Robert Hinderliter
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Posts posted by Robert Hinderliter
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I have a question with respect to run off. The reason that I bring this up and maybe this is not the correct section, but it certainly applies to AHJ's with respect to these BMP's that we talk about.Many states, counties, cities and municipalities apply Salt Brine prior to snow storms as a way of "preventing" snow from icing onto road surfaces with the snow. When these brine trucks go out with their 2500 gallon tanks and run all over applying this to the roadways, at some point, this is going to end up going down the drain into the storm drains which lead back into the waterways of the states, counties, cities and municiaplities. Over a state, I would imagine that millions of gallons of this stuff is applied.
How can an AHJ who applies this highly corrosive substance in mass quantities with Zero run off control to the roadways and eventually the waterways claim that a power washer is causing harm?? How can they enforce against someone what they are in direct violation of themselves?? This seems like what is good for the goose needs to be good for the gander. If not how can one take these people seriously??
I am sorry but politics are not always "Reasonable, Rational, or Reasonable". The salt you are talking about is under debate presently because of the reasons you stated.
There are special exemptions for what you are talking about right along with Fire Department Water.
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Intro:I have recently joined the PWNA and I have accepted a position to be part of its Environmental Committee. For those that know me (810F250 forums id), my initial industry focus is/was pressure cleaning equipment and systems, the last two years focusing on existing wash water requirements within my immediate areas of Maryland, along with industry wash water disposal/capture and pre-treatment technologies . Unfortunately I am unable to say I know the entire history of the PWNA or every detailed aspect of these bmp's, however I am offering my input as power wash service provider, PWNA member; I am open to learning, my hope is to make a valuable contribution.
BMP comments:(Reviewing post 1 to 3 )
Cosmetic cleaning defined on page 2 of the CITY OF FORT WORTH ENVIRONMENT CODE CHAPTER 12.5 ARTICLE III - STORMWATER PROTECTION document http://water.epa.gov/polwaste/nps/upload/nps-ordinanceuments-fort-worth-sw.pdf
Cosmetic cleaning means cleaning done for cosmetic purposes. It does
not include industrial cleaning, cleaning associated with manufacturing
activities, hazardous or toxic waste cleaning, or any cleaning otherwise
regulated under federal, state, or local laws.
From Code of Federal Regulations (CFR) 122.2 Definitions: Process wastewater means any water which, during manufacturing or processing, comes into direct contact with or results from the production or use of any raw material, intermediate product, finished product, byproduct, or waste product.
Some contractors have an issue with the term "Cosmetic Cleaning" and believe the term "Cosmetic Cleaning" does not holistically (or adequately) reflect our power washing/pressure cleaning service offering, lets discuss this, what could be recommended.
The link listed in the pics Robert H " http://www.epa.gov/nps/ordinance/documents/forthworthsw.pdf " does not work , however there is this related page Model Ordinances to Prevent and Control Nonpoint Source Pollution | Polluted Runoff | US EPA (updated 10/17/2012)
I found this older pictured PWNA/***** BMP document on the web here BMP-Cosmetic-Cleaning dated 8/3/2011; reading the bottom of page 3 to the top of page 4 , it identifies filtering through a 20 mesh (which is approximately 841 microns, according to US Forestry mesh to micron web page : the current PWNA document under review mentions 200 mesh which is 74 microns. I also remember some of the older videos with the vacuum sludge filtering system, mentioning 200 micron for pre-treatment discharge to sanitary. With all this info out there , which is the requirement?
The Model Ordinance has been moved to http://water.epa.gov/polwaste/nps/upload/nps-ordinanceuments-fort-worth-sw.pdf
Ordinance states:
Storm sewer entranceswhichwillreceivethewashwater shall be screened to catch leaves and other debris. Wash water discharge shall comply with Section 12.5302(b)(15) <in the model ordinance>
Supplemental document says:
The City of Fort Worth Department of Environmental Management recommends screening the storm drain inlet with a 20 mesh or finer screen to catch the debris.
at another place it says:
Environmental Management recommends discharging through a 400 micron filter to remove the grit and sludge.
That's probably because I always did not give the same answer when asked during development.
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The only exception to the above that I am aware of would be if you are washing directly into a sand trap, grit trap, or grease trap which are designed to discharge into the sanitary sewer system.
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PWNA is asking for professional comments, suggestions, corrections, or questions to our Cosmetic Cleaning BMPs which will be revised in about 90 days 120 days when we run out of present inventory of DVD/CD. I will post them in small topic groups allowing about 24 hours for professional comments. The compete series is posted on pwna.org at Environmental Guidelines | The PWNA
Thank you for everyones input.
Vendors are welcome to respond to this page and list their products or services. Please include quotes above your information.
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I'm going to trade both Ford Focus for two more ford Focus. Then drive the around put a ton of miles on them.I didn’t think that a Ford Focus was a Millionaires’ car?
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You might want to go to this link and read what is happening and the time schedule
Planning is Key to MS4 Success As Phase II Deadline Nears | stormh2o.com
Most Municipalities are in their 2nd 5-year plan and our industry is targeted! Just a hint to the wise.
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If you are going to be recognized by the Regulators you need to represent a National Non-Profit Organization.
When I founded PWNA it was the result of advice from Regulators who told me that regulations were being written by the National CarWash Association and the Liquid Waste Haulers for our trade! And these organization would create BMPs and ordinances that would benefit their revenue stream, not ours.
I am retired now working for Michael Hinderliter in sales Monday through Thursday.
If you young people do not support your national trade associations guess who is going to write the rules for you to follow?
Not you!
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Because of production expense, 1/2" will do both jobs. Coils are about 175' long and that creates a lot of pressure loss. The cost savings is not that great after you have make two sizes. Smaller Coils are found in light duty Dixie Cup Machines.
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Normally 8 GPM and below you use 3/8" high pressure hose, 9" GPM and above you use 1/2" high pressure hose. Using these sizes you lose about 1 psi per foot. The actual loss depends on how many elbows you have and how straight is the hose (is it off the hose reel in a straight line). Also type of rubber or synthic material the hose is made of effects the pressure loss. Synthetic hose link Synflex 3R80-06 has the least resistance that I have measured. It was popular hose before manufacturers started making hose specifically designed for pressure washers. Above about 220F the inter lining would start melting and the ends would blow off. If you were watching for this failure you could actually watch the end start to slide off the hose before it blew off. The hose was designed for Hydraulic Fluid.
The longest length of 3R80-06 that I ever ran was slightly over 1,000 Feet to clean Miller Brewery Tanks for making Beer. They were about 10' in diameter X 125' long, stacked 3 high. It was a Union Shop, so all I did was run the equipment while Union Steel Workers did the work.
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I recommend that every member of PWNA OR ***** that would like a copy of the BMPs place their order with Association Headquarters: 1-copy for $20.00, 2-copies for $35.00 including shipping & handling. That is an extra copy for your local regulator.
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The Texas School will cover all of tbe options, wait until after hands on training before making your purchase decisions. That way you will be an informed buyer.
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There is another Play Maker making a presentation to their State EPA.
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There is game changing technology being tested in a major american city that we need to be a part of. I suggest that information be released only to a local contractor who is a member of the associations. It will be a major competitive advantage for someone during the test period. I'll need advice from both Persidents on how to proceed.
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The Trade Show is 2-Days plus an evenimg reception and Trainining and Certification Courses are 5-Days which is the main focus, not the Trade Show.
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At this time it is obvious that everyone should be able to work with their local munipalities as Eric Flynn did. After you study the BMPs as Eric did, the only help you should need is Telephone support for modifying for your local jurisdiction.
The jurisdictions would rather deal with a local contractor presenting a National Association's BMPs. The only reason everone cannot do this is because they have not done their homework. Are you going to lead or follow?
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Feed back from the Regulators is that for the Industry to have maximum effectiveness is for everyone to post BMPs on their websites and abide by them. This shows knowledge and intent.
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Lots of strong interest at StormCon; More than in past years. My recommendation now is for every contract cleaner to modify the BMPs for his area and post them on his website.
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Summary:
1. The concerns around environmental issues have become very clouded by conspiracy theories and constant misinterpretation of what has taken place. Everyone is entitled to an opinion but if you really are concerned then do the home work to reach an honest and independent decision. Don’t let hearsay be the guide to more misinformation and making a wrong decision that has the potential to seriously cause a negative impact to your business.
2. BMP’s do not create law. As the name suggest, they are best management practices. Municipalities, Contractors or any authority that has influence on how to recovery or even not recover needs to decide what to take from them and what not to take from them. There are many factors that will affect this: 1) There immediate area Urban or Rural; 2) The area of the country plains, coastal or mountain; 3) What kind of discharge limits does the EPA require the city to comply with. That is the Cities have to answer to the EPA or State for discharges of their storm drains to the “waters of the state”; 4)etc – I am sure you have more to add.
3. The BMP’s are recommendation
4. Contractors should get involve at the municipal or state level to help influence what will happen in their areas.
5. Municipalities are not looking to regulate our industry. They are being force to do so by the clean water act. If we as an industry sit back without offering solutions then we are at their mercy. And no offense to regulators; but it is not their job to find solution but to enforce the law. If we are not finding solutions for our industry then they will or simply outlawed mobile power washing.
Simply put many of the major municipalities already have regulations / ordinances in place. It is interesting to see so much focus and concern over the issue so many years after it first raised it ugly head. I hope that it continues and we as an industry can continue to find new and improved ways to protect the environment and the future of our industry.
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False Accusations:
False Accusations has been part of the job of being an environmentalist and leader in the Cosmetic Cleaning Industry, most false accusations are for competitive reasons. I would like to share a few humorous examples.
The EPA called the City of Fort Worth because they were getting a large number of accusations about me and my company. The EPA told me that the City Of Fort Worth responded by saying that if Hinderliter was doing that they would eat their shorts! (How is your reputation?)
The City of Fort Worth was getting a large number of calls from other Regulation Agencies about Cosmetic Cleaning. When I asked why they explained “Because of you and all of your activity”.
The State of Texas Department of Natural Resources monitored my location for several weeks because of all of the complaints they were getting about me. After which the Agent that was charge with doing the investigation came into my office and introduced himself. He said that he did not normally come in and introduced himself, but in my case he made an exception because it was obvious that everything I was accused was false and was making a good faith environmental effort do everything correctly. And that it was also unfortunate that leaders generally attracted these kinds of accusations. As he said “it goes with the territory”.
George at StormCon thinks this is funny and enjoys teasing me about it; in front of more people the better. It’s been an ongoing joke for several years, especially my request for a speaking time slot.
I have gotten use to these kinds of attacks, and do not pay much attention to them. Others are more upset than me. Since most of these attacks come from a very small group of people I tend to ignore them. However, I have been requested to start responding and defending myself, I have depended on others to do this in the past because it has more validity. But as with everything else I can change to coincide with today’s environment and request.
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Byline: Lisa Patterson
Robert Hinderliter is known in the field of power washing as president and founder of Rahsco Mfg. Co. now PowerWash.com Hinderliter is a veritable force in the industry. But his work behind the scenes to regulate and streamline authority is largely unknown. Hinderliter worked for years to make sure, across the board, the standards and enforcements for power washers was universal. He still works to prefect the system today by being a watchdog in the power washing community. He ensures that power washers are not shutdown based on loose standards and haphazard chains of command. Since 1995 he has posted a website resource for Regulators, which resulted in a lot of references to PWNA and himself as Environmental Chairman of PWNA.
In September of 1992, Hinderliter founded Power Washers of North America (PWNA) to address cosmetic cleaning environmental issues. The group has become a “clear voice” in an industry of gray regulations along with United Association of Contract Cleaners (*****, which Hinderliter also founded). According to their website, with a stroke of a pen a law can be passed that puts a power washing contractor out of business. It goes on to say, a lawmaker, without the knowledge and understanding of the importance of the contract cleaner, can make an uneducated decision that can put a power washing company out of business and increase pollutants in the Storm Drains because of a lack of cleaning. Hinderliter, through his work with PWNA and ***** as Environmental Chairman, represents every power washing business and “communicates to the world that power washing is a vital part of the community.”
So for many power washers one question remains, why would the Environmental Protection Agency (EPA) set standards without consulting the experts in the field? This was a question Hinderliter asked before he started offering and holding seminars for power washers, business owners and regulators. By using industry leaders to educate the outside world it allowed the power washing community more control of their practices. In 2006 two seminars were held in San Antonio, TX. The first seminar that was for regulators resulted in the development of the city’s Best Management Practices (BMPs). The second seminar was held for business owners along the River walk and contract cleaners in San Antonio to explain the BMPs. It just seems clear that the people who should be helping to steer this planning should be the experts. By having direct communication with the 2 groups, business owners and regulators (Storm Drain and Sanitary Sewer Departments), the implementation of such plans are smooth and organized.
But not every city in EPA region 6 is eager to adopt such practices. This hesitation isn't because of need or because of efficient practices already in place. It would seem to Hinderliter, from his years of diligently trying to educate regarding better practices, it's the city's lack of organization that limits their effectiveness for better pollution control. This disarray not only brings harm to the environment but also cause the city’s economy to dwindle. Hinderliter was instrumental in getting the EPA standards set for power washing regulations. EPA's Region 6 office reflects Hinderliter's perseverance and determination. Although cities are receptive to such seminars, Hinderliter has to take copious amounts of time to meet with the designated officials and get these seminars underway.
One such city that has not been receptive to this planning is Houston TX. Efforts in Houston, TX are taking some time considering they have three departments handling enforcement. These departments are: the Public Works Department; Storm Water Enforcement Group which enforces municipal code; the Health Department which also enforces municipal codes; and the Houston Police Department; Major Offenders Division (under Officer Stephen Dicker) enforces Texas & US Ordinances with criminal prosecution. These three departments do not work as a cohesive team. So there is no real guideline in place for enforcement. In fact, calls to 311 non-emergency number (verses 911 emergency number) are routed to one of the three departments randomly for cosmetic cleaning complaints. Depending on which department shows up to handle the complaints will determine how you are going to be treated; “Education and Compliance” or “Criminal Prosecution”. As stated by Officer Dicker, “in criminal law there are no allowances for warnings written into the law.” So if the police department showed up citations are being issued. This caused many power washers to pull their operation out of the City of Houston, which resulted in cleaning not being done and pollutants being washed into the Storm Drains during the next rain event.
Hinderliter's efforts in Houston began in 2005 when he was in contact with Lanice Blue, Environmental Investigator II. At the time there were seven contract cleaners that held Class C permits for waste water transportation. Moving on to 2007 after a successful round of seminars in San Antonio TX in 2006, Hinderliter had several contacts with Houston TX including: Amy Boyers, Senior Environmental Planner; Naomi Marcias, Environmental Investigator; Sylvia Brumlow, Community Liaison, HPD; Dorene Hancock, Supervisor Stormwater Enforcement; Nancy Sullins; Almika Millage, Department of Health and Human Services. Through these contacts he was under the impression he was going to do Environmental Workshops for Houston TX similar to the ones he had just done for San Antonio. According to Hinderliter, “There was a lot of conversation along that line then Houston just stopped talking to me without any explanation.”
Hinderliter found this silence to be unprovoked considering that during the process of negotiations with Houston, TX he did a seminar for EPA region 6 explaining the effects of heavy enforcement vs voluntary compliance with ordinance being reasonable, rational, and logical. After the presentation he had a group of panelists from various municipalities come up to answer questions about their ordinances and the effect they were having. Dorene Hancock represented Houston and explained their enforcement efforts and asked him to return the following year to emphasize the demonstration of BMPs. According to Hinderliter, Dorene Hancock was “easy to work with, being reasonable, rational, and logical.” He worked with her on two MS4 Conferences for Region 6.
So what has caused this silence in an area that seems desperately in need of structure. Hinderliter feels that part of the problem is “jealousy” between regulators and departments within the city of Houston. Hinderliter sees egos getting in the way of efficiency. Also it's a major case of departments being uneducated in needed practices. Because each department works autonomously from one another there is no protocol to handle waste coming from another department. An obvious example of that is the Storm Water Enforcement and the Sanitation Department. Storm Water Department claim they do not want the runoff in their drains while Sanitary Sewer Department claims they can't handle the waste since it is composed of chemicals they are not accustomed to sanitizing and only allow 3 discharge points in the City of Houston; which increases the cost of cleaning because of transportation cost. Because of the deflecting of authority and the over use of one department as the official criminal enforcer there is a breakdown of the city’s economic flow and a negative effect on pollution control. As Hinderliter pointed out, based on EPA reports, a city such as Fort Worth, TX who has an ordinance in place that is rational, reasonable, logical and depend on voluntary compliance has the same level of contaminates in Storm Drains as Houston who has over enforcement. The problem, as Hinderliter would argue, is not the amount of enforcement but the lack of a structured plan where all departments work together to enforce a set BMPs that are reasonable, rational, and logical. Hinderliter feels that Houston, TX understands this because of their attendance at the EPA Region 6 MS4 Conference where he presented this information with Houston in attendance and Dorene Hancock serving on a panel at the end of the presentation.
The key to success with the seminars that Hinderliter offers is that all parties involved attend; Storm Water Department, Sanitary Sewer Department, and Contract Cleaners. This way the BMPs can be demonstrated and molded for efficiency. But Hinderliter continues on in Houston to meet with the departments that did not attend. But it’s been a struggle. Houston, TX has been the only municipality to ignore the Industrial Trade Associations input & most Open Records Requests. Although based on emails sent to Hinderliter, it wasn’t a matter of ignoring rather a matter of departments relinquishing the responsibility to other departments. But Hinderliter feels it is stalling which is only causing the city to become more polluted and unclean.
He has had tremendous success with other areas of EPA Region 6 which services, Arkansas, Louisiana, New Mexico, Oklahoma and Texas. Hinderliter's unfailing commitment to his industry has allowed power washers to continue working and business's to continue growing based on curb appeal and this allows the city's economy to grow as well. Houston, TX has had three Power Washing Workshops sponsored by the Police Department, one in 2007 and two in 2011. These seminars were recorded and are online for free viewing. But more work is needed.
Hinderliter will continue on in his efforts but encourages the power washers in the industry to be a “voice”. He encourages the power washers, business owners and regulators to support PWNA and *****. As the PWNA website extols, every business of every size, from 1 to 10,000, needs to be one of the many voices of the PWNA. The more members we have, the stronger and clearer our voice becomes. The stronger and clearer our voice is, the more protected and secure our businesses are. Become a part of that voice and protect the investment of time and money that you have put into your business.
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To answer some more questions:
Most of the questions are because people have not read or studied the Model Ordinance, Model BMPs, or Model Workshop which has been made available to everyone. Eric Flynn had no problem after studying the material in making a presentation to Galveston County, which was very well accepted with a lot of information that they needed.
I am going to answer questions that you may have after studying the material that are not obvious.
Why do the municipalities need this information: NPDES Phase I and Phase II MS4 Permits require the municipalities to develop and implement Cosmetic Cleaning BMPs with measureable goals. For the Cosmetic Cleaning Industry these parameters are: Fats, Oils, Greases (FOG), and Detergents in the MS4s. Phase II Permits are in 5-year plans, this issue has to be addresses in the second 5-year plan if it was not addressed in the first 5-year plan. There was some lenience when the 5-years plans started, most municipalities’ are in their second 5-year plan. Galveston County is in their first 5-year plan in year 4, which called for these BMPs before the end of August, 2011.
These 5-year plans are not a cookie cuter, which is they all do not have to be the same. The municipalities have to submit their plans for EPA approval, which include measureable goals for reporting purposes. Each municipality can do the necessary items in the order and style that comply with their particular situation. Galveston County chose the first 5-year plan year Number 4 to address our industry. This is addresses in most 5-year plans in the second 5-year plan. This means that is going to be like pop-corn going off all over the county for the next 5 to 10 years.
Why consult a National Non-profit Trade Association: I do have any documentation on this but I have been told many times by regulators that they could take comment from me as a representative of a National Non-Profit Trade Association but could not accept any comments from me for changes as a private business owner. In over 20 years there has never been an exception. Galveston County reached out to the two National Non-Profit Trade Associations for advice, and when Eric made his presentation it was as a representative of *****. After Eric studied the material he asked if he could change it to fit Galveston County needs. I informed Eric that was the purpose of the Model BMPs, as there was too much material for one person to develop on their own. If a local member of either ***** or PWNA was not available and willing to make the presentation than I would have had to go.
Because of this protocol it part of National Non-Profit Trade Association responsibility to fulfill this need. This was explained to me by an EPA Regulator who mentored me about the political requirements of how regulations were developed. As a result this training from an EPA Regulator PWNA was born after CEMA refused to admit Contract Cleaners into their membership.
NPDES Requirements, Public Outreach and Education: Part of the NPDES Permit Requirements is for Public Outreach and Education; this means when ever a municipality furnishes a speaker or consultant at any function or personal advice they are filling part of their NPDES Requirements. The purpose of this is not to educate the speaker, but to educate the audience in their BMPs and how they interpret the CWA. This is not a “Public Comment Period”.
The Model BMPs do not promote Sales of Expensive Equipment: In most cases the Model BMPs can be complied with for less that $200.00 if the Contract Cleaner chooses. There are provisions for complete reclaim and remediation systems if the contract cleaner chooses for competitive reasons. Statements otherwise are made by individuals who have not studied the materials.
Discharges that do not reach the “Waters of the State” are not under the Requirements of a NPDES Permit: Discharges that do not reach “waters of the State” are not a violation of the CWA. There are a very few exception of this that are regional. It would take way too much time to explain rare exceptions here that apply to only a few like the Kansas City Area.
Municipalities that already have their BMPs in place are only concerned with their reportable contaminates in their MS4s: If the FOGs and Detergents are above target limits on their annual NPDES Reports to the EPA then the Municipalities will have to reexamine their enforcement, Illicit Discharge Detection and Elimination (IDDE) procedures, and their BMPs. At this time they may look at National Non-Profit Trade Associations for advice on what is working in other areas but are more likely to look at other municipalities for advice. EPA Region 6 has a formal procedure for this in their MS4 conferences. I have had one instance where the EPA required a municipality to open up their Sanitary Sewer System to discharges from Cosmetic Cleaners to reduce contaminates in their MS4s.
The Term Cosmetic Cleaners: This term was created by me back in 1995 when the need arose for a term to describe our industry. The City Attorney of Fort Worth and the EPA put it into legalize. It is now in a lot of regulations and ordinances with the legal description. You are welcome to change if you like, but with it acceptance and usage now in a lot of ordinances and BMPs, I believe is would be a waste of energy that could be better spent on other items.
Hot Water and Detergents are emulsifiers: This was in a letter I received from the EPA for corrections to my presentation. I looked for it but could not find it after about 20 years. Part of my presentations to Regulators is to always ask for corrections, comments, and recommendations on anything they disagree with. Watch the MS4-08 presentation to EPA Region 6 for verification of this; I believe it is still up on youtube. Due to your request I will go back and ask for another determination letter from the EPA.
I believe all of the other answers are obvious from studying the Model Ordinance, Model BMPs, or Model Workshop. Please do not ask any more questions without studying the materials. If you do not want to study it that is fine, all I ask if for you not to make any comments about its contents if you do not know what they are.
PWNA Cosmetic Cleaning BMPs based on the EPA's Model Ordinance
in PWNA News, Events, and Information
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With the gird lock in Congress right now, it should be obvious why things happen the way they do.
You are talking about rational thinking, that is not how things generally work.