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Guy B

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Posts posted by Guy B

  1. Posted · Report reply

    All opinions are equally important and valid in a member supported Org....at least they should be.

    However, you seem to be ignoring the fact that this could not have happened without the ***** allowing it either via direct permission or by abdication of leadership on an extremely important issue....In the NCAA this is called "a loss of institutional control"....which is really really what this is all about.

    First quote is true Barry. Opinions of Members in a Member supported Org are very important, but if you're talking about "Any And All Opinions" from people that don't have a dog in the fight and or not Members, then I would have to say "No Not Really".

    No one is ignoring anything Barry, especially me. There has been quite the debate about this at the ***** forum. You see there is more at play here than you seem to think you know Barry. Loss of Institutional Control is not what this is about at all, but I don't expect you to understand or see that from your vantage point.

  2. Posted · Report reply

    You don't need to give them the power to steer the industry regulations and authority to make policy decisions and press releases.

    I'm sure for those who do not know the history, dynamics, players, facts. etc. of this can easily "arm chair quarterback" their opinion. Which is fine, it's your uneducated opinion, have at it.

    Barry, your above quote is really what this is all about.

    Good to see you.

    ---

    - Sent from my iPhone using Tapatalk

  3. Posted · Report reply

    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.

    So why did the P$na tell everyone that they were not going to shop the Model BMP around to Municipalities? So they lied?

    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. This makes perfect sense it's called "Conflict Of Interest"

    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. And the ***** was born after a conflict with the P$na.

    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”. May be not, but it should be. How they interpret the CWA...I Love That

    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. In most cases sump pump and a pool won't get it, but it's an option

    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. This would be another "How they interpret State Waters" Houston says ditches are State Waters, along with sewers, dry lakes, or any depression of land that collects water. I may be wrong but I believe they include septic systems in this also.

    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. Again makes sense. If Municipalities are above their limits the EPA could withhold Grant Monies.

    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. As BMP's evolve, as Environmental concerns evolve, so should the description of our Industry evolve. You're right, waste of time.

    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. Never said anything about Detergents, I know they're emulsifiers. I was talking about the use of hot water, yes it emulsifies, so does cold water to a certain extent.

    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. Got nothing for that one

    Thanks for clearing that up.

  4. Posted · Report reply

    Again, I have no problem with the "Meat" of the BMP's, but I do have a problem with local Regulators going "Above & Beyond", where does this end? When will it be a crime to have wash water hit the ground when washing houses or apartments? When will it be deemed illegal to sump into a "Landscaped Area"? If I have blocked a drain but by chance 10 or 20 gals seeps by, am I put in jail? Is it a $10,000 or $20,000 fine? Where will it end?

    It is my understanding that developers (In Houston) were suppose to have complied with Regulations as to regards to "Interceptors" being installed to stop off property discharge. I heard no mention of interceptors in any of the videos. Are all parking decks in Houston equipped with these now? If not are the owners of these parking decks violating the law by not being in compliance? At any time was the subject of "Interceptors" brought up in the Houston meetings?

    Why do I care about what is happening in Houston? Because it's happening in my area. This spring we were washing apartments in a small town near my main service area. I noticed a City truck cruising by a couple of times when he decided to stop. He introduced himself as a "Environmental Enforcement Tech". He explained to me that "Someone" had called and said I was discharging in the storm drain, I told him nothing could be further from the truth and to check for his self. He did and found I was Compliant. He then bragged that he had caught a couple of washers cleaning fast food joints in town, and Popped them $1000.00 a piece, then went on to explain their Towns BMP's, I explained to him that I was not aware that their Town had any Bmp's but that I was pretty sure I could recite them back to him, and was fully aware of what they were and what they meant....In a nice way. He really didn't seem impressed when I told him I was a licensed waste water operator in N.C. for the last 12 years.

    We talked about the drain and "What If" I told him that I would block it and sump the wash water to a "Landscaped Area" to which he replied "Well We Would Really Rather You Send It To A Sanitary Clean Out Drain" quite smugly. So I ask him "Does Your Waste Water Plant Know This"? His reply....No. I let him know that if he or his boss had any questions to just give me a call, didn't seem to like that either.

    Sorry Back On Topic........... I just don't see why City Officials and Contractors can't work together for the same common goal.

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  5. Posted · Edited by Guy B · Report reply

    This is a pretty simple process really. All you have to do is follow the history. Here's how it goes:

    1) Make rules and incite the municipalities to make rules where there are no rules.

    2) Offer certification classes to teach those rules.

    3) Convince the municipalities that contractors without certifications shouldn't be allowed to work.

    4) Sit back and collect all the training fees for certifying contractors so they can work.

    For reference please research "kitchen exhaust cleaning" - or "PWNA" or "Delco".

    If you think kec guys are rolling in the dough now that all the regulations are in place then by all means support the BMP's and more power to you. If the kec industry isn't booming then maybe that approach didn't work.

    You guys decide.

    Kinda looks that way doesn't it Tony. That might answer a lot of questions. Just saying.

  6. Posted · Report reply

    Let me answer some questions:

    First there is a very important Trade Show Next Week for Storm Water Regulator, it is at www.stormCon.com . Normally there is over 2,000 regulators present, do not know about this year because of the shortage of money in many jurisdictions. I have spoken several times at this event, normally I have over 100 attendees, mostly regulators but I had Wal-Mart twice.

    I did not have the time for all of the proper protocol that I should have done because of a shortage of time caused in the delay in getting approval from PWNA and ***** and getting the CD/DVD produced. I have talked to both Presidents about this, and will not happen in the future. I moved ahead because of the importance of StormCom.

    Second, the EPA’s Model Ordinance has been in effect since January 2, 1996 which has produced one of the lowest pollutants in the MS4 in the Nation at almost no cost to the Municipalities and the Contractors. It is Reasonable, Rational, and Logical; it makes sense. If you will study it you will see that all it requires is for the contractor to Pre-Clean and Filter his waste water. Filtration can be with an oil absorbent boom and a window screen around the bottom of a sump pump which directs the water to sanitary sewer. Cost less than $200.00. In the Model Work Shop you are shown how to comply with a child’s swimming pool for a drain blocker, a sump from Home Depot, and an oil absorbent boom. Does not look very professional, but it works and is legal! The contractor can decide what technology he wants to use.

    About my being a dealer, if you look at my work for the past 20 years you will see that is does not push high dollar sales of unnecessary equipment. My philosophy has been that the easier it is to comply, the higher level of compliance there will be, which in turn will give more contractors the opportunity to save the environment. Several contractors who have pushed environmental regulations after they have purchased expensive equipment want the rules to be very difficult in order to limit competition. It takes everyone involved to develop good regulations: Regulators, Manufacturers, Dealers, Contractors, and End Users (your customers). You cannot separate one from the other; it takes everyone involved to produce a good answer.

    My background: I have trained more regulators and contractors than anyone else in the nation. I know what works and what does not; have been asked to speak many times at regulatory meetings and events. I did this in order to save my business, I was forced into it. On the advice of regulators I started PWNA, again to save my business. Because of the work I did, almost every regulation today for Cosmetic Cleaning includes verbiage, and terms that I developed. I know a lot of Regulators on a personal basis.

    I presented to EPA Region 6 in 2008 the fact that Houston’s BMPs were not working; Houston was represented at the event. At the time I did not know why: but as time passed it was obvious that the reason was that cleaning was not being done as contractors left Houston because of the threat of excessive fines. There is a lot of behind the scene correspondence that will be released later.

    It is one thing to criticize, but you need to make specific suggestions for changes, corrections, or additions. The main purpose of the Model Ordinance, Model BMPs, and Model Workshop is so that local contractors can take the material and adjust it to their local situation. This has already been tested by Eric Flynn in Galveston County. Eric took the BMPs and modified them to fit his situation with very positive results. Eric was suppose to talk for 15 minutes, his information was so very informative that it lasted almost 1 ½ hours. I received several very positive comments from the regulators he spoke to. I will let Eric speak for himself on the details. Eric said that he did not have the time to develop the program, but did have the time to modify it slightly and make the presentation!

    I know the changes that Eric made and I agree with them. They will probably be incorporated into the BMPs at the next printing which will have proper approval for. You have all properly beat me over the head with that one.

    Mr. Hinderliter, your knowledge and expertise is without question, but if you would indulge me I have some questions.

    Why is it so important to "Shop" this BMP around? When I was told (Personally) by the ex-ED of the PWNA said they wouldn't. You're doing this and you know you are. What is the reason for this?

    Why are Pressure Washers "Pigeon Holed" as "Polluters" in the eyes of the Regulators you speak to and know on a personal level? Why were they Grouped together with Major Environmental Criminals that do things that we as Contractors, not to mention Human Beings would never do?

    Why did it take a small group of Contractors (that had no where near your knowledge, influence or expertise) to point out the Major Flaws and mistakes in they're targeting Pressure Washers in Houston? Why didn't Mr. Clark recognize the efforts of these Contractors in his PWNA announcement about the last Houston meeting?

    Why is what we do still categorized as "Cosmetic Cleaning"? To me (And A Lot Of Others) this is a derogatory description of the service we provide. This term degrades the service, and Industry I represent.

    Why disallow hot water? Emulsification also happens (To a smaller degree) even in cold water washing?

    I have immense respect for you Robert, and my opinions in this matter are not swayed by outside personalities. What you're saying, and what you're doing seem to be totally opposite.

  7. Posted · Report reply

    The issue is, using the *****'s name in a release promoting the BMP without the Org's permission. BMP's for every City, State & County are coming via the EPA. With or without the P#NA's or Roberts help. Again if the ***** wants to add an "Environmental Standard" I see no problem with this, but to promote this BMP that doesn't represent All of it's Members is wrong IMHO. I still have a problem with the wording attached to the Ft. Worth BMP. The meat of the BMP mirrors that of the minimum of the CWA, which I don't have a problem with.

    The P#NA has wanted for a long time to "Absorb" the Membership of the ***** they hate the *****...Why? Because the ***** stands against everything they stand for, I think you guys know this. Why did the ***** accept the BMP that the P%NA took a Butt Whipping For??? There was a reason I believe, but it's only a hunch.

    I'm sure the other Org. would love for you guys to Drop or not renew your Membership to the *****, just gives them more power. They don't need Membership dues to survive, the ***** does.....Think About It.

    Don't get me wrong, Vendors are one of the most important assets of any Org., but the most important asset is it's Members and the best interests of it's Members..... Period.

  8. Posted · Report reply

    Man, you're in a great position to start and build a business. My advice is not to start right now. Even though you are in the South, things will be winding down soon. Use this time to research and gather as much info as possible, which it looks like that's what you're doing.

    Keep It Simple!!! Whatever scope of work you choose, try to narrow it down as much as possible. Make sure you can profit from them, and make sure you have the proper equipment to "maximize your profit potential"

    Read, Read & Read some more.

    ---

    - Sent from my iPhone using Tapatalk

  10. Posted · Report reply

    Ok now it's wired. All of the lights are LED except for fender lights. Grounds for lights and brakes. All 4 wheels have brakes. 95% of the wiring is encased in flex tubing. Wiring is a "Weak Link" as far as trailers, so I wanted to do what I could to prevent problems down the road. You'll notice wires are run through metal tubing coming from the front, through the angle to the back. Then 3 pieces of metal tubing support the flex tubing across the back to the other side.

    Added an LED light strip to the back for extra visibility, I'm sure I'll be replacing this frequently.

    Bed will be put in this weekend.

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  14. Posted · Report reply

    I consider softwash under 500 psi. No pressure under 100 psi. Low pressure under 1500 psi. As measured as the tip.

    I thought you were talking about softwashing since that's the title of your topic.

    There are also people who just spray through a pump with "no pressure". They are also calling this "softwash" . The RCIA was trying to bash power washing last year and spreading fear about it in order to promote this type of cleaning.

    Wheres the like button???

    Doug, couldn't agree more. Fear mongering to sell "Soft Wash" equipment. Guess we know how that ended.

    Yep, we wash homes using under 500 psi, concrete 3000psi, wood around 1000....Knowing the difference.......Priceless

  15. Posted · Report reply

    Should be sand blasted & painted next. Went with epoxy primer and polyurethane Red PPG paint. $500.00 in primer & paint. 1 gal primer...2 gal paint. My hip pocket is hurting, and I'm not even done yet. Here's whats left to buy.

    Boards

    New roof rig (Bob)

    8 gpm cold PP (Bob)

    2...35 gal chem tanks

    1...50 gal chem tank

    sch 80..2" pvc for hydrant fill

    2" pvc valve

    2" cam locks (for fire hose)

    20 gal fuel tank

    That's just off the top of my head!

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  18. Posted · Report reply

    Wanted to post this for all of the TGS friends. I posted this on a couple of other forums for folks looking to rebuild they're trailers.

    Well got some time to start tearing down the unit I bought in Fla. last year.

    It's 5'1/2 x 12' there will be a 8 gpm hot skid up front, 8 gpm cold on the back, 4 Titan reels hanging from the rack (2 high psi, 1 roof, 1 fill) 525 gal tank, air gaped hydrant fill to tank, roof rig, 2...35gal chem tanks, 1... chem 50gal tank. Trailer brakes all the way around.

    Had my good Friend & Great American "Dale Ray" replace some angle and channel iron, re-weld a few things, and should be finished tomorrow. Then it's off to be sand blasted and painted with epoxy primer and polyurethane PPG paint.

    Kind of undecided on paint color, but it will be bright and eye catching for sure..................Any Color Suggestions??

    Also if you were building this trailer, what else would you add to it??

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  20. Posted · Report reply

    I would suggest to anyone that is starting out in pressure washing to go no lower than a 13 hp 3000 to 3500 psi, 4 gpm machine. Gallons per minute (Or liters) is more important than psi (or Bar). The more gpm (liters) the faster you move.

    Even 1 gpm more is a lot. All of our washers are 8 gpm, and wouldn't have it any other way.

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