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Robert Hinderliter

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

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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.

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.

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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!!

Michael:

If you are really interested in how this was done in your area you will have to do some research.

Go to websites where this information is (eats up a lot of time), start with the epa.gov, state website, Departments of Environment Management, Stormwater Department, health departments, local municipality, here are some examples:

California

California Environmental Protection Agency

California Department of Conservation

California Air Resources Board

California Department of Water Resources

California Integrated Waste Management Board

CA, Calabasas Mobile Commercial Washing Operations http://www.cityofcalabasas.com/pdf/mobile-car-wash/Calabasas-Mobile-Car-Wash-Ordinance.pdf

CA, CASQA Vehicle and Equipment Cleaning SC-21 http://www.cabmphandbooks.com/Documents/Industrial/SC-21.pdf

CA, County of San Diego County of San Diego County of San Diego: Stormwater - Power Washing

CA, Discharge Prohibitions San Francisco Bay Basin http://www.waterboards.ca.gov/sanfranciscobay/water_issues/programs/planningtmdls/basinplan/web/tab/tab_4-01.pdf

CA, Greater Sacramento Area http://www.sactostormwater.org/SSQP/documents/PressureWashing_BMPs_Dec08.pdf

CA, NAPA-SOLAND-SONOMA Stormwater Agencies http://city.ci.st-helena.ca.us/images/aad/Docs/SurfaceCleaner%20Guide12.04.pdf

CA, Parker West Environmental pressure washing removes petroleum and chemical pollutants from driveways and facilities without polluting storm drain systems

CA, Pressure Washing Regulations in California What are the Pressure Washing Regulations in California? | eHow.com

CA, Regional Water Quality Control Board, Exceptions for Low-Threat Discharges, Side Walks http://www.waterboards.ca.gov/northcoast/water_issues/programs/basin_plan/081120_ltd/comments/1_29_09_DMcenhill.pdf

CA, San Diego, http://www.sandiego.gov/thinkblue/pdf/mobilebusinessbrochure.pdf

CA, San Francisco Bay Implementation Plans Chapter 4 State Water Resources Control Board - San Francisco Bay

CA, Santa Clara Valley 7. Equipment Washing & Steam Cleaning http://www.waterboards.ca.gov/water_issues/programs/stormwater/docs/murp_appendix4cc.pdf

CA, Title 8 Car Washing and Polishing http://www.dir.ca.gov/dlse/CarWash/CARWASH-RegsSections13680-13693FINAL-1121.pdf

CA, Prevention of Groundwater Contamination in Southern CA Groundwater Contamination Prevention/Cleanup in the Central and West Coast Basins

Took about 4 hours to assemble the above.

Here are some search terms

Power Wash

Pressure Wash

Cosmetic Cleaning

Car Wash

Boat Washing

Airplane Washing

Truck Wash

Stormwater Storm Water

Storm Drain

Storm Sewer

Sanitary Sewer

NPDES MS4

Most websites will have a search box, which may or may not give you acceptable results. Watch very closely:

US Environmental Protection Agency Here there is a search Box, enter the items above.

If you enter (Cosmetic Cleaning) it will take you to any document with any of those words in it. But if you enter ("Cosmetic Cleaning"), then it will only take you to those documents where those words are together.

Now if you want to search with Google the do this:

site:epa.gov/ cosmetic cleaning or site:epa.gov/ "cosmetic cleaning" which will take you directly to the EPA's Model Ordinance.

Most search engine use Google already, but not always. Also, I have found sometimes that using the manual search as ( site: ) above gives different results.

Happy searching.

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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 ?

Nigel: That needs to be addressed in the next update. We need to start making a list of everything.

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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?

I have not studied the BMP's either , I welcome the review and hope that all PWNA members, and BBS members and guest follow this thread and make comments.

John, 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

Operations are reviewed and/or changing seasonally.

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.

Lets definitively identify what the PWNA doc would have, and review

20 US mesh is 841 microns

40 US mesh is 420 microns

What is the current Storm Inlet Protection BMP mesh/micron criteria for land construction?

Edited by 810F250

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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?

The more votes you represent the more they pay attention to you. Good Ole American Way.

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The more votes you represent the more they pay attention to you. Good Ole American Way.

"Aint that the truth" that's why we need proper representation down the road.

Internet discussion are great but the reality of them is no one is going to accept these discussions as a way to get the powers to be to do anything or even recognize us at all. Looking forward to having open discussions with these EPA type people down the road starting with the Vegas Parking Garage Event.

Edited by John T

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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.

Here are some other EPA Storm Water exemptions

Allowable Non-Storm Water Discharges:

1. Discharges from fire fighting activities

2. Fire hydrant flushing (testing)

3. Potable water including water line flushing (testing)

4. Uncontaminated air condition or compressor condensate

5. Irrigation drainage

6. Landscape watering, provide all pesticides, herbicides, and fertilizers have been applied

in accordance with manufacturers instructions

7. Pavement wash water where no detergents are used and no spills, leaks of toxic or

hazardous materials have occurred (unless all spilled material has been removed)

8. Routine external building wash down which does not use detergent

9. Uncontaminated groundwater or spring water

10. Foundation or footing drains where flows are not contaminated with process materials

11. Incidental windblown mist from cooling towers that collects on rooftops or adjacent

portions of your facility, but NOT intentional discharges from cooling towers

Nigel: That needs to be addressed in the next update. We need to start making a list of everything.

Agreed. More peer reviews the better.

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I recommend that the existing PWNA Cosmetic Cleaning BMP's manual be reviewed in chronological order (after we identifying the exact document to be reviewed, pdf file or word doc),..... though forum members can review pages that are currently being posted, there is a greater chance of page omission.

19618d1361136463-power-washers-north-america-cosmetic-cleaning-bmps-based-epas-model-ordinance-capture-22.jpg

I recommend that an alternative photo be used here, possibly one showing no debris at the inlet (showing water draining into storm inlet it is not necessary, as this may conjure thoughts that the water must be of a certain clarity, clear water is not necessarily safer for the environment vs mildly turbid water) , this photo is better suited to show the need for street/parking lot sweeping.

The phrase "Nothing Down the Drain But Rain", is a contradictory phrase, although I not aware of its inception/history and though it may have been developed in earnest, the reality is, it is not attainable, the EPA and localities allow exempt, permitted and non-permitted discharges to the "drain but rain"

Recommend that no photo be placed at this point in manual or if one is to be placed, the alternative suggested above.

{I am taking a steep back, looking at the big picture, .....................}

I think there is a great deal of information in the current PWNA Cosmetic Cleaning BMP manual, (I am reviewing the pdf version), the manual appears as a combination of pressure cleaning BMPs and AHJ training.

I dont believe the two should be heavily inter mixed as they currently are, there maybe some overlap but in my opinion there is to much non-direct information, which is not necessary to be placed in a Contractors Association Cosmetic Cleaning BMP Manual. A manual should be as clear as possible. The PWNA can engage in providing training to AHJ's and I feel this should be entertained.

The PWNA Cosmetic Cleaning BMP manual should be focused with an objective being:

Concise in identifying/recommending, reasonable rational and logical Best Management Practices for various cleaning circumstances, that ultimately contractors have researched, developed, tested/adopted, re-evaluated and validated to minimize negative impact to the environment from operations with necessary consultation and assistance form internal and external knowledge/beneficial sources.

..........................................................................................................................................................................................................................

{I am thinking out loud here:}

What is the historical perspective of BMP's? ,and in particular the PWNA proposed BMP's ?, we need to identify a vision for the manual, and ultimately its mission

Hope this post can be understood in the positive nature it was intended.

Edited by 810F250

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I recommend that the existing PWNA Cosmetic Cleaning BMP's manual be reviewed in chronological order (after we identifying the exact document to be reviewed, pdf file or word doc),..... though forum members can review pages that are currently being posted, there is a greater chance of page omission.

I recommend that an alternative photo be used here, possibly one showing no debris at the inlet (showing water draining into storm inlet it is not necessary, as this may conjure thoughts that the water must be of a certain clarity, clear water is not necessarily safer for the environment vs mildly turbid water) , this photo is better suited to show the need for street/parking lot sweeping.

The phrase "Nothing Down the Drain But Rain", is a contradictory phrase, although I not aware of its inception/history and though it may have been developed in earnest, the reality is, it is not attainable, the EPA and localities allow exempt, permitted and non-permitted discharges to the "drain but rain"

Recommend that no photo be placed at this point in manual or if one is to be placed, the alternative suggested above.

{I am taking a steep back, looking at the big picture, .....................}

I think there is a great deal of information in the current PWNA Cosmetic Cleaning BMP manual, (I am reviewing the pdf version), the manual appears as a combination of pressure cleaning BMPs and AHJ training.

I dont believe the two should be heavily inter mixed as they currently are, there maybe some overlap but in my opinion there is to much non-direct information, which is not necessary to be placed in a Contractors Association Cosmetic Cleaning BMP Manual. A manual should be as clear as possible. The PWNA can engage in providing training to AHJ's and I feel this should be entertained.

The PWNA Cosmetic Cleaning BMP manual should be focused with an objective being:

Concise in identifying/recommending, reasonable rational and logical Best Management Practices for various cleaning circumstances, that ultimately contractors have researched, developed, tested/adopted, re-evaluated and validated to minimize negative impact to the environment from operations with necessary consultation and assistance form internal and external knowledge/beneficial sources.

..........................................................................................................................................................................................................................

{I am thinking out loud here:}

What is the historical perspective of BMP's? ,and in particular the PWNA proposed BMP's ?, we need to identify a vision for the manual, and ultimately its mission

Hope this post can be understood in the positive nature it was intended.

Nigel: You are correct in that the BMPs as currently posted are a combination of AHJ Training and Practical BMPs. I felt that if the contract cleaner was aware of the AHJ Training then they could do a better job of making a competent decision. Most of the AHJ Training were develop by Charlotte, NC with some editing by myself and Mike Hilborn.

Another thing you need to be aware of is that almost everyone who was involved with the development of the ordinances and BMPs have retired. Very few people of the original development community are still working. That is another reason that things are not always consistent.

I have no problem with reviewing everything, however, that is a very big effort. Everything could be split into contractor training and AHJ Training. The biggest problem I see is finding someone willing to lead the effort.

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Sidebar note as per Conversation with Robert today--Here is the PWNA BOD's the first year I served. This was at a PWNA Convention in Dallas around 2004/2005. That Sport Jacket was given to me from Rod Rodriguez because they wanted us in Suit jackets for this picture. I think I only owned one then and I didn't bring it. If you can zoom in you will see my shoes. I walked a mile plus in the snow every day to be at this Convention because I was to naive to book in the room block.

I look back on this and I wish then we had been more involved with BMP's.

Today I am happy to serve with my fellow PWNA Enviro chairpersons even though its been challenging already. If its not a challenge then what's the point:biggrin:

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Sidebar note as per Conversation with Robert today--Here is the PWNA BOD's the first year I served. This was at a PWNA Convention in Dallas around 2004/2005. That Sport Jacket was given to me from Rod Rodriguez because they wanted us in Suit jackets for this picture. I think I only owned one then and I didn't bring it. If you can zoom in you will see my shoes. I walked a mile plus in the snow every day to be at this Convention because I was to naive to book in the room block.

I look back on this and I wish then we had been more involved with BMP's.

Today I am happy to serve with my fellow PWNA Enviro chairpersons even though its been challenging already. If its not a challenge then what's the point:biggrin:

Dallas only snow fall that year, about 12 inches. Dallas has no snow removal equipment. Thanks for the picture.

Excellent show with IWCA

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Be aware that in a lot of Second Five Year Plans for Phase II there are General NPDES Permits for Contractors for certain jobs. Search for these in your area.

Hey Robert can you explain in the least amount of sentences what the first 5 yr plan was and then what changes second 5 yr plan is and also what yr did they start? Are we in the second phase now?

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Sidebar note as per Conversation with Robert today--Here is the PWNA BOD's the first year I served. This was at a PWNA Convention in Dallas around 2004/2005. That Sport Jacket was given to me from Rod Rodriguez because they wanted us in Suit jackets for this picture. I think I only owned one then and I didn't bring it. If you can zoom in you will see my shoes. I walked a mile plus in the snow every day to be at this Convention because I was to naive to book in the room block.

I look back on this and I wish then we had been more involved with BMP's.

Today I am happy to serve with my fellow PWNA Enviro chairpersons even though its been challenging already. If its not a challenge then what's the point:biggrin:

John, who is the guy second from the right on the first row?

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John, who is the guy second from the right on the first row?

You may have seen him in the past or as recently as this past IWCA Convention. His name is Kenny Cohn (might be spelling his last name wrong) who was a past IWCA President.

Its good to surround yourself with people like him. 2 yrs later I served right under Jim Grady who was also a past IWCA president who was the PWNA treasurer and when he left that's the position I was given. Jim Grady is aces.

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Nigel: You are correct in that the BMPs as currently posted are a combination of AHJ Training and Practical BMPs. I felt that if the contract cleaner was aware of the AHJ Training then they could do a better job of making a competent decision. Most of the AHJ Training were develop by Charlotte, NC with some editing by myself and Mike Hilborn.

Another thing you need to be aware of is that almost everyone who was involved with the development of the ordinances and BMPs have retired. Very few people of the original development community are still working. That is another reason that things are not always consistent.

I have no problem with reviewing everything, however, that is a very big effort. Everything could be split into contractor training and AHJ Training. The biggest problem I see is finding someone willing to lead the effort.

I don't know all the history of the documents, ......there is a "big effort" requirement, I will assist as best possible.

............................................................................................................................................

I asked in a earlier post what was the construction BMP mesh/micron requirements, in reviewing some construction industry BMP's storm inlet protection media material specs I came across this info:

They are commonly geo-textiles:

Slit Dike (gravity flow sediment removal) offers approximately 40 US mesh/420 micron sediment filtering

Curb Inlet Protector (gravity flow sediment removal) 8 oz/sd.yd offers approximately 80 us mesh/180 micron

Pipe Sock (pumped flow sediment removal) 11 oz/sq.yd offers approximately 100-140 US Mesh/ 100-150 Microns

Dewatering Bag (pumped flow sediment removal) 8 oz/sq.yd offers approximately 80 US Mesh/ 180 microns

Size of suspended particulate appears to be commonly addressed with respect to storm water discharges, I have not seen any document reference to quantity (mg/l) or ppm requirements.

In contrast the average sanitary sewer limits of Suspended Solids may vary, but one POTW limit in Maryland is 400mg/l, but micron size not mentioned.

Edited by 810F250

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