to help keep contractors working.

If anyone has this or similar information, please post links to it or email me files or scan the brochures or handouts if possible.

This is very important information that can help contractors in many cities as not only Texas is in a serious drought but also parts of Georgia and other states.

I will start a separate thread later on here and over on PWI about this.

Thank You.
 

Guy Blackmon

New member
I am not sure how many years ago there was an issue over in Georgia, and another city but I don't remember the cities.

Many contractors got together as the city was in a very bad drought but the contractors got together and helped out in that city, explained to them the CWA and what it really meant and talked with the city to help keep the contractors working for safety and sanitary reasons, not for other reasons which in the city's eyes would not be a good reason for cleaning.

I was not able to go there and help out but does anyone have information whether in electronic files, handouts or other information on what was said to the city so that the contractors can keep on working even in the drought?

I hate to alter the direction of this great thread but in a way it does involve the CWA as that is part of the education for the city to help keep contractors working.

If anyone has this or similar information, please post links to it or email me files or scan the brochures or handouts if possible.

This is very important information that can help contractors in many cities as not only Texas is in a serious drought but also parts of Georgia and other states.

I will start a separate thread later on here and over on PWI about this.

Thank You.

That also happened in Raleigh NC probably about the same time. It really had nothing to do with the CWA but more about water restrictions hurting Contractors making a living. A group got together and worked with Officials to eliminate the problem.
 

Chris Chappell

New member
Guy, do you have any info about it or who was involved?

I might be in that situation very soon and was trying to find people that were involved and had info on what was said in the meetings.

Thanks.
 

Guy Blackmon

New member
Guy, do you have any info about it or who was involved?

I might be in that situation very soon and was trying to find people that were involved and had info on what was said in the meetings.

Thanks.

Chris, I'll do what I can...Celeste was the spearhead on that, she is probably the most knowledgeable on this subject. It was also my understanding that Contractors used "Reuse" water form the wastewater plants in the area.
 
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