PWNA Cosmetic Cleaning BMPs based on the EPA's Model Ordinance

[Robert Hinderliter 64]

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.

Edited February 15, 2013 by Robert Hinderliter

[Robert Hinderliter 64]

[Robert Hinderliter 64]

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.

[Robert Hinderliter 64]

Edited February 16, 2013 by Robert Hinderliter

[Robert Hinderliter 64]

[810F250 14]

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?

Edited February 16, 2013 by 810F250

[NJWashingGuy 31]

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??

[apsurfacesolutions 17]

Mike it's the old cliche " don't do as I do do as I say"

[John T 744]

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??

Mike we talked about this in the past and these are the type questions I would love to see answered. At our Vegas Parking Garage Event since where going to have these EPA Guys in the conference room your question would be a good one but of course does it ever really snow in Vegas??

Maybe we need to bring this show to Atlantic City next year and see where these EPA types stand on the East Coast because once again your question comes to mind. I wonder since there's safety concerns about snowfall and Black Ice here if that factors in to what's allowed and what's not? Good question.

[John T 744]

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?

I'm in trouble already:) Nigel Congrats in joining the PWNA and I'm honored to serve with you on this committee. Nothing like surrounding myself with a few brains and you rank very high in that Dep't. Many of us are going to learn alot between you and the rest of the PWNA enviro committee. I'm learning already by just what you posted--Thanks!

[Guy B 70]

Great Question Michael! Under Local storm water BMP's there is a list of "Exemptions" of what is allowed go in a storm drain. Just a few examples are wash down from car wrecks, run off from structure fires, flushing hydrants, street sweeping, etc...

While these are technically violations they are exempted from fines & prosecution. This doesn't seem fair but is the law in certain areas.

Edited February 16, 2013 by Guy B

[C&S Property Services 24]

Mike,

Knowing the Snow and Ice Management as I do there really isnt an explanation. I do know that most states (or at least Maryland) are trying to pass bills that use of brine will be a requirement 24 hours prior to any snow event. My opinion is that this is their regulation as cutting the use of actual rock salt. Knowing that brine is salt and water mixed I am sure the thinking is we just cut the salt usage in half. Again thats just my opinion and maybe someone knows something more.

[NJWashingGuy 31]

Great Question Michael! Under Local storm water BMP's there is a list of "Exemptions" of what is allowed go in a storm drain. Just a few examples are wash down from car wrecks, run off from structure fires, flushing hydrants, street sweeping, etc...

While these are technically violations they are exempted from fines & prosecution. This doesn't seem fair but is the law in certain areas.

Mike,

Knowing the Snow and Ice Management as I do there really isnt an explanation. I do know that most states (or at least Maryland) are trying to pass bills that use of brine will be a requirement 24 hours prior to any snow event. My opinion is that this is their regulation as cutting the use of actual rock salt. Knowing that brine is salt and water mixed I am sure the thinking is we just cut the salt usage in half. Again thats just my opinion and maybe someone knows something more.

I would love to see an answer to this, especially if they locked themselves into the statement of an exemption. Salt brine is more more corrosive than the 15% that we use for a lot of cleaning. For a testament to its corrosive ability, I would love to show a regulator a time shown event of leaving a piece of metal in a five gallon pail of the stuff and see how long it lasts. If that stuff is as strong as I believe, thy are gonna be hard pressed to make a good argument why it's allowed. In addition to that, the chemical properties are similar with salt as a main ingredient.

Anyone else have more info on this type of thing being allowed???

it needs to be about the environment, not hypocracy!!

Edited February 16, 2013 by NJWashingGuy

[NJWashingGuy 31]

One other thing to point out would be that one snow preparation event by a state, county, city or municipality is far wore than what a group of power washers could do in a year...........

[Jim Gamble 20]

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?

Congratulations on your NEW PWNA Position. You got to be one of the smartest guys in the field.

Good Choice !!!

GO PWNA !!!!!!

Edited February 16, 2013 by Jim Gamble
added PWNA

[John T 744]

One other thing to point out would be that one snow preparation event by a state, county, city or municipality is far wore than what a group of power washers could do in a year...........

Another good point.... There seems to be different standards set by the EPA which is why there most likely are lobbyist involved. Case in point- AUTOMOBILES- there's got to be more pollution caused by them then probably anything on this planet but you know there a powerful group with lobbyist etc etc etc. So that tells me instead of looking the other way and acting like no one ever gets fined for Powerwashing especially when your talking about the larger jobs out there must be something we can do.

Suggestion would be to find a way inside to these EPA types and figure out what makes them tick. Why is there one standard such as dealing with salt brine possibly and dealing with Powerwashing runoff seam to be so different.

Another reason why I want to see some of these EPA people up close and personal at the Vegas Parking Garage event because personally Mike-- we can all post about this on the net which is educational of course but besides that where does it get us in having maybe a leg up in possibly making the EPA be more understanding into what we do??

We can run but we can't hide so the road to success is to eventually deal with them as a group. In that group where going to need people who are intellects who can back up what their saying because we already know this is going to be an uphill battle no matter what when dealing with anything that involves the EPA.

[Guy B 70]

Michael, I completely agree its total hypocrisy, but they make the rules and we have to follow them as best we can.

[John T 744]

Michael, I completely agree its total hypocrisy, but they make the rules and we have to follow them as best we can.

Or be heard. How we get there?? That's what where trying to figure out.

[810F250 14]

Thank you John T and Jim G

Comment on Snow and ice management.

Snow and ice management services (which I also provide) has grown exponentially with urbanization,...... the influence of products and techniques of yesteryear have/are being analyzed with respect to efficiency and environmental impact, improvements are being made to reduce negative impact, cities are investigating environmental consequences, monitoring and making changes to products, equipment and operating procedures.

One of the key drivers of Snow and Ice Management continued service is its importance , .....ie safety, commerce/trade, continued government operations, national security etc

here is the link to the photoed epa document above.

Another EPA Doc: Managing Highway Deicing to prevent Contamination of Drinking Water

Changes are already being implimented for Snow and Ice operations, ongoing studies are being conducted; manuals are being written and BMP's are being adopted, ...............uncovered/unsecured salt stock piles are becoming a taboo,....... you may have observed newer norms of Snow and Ice mangement namely .................pre-treatment, pre-wetting and anti icing

[810F250 14]

Thank you John T and Jim G

Comment on Snow and ice management.

Snow and ice management services (which I also provide) has grown exponentially with urbanization,...... the influence of products and techniques of yesteryear have/are being analyzed with respect to efficiency and environmental impact, improvements are being made to reduce negative impact, cities are investigating environmental consequences, monitoring and making changes to products, equipment and operating procedures.

One of the key drivers of Snow and Ice Management continued service is its importance , .....ie safety, commerce/trade, continued government operations, national security etc

here is the link to the photoed epa document above.

Another EPA Doc: Managing Highway Deicing to prevent Contamination of Drinking Water

Changes are already being implimented for Snow and Ice operations, ongoing studies are being conducted; manuals are being written and BMP's are being adopted, ...............uncovered/unsecured salt stock piles are becoming a taboo,....... you may or may not have observed newer norms of Snow and Ice mangement today..................................namely pre-treatment,...... pre-wetting,...... anti icing, and .......alternative deicing materials

Edited February 17, 2013 by 810F250
added

[Mathew Johnson 123]

Thank you John T and Jim G

Comment on Snow and ice management.

Snow and ice management services (which I also provide) has grown exponentially with urbanization,...... the influence of products and techniques of yesteryear have/are being analyzed with respect to efficiency and environmental impact, improvements are being made to reduce negative impact, cities are investigating environmental consequences, monitoring and making changes to products, equipment and operating procedures.

One of the key drivers of Snow and Ice Management continued service is its importance , .....ie safety, commerce/trade, continued government operations, national security etc

[ATTACH=CONFIG]19614[/ATTACH]

here is the link to the photoed epa document above.

Another EPA Doc: Managing Highway Deicing to prevent Contamination of Drinking Water

Changes are already being implimented for Snow and Ice operations, ongoing studies are being conducted; manuals are being written and BMP's are being adopted, ...............uncovered/unsecured salt stock piles are becoming a taboo,....... you may or may not have observed newer norms of Snow and Ice mangement today namely .................pre-treatment, pre-wetting and anti icing

Good info Nigel!

Mathew Johnson

Sent from my iPhone using Tapatalk

[810F250 14]

While reviewing links on the PWNA's current environmental page related to Updated BMP Documents 2011 I noticed that there is different content for the various format versions of the BMP. (this creates confusion , especially when the word doc is compared to the pdf versions, the filtering requirements are different as I mentioned earlier (initially I had not realized that the doc I found on the web was still current to the PWNA's website), the powerpoint version does not open in powerpoint but rather is a copy of the pdf version (they both have the same web link).

Robert, Post #4 and #5 made in thread seem to be following the pdf versions of the 2011 Updated BMP's , but not in order, this creates some confusion to followers, after your post #2 which ended with Always Filter Waste Water, the next review topic should be Waste Water Capture (lower portion of page 7 in pdf version of BMP document).

I suggest streamlining the current environmental page BMP web links discrepancies on the PWNA website and identiy in no uncertain terms what is the screen mesh suggested requirement, also when identifying mesh sizes always reference the equivalent micron size.

Lets continue from page 7 ?

[John T 744]

While reviewing links on the PWNA's current environmental page related to Updated BMP Documents 2011 I noticed that there is different content for the various format versions of the BMP. (this creates confusion , especially when the word doc is compared to the pdf versions, the filtering requirements are different as I mentioned earlier (initially I had not realized that the doc I found on the web was still current to the PWNA's website), the powerpoint version does not open in powerpoint but rather is a copy of the pdf version (they both have the same web link).

Robert, Post #4 and #5 made in thread seem to be following the pdf versions of the 2011 Updated BMP's , but not in order, this creates some confusion to followers, after your post #2 which ended with Always Filter Waste Water, the next review topic should be Waste Water Capture (lower portion of page 7 in pdf version of BMP document).

I suggest streamlining the current environmental page BMP web links discrepancies on the PWNA website and identiy in no uncertain terms what is the screen mesh suggested requirement, also when identifying mesh sizes always reference the equivalent micron size.

Lets continue from page 7 ?

Excellent points Nigel. I looked at these BMP's in the past but I haven't really studied them as of yet. It's on my list.

Hey fast question. Why do you suppose it is that for snow/ice purposes it's OK to lay salt brine down on the roads which most of it will travel down the storm drains if it has dissolved first(probably still end up down the storm drain) and yet our waste water is a total no no to let it pour down a storm drain? Do you think because of the safety factor here where salt/brine can save lives makes it where they get more of a free pass then we do?

What's are some thoughts as to why this is?

[Robert Hinderliter 64]

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.

[Robert Hinderliter 64]

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.