The document summarizes regulations and best management practices (BMPs) for mobile power washing businesses. It discusses the Clean Water Act and how it prohibits discharging pollutants into waterways without a permit. It outlines BMPs like containing wash water onsite and discharging only drinking water quality wastewater to sanitary sewers to avoid fines for off-property discharges. The document provides an overview of the NPDES permitting system and its phases that regulate stormwater runoff.
This document provides an overview of significant events and regulations affecting the mobile power washing industry, including:
- The Clean Water Act of 1972 established regulations on discharging pollutants into waterways and required municipalities to assess their environmental impact.
- Enforcement of these regulations increased in the late 1980s and early 1990s with cities passing ordinances banning off-property discharge and requiring wastewater be directed to sanitary sewers.
- The NPDES permit system required cities over 250,000 people to obtain permits by 1992 and over 100,000 people by 1993, with Phase II in 2003 covering smaller municipalities. These regulate stormwater and wastewater discharges.
The document discusses best management practices for managing wash water runoff from pressure washing and vehicle detailing. It provides an overview of regulations under the Clean Water Act regarding discharging wash water and wastewater. It also defines key terms and discusses proper containment and disposal of wash water, including discharge to sanitary sewers or transporting offsite to authorized facilities.
EPA Region 6 MS4 Ordinances for Pressure Power Wash Cosmetic Cleaning presented in Waco, TX July 15, 2008. Summaries the Cosmetic Cleaning Ordinances of EPA Region 6 and there effect on the pollutants in the Storm Drains.
The document discusses Wisconsin's universal waste rule (UWR) and special waste program. The UWR aims to promote recycling of commonly generated hazardous wastes like batteries, pesticides, mercury thermostats, and fluorescent bulbs. It provides reduced regulatory requirements for these wastes to encourage proper management. Wisconsin has expanded the list of wastes covered to include additional mercury-containing items. The special waste program coordinates the inclusion of other materials and aims to ban certain wastes from landfill disposal to promote recycling and remove toxins from the waste stream.
This document discusses the concept and growing movement of zero waste. It defines zero waste as a total commitment to pursuing zero waste, rather than just reducing waste. Zero waste is gaining attention from governments and media outlets around the world. While the average recycling rate in America is only 34%, some communities and businesses have achieved rates over 90% through strategies like convenient collection programs, education, mandates, and improved technologies. The document argues that pursuing zero waste through these types of strategies can generate economic and environmental benefits.
Elected officials have legal responsibilities and potential liability when managing water and wastewater treatment. Two case studies are described where municipalities were held criminally and civilly liable for incidents that polluted water sources and harmed public health. These cases illustrate that elected officials can be held responsible by courts and regulators for safely operating water and wastewater systems and protecting public health. Ongoing education is important for understanding legal responsibilities in this highly regulated field.
This document provides an overview of significant events and regulations affecting the mobile power washing industry, including:
- The Clean Water Act of 1972 established regulations on discharging pollutants into waterways and required municipalities to assess their environmental impact.
- Enforcement of these regulations increased in the late 1980s and early 1990s with cities passing ordinances banning off-property discharge and requiring wastewater be directed to sanitary sewers.
- The NPDES permit system required cities over 250,000 people to obtain permits by 1992 and over 100,000 people by 1993, with Phase II in 2003 covering smaller municipalities. These regulate stormwater and wastewater discharges.
The document discusses best management practices for managing wash water runoff from pressure washing and vehicle detailing. It provides an overview of regulations under the Clean Water Act regarding discharging wash water and wastewater. It also defines key terms and discusses proper containment and disposal of wash water, including discharge to sanitary sewers or transporting offsite to authorized facilities.
EPA Region 6 MS4 Ordinances for Pressure Power Wash Cosmetic Cleaning presented in Waco, TX July 15, 2008. Summaries the Cosmetic Cleaning Ordinances of EPA Region 6 and there effect on the pollutants in the Storm Drains.
The document discusses Wisconsin's universal waste rule (UWR) and special waste program. The UWR aims to promote recycling of commonly generated hazardous wastes like batteries, pesticides, mercury thermostats, and fluorescent bulbs. It provides reduced regulatory requirements for these wastes to encourage proper management. Wisconsin has expanded the list of wastes covered to include additional mercury-containing items. The special waste program coordinates the inclusion of other materials and aims to ban certain wastes from landfill disposal to promote recycling and remove toxins from the waste stream.
This document discusses the concept and growing movement of zero waste. It defines zero waste as a total commitment to pursuing zero waste, rather than just reducing waste. Zero waste is gaining attention from governments and media outlets around the world. While the average recycling rate in America is only 34%, some communities and businesses have achieved rates over 90% through strategies like convenient collection programs, education, mandates, and improved technologies. The document argues that pursuing zero waste through these types of strategies can generate economic and environmental benefits.
Elected officials have legal responsibilities and potential liability when managing water and wastewater treatment. Two case studies are described where municipalities were held criminally and civilly liable for incidents that polluted water sources and harmed public health. These cases illustrate that elected officials can be held responsible by courts and regulators for safely operating water and wastewater systems and protecting public health. Ongoing education is important for understanding legal responsibilities in this highly regulated field.
Regulations related to health, environment and safetyDhruv Patel
This document discusses regulations related to health, safety, and the environment in India. It begins by introducing the topic and listing some key Indian laws that govern these areas, such as the Factories Act, Mines Act, and Dock Workers Act. It then discusses provisions of the Factories Act and Mines Act in more detail, outlining requirements for workplace health, safety measures, medical supervision of workers, and more. The document also covers topics like wastewater disposal and treatment, pollution prevention, waste management regulations, and the differences between large and small quantity generators of hazardous waste.
The document discusses the history and regulation of stormwater pollution in the United States. It outlines key events in the Clean Water Act that led to stormwater being defined as a point source pollution in 1987. It also describes the EPA's NPDES permitting programs for municipal stormwater systems and construction sites that have phased in regulation of large and small entities since 1990. The document closes by discussing current issues like setting effluent limits, implementing total maximum daily loads, and exploring options to reduce urban stormwater runoff volume.
Urban Water Quality Issues - Assisting Municipalities in Implementing NPDES P...nacaa
The document discusses strategies for assisting municipalities in implementing NPDES Phase II stormwater programs. It outlines the challenges small communities face in complying with permit requirements and providing expertise. It recommends providing turn-key training, workshops in convenient locations, guidance and examples to help communities understand requirements and improve practices like pollution prevention and illicit discharge detection. The training programs held workshops that 522 people attended and helped communities address issues like vehicle washing discharges and spill prevention.
Running head DRAFT OF THE FINAL WRITING PROJECT DRAFT OF THE FI.docxcharisellington63520
Running head: DRAFT OF THE FINAL WRITING PROJECT
DRAFT OF THE FINAL WRITING PROJECT 8
Draft of the Final Writing Project
Heather Fuller
LS302: Environmental Law and Policy
November 08, 2015
RRE International wants to begin the construction and operation of the smelter in the City of Riverside. There is the need for the company to get permits for its operation as it intends to build and operate the smelter, construct outfalls that will discharge into the Long Trout River, and store and transport the hazardous waste.
The paper will look at various issues that might come up with the building of the facility in that area. The issues include the opposition from residents living within the surrounding community who might oppose the facility from being built in that area. The other issue is the concerns of the reactions from local and state officials to locating this facility in their area. Another issue that will be discussed is the possible contamination of soil and river that will raise concern from the citizens.
Another issue of concern will be the air quality of the area due to building of the facility.
The paper will also look at some of the permits that will need to be pulled before the facility is set up. The environmental acts involved in the building of the facility will also be highlighted. Finally, there will be a discussion of the development and fostering of relations with government officials.
Permits and needs for the permits
There are several permits that RRE International will require to obtain before they begin the construction and operation of the smelter company they want to set up in the City of Riverside. One of the permits is the building and construction permit which is the formal permission to start the construction, demolition, addition or renovation of property. The other permit is the business license that is needed for entities that are carrying out business in the limits of a city. The other required permit is the certificate of disclosure of hazardous substances. This requires those businesses which handle hazardous materials to report the information to implementing agencies. The facility is also required to fill a Business Emergency/Contingency Plan so as to develop an emergency plan.
Another requirement is the land use permit/zoning clearance is needed to allow specific types of development. Land use permit is required for the zoning of a site. There is also a requirement for police regulations or public safety. The city of Riverside has an ordinance that requires the facility to get a permit to have an entry alarm. The facility requires obtaining a fictitious business name since the organization’s business name does not contain the surname of its owners. Another permit required is the hazardous material/waste generation program which is to be filled if an organization ha.
The Resource Conservation and Recovery Act (RCRA) is the principal US law governing solid and hazardous waste disposal. Enacted in 1976, RCRA aims to protect human health and the environment from waste hazards by regulating waste from "cradle to grave", including generation, transportation, treatment, storage, and disposal. RCRA addresses both hazardous and non-hazardous waste, and gives the EPA authority to implement regulations around waste management. RCRA has been amended over time to expand its scope and strengthen protections.
Environmental Issues in Real Estate Transactions Polsinelli PC
Presentation covers basics of environmental law applicable to real estate transactions including key statutes, important liability defenses or "safe harbors", role of due diligence, and how much diligence is required, contractual provision and resources to address environmental issues and keep the deal alive.
The document summarizes the history and evolution of stormwater management regulations in the United States from the 1940s to present. It discusses the key laws passed including the Clean Water Act and its amendments. It describes the development of NPDES permitting programs for municipal separate storm sewer systems and the establishment of effluent limitation guidelines and best management practices for stormwater. It also discusses the concept of "maximum extent practicable" in regulating stormwater discharges.
This document provides a summary of major environmental laws and regulations in the United States over time. It begins with a brief history of environmental practices from the 1600s to the 1970s. It then describes key events that led to increased environmental regulation, such as pollution incidents involving the Cuyahoga River and Love Canal. Major environmental laws passed between the 1970s and 1990s are outlined, including the Clean Air Act, Clean Water Act, and Superfund. The roles of the EPA and concept of cooperative federalism are also summarized. Current major concerns related to the environment are listed at the end.
This document provides a summary of major environmental laws and regulations in the United States over time. It begins with a brief history of environmental practices from the 1600s to the 1970s. It then describes key events that led to increased environmental regulation, such as pollution incidents involving the Cuyahoga River and Love Canal. Major environmental laws passed between the 1970s and 1990s are outlined, including the Clean Air Act, Clean Water Act, and Superfund. The roles of the EPA and concept of cooperative federalism are also summarized. Current major concerns related to the environment are listed at the end.
The document discusses a proposed sewer expansion project by the Steuben Lakes Regional Waste District and opposition to the project from a citizens group. It summarizes various studies from the 1970s concluding septic systems were effectively treating wastewater and not negatively impacting water quality. The EPA recommended a limited alternative approach rather than a large sewer system, but the District approved the larger sewer plan against the EPA's recommendation.
The document discusses the EPA's recommendation that the SLRWD use a Limited Alternative Action rather than implement the sewer expansion plan proposed by Mick, Rowland & Associates. The EPA found that septic systems were effectively treating waste when maintained properly and that a centralized sewer system was not needed and could harm the environment and burden homeowners with high costs. Studies by various organizations supported the EPA's conclusion that the lakes were already improving in water quality.
1. The document discusses various types of environmental legislation and regulations aimed at protecting air, water, and land from pollution, including the Clean Air Act, Clean Water Act, and Safe Drinking Water Act.
2. It also covers the four main phases of environmental contamination: water contamination from industrial and agricultural waste; air contamination from vehicles, agriculture, and mining; noise contamination from transportation, construction, and industry; and soil contamination which can affect both ecosystems and human health.
3. Different remediation methods are discussed for treating contaminated groundwater, surface water, soil, and sediments in order to remove pollutants and restore environmental quality.
Waterkeeper submission: Review of Ontario’s Environmental Bill of Rights and ...LOWaterkeeper
Waterkeeper submitted these recommendations to the Environmental Commissioner of Ontario in response to the Ministry of the Environment and Climate Change’s call for public comments as part of its review of Ontario’s Environmental Bill of Rights (“EBR”).
The EBR is a uniquely Ontarian, powerful tool to bring citizens, government, and business together to protect the province’s environment. Over the years, issues with the EBR and its implementation have emerged. This review is a welcome opportunity to improve the EBR without undermining or compromising original protections.
One aspect of the EBR’s importance that deserves highlighting is its value to charities. Political activity by charities is limited. Partisan activities are prohibited. Tools such as those created under the EBR are often the sole means by which charities can
participate in government decision-making.
Similarly, the EBR is a safeguard for Ontario residents who may not have geographic, political, social, or professional access to government. As such, this review is an important opportunity to re-assert the authority of the EBR when it comes to decision-making in Ontario.
In addition to these comments, Lake Ontario Waterkeeper / Swim Drink Fish Canada wholly endorses the detailed comments submitted on November 4, 2016 by the Canadian Environmental Law Association (“CELA”).
The Port Authority of New York and New JerseyProposal for .docxssusera34210
The Port Authority of New York and New Jersey
Proposal for Performing an Environmental Impact Statement and Alternatives Analysis for Modifying or Replacing the Lincoln Tunnel Helix
Proposal for Performance of an Environmental
Impact Statement and Alternative Analysis
–
For Modifying or Replacing the
Lincoln Tunnel Helix
Prepared by:
Greenfield Environmental Consulting
Issued: April 21st, 2015
The Port Authority of
New York and New Jersey
Table of Contents:
Section A – Firm Qualifications and Experience ……………………………………....3
A.1 – Governmental Regulations and Laws …………………………………………………. 4
A.2 – Guideline Documents …………………………………………………………………. 7
A.3 – Environmental Permits ……………………………………………………………….. 12
A.4 – NEPA Lead Agency ………………………………………………………………….. 13
A.5 – Environmental Documentation ……………………………………………………….. 14
Section B – Staff Qualifications and Experience ……………………………………..16
B.1 – Organizational Chart ………………………………………………………………….. 17
B.2 – Personal Profiles and Individual Experience …………………………………………. 18
Caulfield, Christopher ……………………………………………………………………….. 18
Greenleaf, Luke ……………………………………………………………………………… 23
Anderson, David …………………………………………………………………………….. 25
Zyndorf, Oren ……………………………………………………………………………….. 27
Schroeder, Alison …………………………………………………………………………… 30
Lombardi, John …………………………………………………………………………….... 32
Mahmud, Anna …………………………………………………………………………….... 34
Martin, Jonathan …………………………………………………………………………….. 37
Mugabel, Abdul ……………………………………………………………………………... 38
Section C – Technical Approach ……………………………………………………..40
C.1 – Preparation of Environmental Impact Statement ……………………………………... 41
C.2 – No-Action Alternative ………………………………………………………………... 43
C.3 – List of Alternatives to be Reviewed ………………………………………………….. 44
C.4 – Environmental Impact Statement Table of Contents …………………………………. 48
C.5 – Data Analysis Sources ………………………………………………………………... 54
C.6 – Safety Measures ……………………………………………………………………..... 56
C.7 – Public Participation …………………………………………………………………… 59
Section D – Cost and Timetable ……………………………………………………...60
D.1 – Project Schedule ……………………………………………………………………… 61
D.2 – Cost Estimate and Budget …………………………………………………………..... 62
Firm Qualifications and Experience
A
Section
A.1
Governmental Regulations and Laws
Law is defined as the principles and regulations established in a community by some authority and applicable to its people, whether in the form of legislation or of custom and policies recognized and enforced by judicial decision. Laws are actually rules and guidelines that are set up by the social institutions to govern behavior. Laws are made by government officials. Laws must be obeyed by all, including private citizens, groups and companies as well as public figures, organizations and institutions. Laws set out standards, procedures and principles that must be followed. Regulations can be used to define two things; a process of monitoring and enforcing legislations and a written instrument ...
The document discusses point source water pollution and regulations. It provides background on key policies and acts related to water quality regulation, such as the Clean Water Act. It also summarizes different regulatory approaches for point sources, including command-and-control regulations and market-based mechanisms like effluent taxes and tradable permit systems. Overall, the document presents an overview of point source pollution issues and the evolution of policies in the United States to regulate industrial and municipal wastewater discharges.
This document provides an evaluation report of Rhode Island's pump-out facilities from 2014. It discusses the background and history of no discharge areas, describes the inspections of 67 facilities, and reports the results. Key findings include: 63 of 68 facilities inspected were functional, with only 1 failing the pump test of emptying 5 gallons in under a minute. The report provides recommendations to improve the program and compliance with protecting Rhode Island waters.
Three key federal laws regulate water and wastewater treatment:
1. The Clean Water Act establishes water quality standards and regulates discharges into surface waters through the National Pollutant Discharge Elimination System permitting program. It also requires the establishment of Total Maximum Daily Loads for impaired waters.
2. The Safe Drinking Water Act regulates public water systems and establishes maximum contaminant levels for over 100 drinking water contaminants. It requires water systems to monitor contaminant levels and report results.
3. States are primarily responsible for enforcing these laws and must adopt regulations that are at least as stringent as the federal standards. Compliance involves obtaining proper permits, meeting discharge limits, monitoring and reporting water quality data, ensuring treatment
This document discusses Simix Surface Solutions' actively green self-cleaning nanoparticle technology. It highlights benefits like reduced maintenance costs, water and energy savings, and improved indoor air quality. The technology uses titanium dioxide and potassium silicate coatings that stay clean longer and remove pollutants. Applying the coatings to buildings, transportation and other surfaces provides disruptive sustainability benefits like multi-year exterior self-cleaning and energy efficient indoor air purification.
Infrastructure Challenges in Scaling RAG with Custom AI modelsZilliz
Building Retrieval-Augmented Generation (RAG) systems with open-source and custom AI models is a complex task. This talk explores the challenges in productionizing RAG systems, including retrieval performance, response synthesis, and evaluation. We’ll discuss how to leverage open-source models like text embeddings, language models, and custom fine-tuned models to enhance RAG performance. Additionally, we’ll cover how BentoML can help orchestrate and scale these AI components efficiently, ensuring seamless deployment and management of RAG systems in the cloud.
Regulations related to health, environment and safetyDhruv Patel
This document discusses regulations related to health, safety, and the environment in India. It begins by introducing the topic and listing some key Indian laws that govern these areas, such as the Factories Act, Mines Act, and Dock Workers Act. It then discusses provisions of the Factories Act and Mines Act in more detail, outlining requirements for workplace health, safety measures, medical supervision of workers, and more. The document also covers topics like wastewater disposal and treatment, pollution prevention, waste management regulations, and the differences between large and small quantity generators of hazardous waste.
The document discusses the history and regulation of stormwater pollution in the United States. It outlines key events in the Clean Water Act that led to stormwater being defined as a point source pollution in 1987. It also describes the EPA's NPDES permitting programs for municipal stormwater systems and construction sites that have phased in regulation of large and small entities since 1990. The document closes by discussing current issues like setting effluent limits, implementing total maximum daily loads, and exploring options to reduce urban stormwater runoff volume.
Urban Water Quality Issues - Assisting Municipalities in Implementing NPDES P...nacaa
The document discusses strategies for assisting municipalities in implementing NPDES Phase II stormwater programs. It outlines the challenges small communities face in complying with permit requirements and providing expertise. It recommends providing turn-key training, workshops in convenient locations, guidance and examples to help communities understand requirements and improve practices like pollution prevention and illicit discharge detection. The training programs held workshops that 522 people attended and helped communities address issues like vehicle washing discharges and spill prevention.
Running head DRAFT OF THE FINAL WRITING PROJECT DRAFT OF THE FI.docxcharisellington63520
Running head: DRAFT OF THE FINAL WRITING PROJECT
DRAFT OF THE FINAL WRITING PROJECT 8
Draft of the Final Writing Project
Heather Fuller
LS302: Environmental Law and Policy
November 08, 2015
RRE International wants to begin the construction and operation of the smelter in the City of Riverside. There is the need for the company to get permits for its operation as it intends to build and operate the smelter, construct outfalls that will discharge into the Long Trout River, and store and transport the hazardous waste.
The paper will look at various issues that might come up with the building of the facility in that area. The issues include the opposition from residents living within the surrounding community who might oppose the facility from being built in that area. The other issue is the concerns of the reactions from local and state officials to locating this facility in their area. Another issue that will be discussed is the possible contamination of soil and river that will raise concern from the citizens.
Another issue of concern will be the air quality of the area due to building of the facility.
The paper will also look at some of the permits that will need to be pulled before the facility is set up. The environmental acts involved in the building of the facility will also be highlighted. Finally, there will be a discussion of the development and fostering of relations with government officials.
Permits and needs for the permits
There are several permits that RRE International will require to obtain before they begin the construction and operation of the smelter company they want to set up in the City of Riverside. One of the permits is the building and construction permit which is the formal permission to start the construction, demolition, addition or renovation of property. The other permit is the business license that is needed for entities that are carrying out business in the limits of a city. The other required permit is the certificate of disclosure of hazardous substances. This requires those businesses which handle hazardous materials to report the information to implementing agencies. The facility is also required to fill a Business Emergency/Contingency Plan so as to develop an emergency plan.
Another requirement is the land use permit/zoning clearance is needed to allow specific types of development. Land use permit is required for the zoning of a site. There is also a requirement for police regulations or public safety. The city of Riverside has an ordinance that requires the facility to get a permit to have an entry alarm. The facility requires obtaining a fictitious business name since the organization’s business name does not contain the surname of its owners. Another permit required is the hazardous material/waste generation program which is to be filled if an organization ha.
The Resource Conservation and Recovery Act (RCRA) is the principal US law governing solid and hazardous waste disposal. Enacted in 1976, RCRA aims to protect human health and the environment from waste hazards by regulating waste from "cradle to grave", including generation, transportation, treatment, storage, and disposal. RCRA addresses both hazardous and non-hazardous waste, and gives the EPA authority to implement regulations around waste management. RCRA has been amended over time to expand its scope and strengthen protections.
Environmental Issues in Real Estate Transactions Polsinelli PC
Presentation covers basics of environmental law applicable to real estate transactions including key statutes, important liability defenses or "safe harbors", role of due diligence, and how much diligence is required, contractual provision and resources to address environmental issues and keep the deal alive.
The document summarizes the history and evolution of stormwater management regulations in the United States from the 1940s to present. It discusses the key laws passed including the Clean Water Act and its amendments. It describes the development of NPDES permitting programs for municipal separate storm sewer systems and the establishment of effluent limitation guidelines and best management practices for stormwater. It also discusses the concept of "maximum extent practicable" in regulating stormwater discharges.
This document provides a summary of major environmental laws and regulations in the United States over time. It begins with a brief history of environmental practices from the 1600s to the 1970s. It then describes key events that led to increased environmental regulation, such as pollution incidents involving the Cuyahoga River and Love Canal. Major environmental laws passed between the 1970s and 1990s are outlined, including the Clean Air Act, Clean Water Act, and Superfund. The roles of the EPA and concept of cooperative federalism are also summarized. Current major concerns related to the environment are listed at the end.
This document provides a summary of major environmental laws and regulations in the United States over time. It begins with a brief history of environmental practices from the 1600s to the 1970s. It then describes key events that led to increased environmental regulation, such as pollution incidents involving the Cuyahoga River and Love Canal. Major environmental laws passed between the 1970s and 1990s are outlined, including the Clean Air Act, Clean Water Act, and Superfund. The roles of the EPA and concept of cooperative federalism are also summarized. Current major concerns related to the environment are listed at the end.
The document discusses a proposed sewer expansion project by the Steuben Lakes Regional Waste District and opposition to the project from a citizens group. It summarizes various studies from the 1970s concluding septic systems were effectively treating wastewater and not negatively impacting water quality. The EPA recommended a limited alternative approach rather than a large sewer system, but the District approved the larger sewer plan against the EPA's recommendation.
The document discusses the EPA's recommendation that the SLRWD use a Limited Alternative Action rather than implement the sewer expansion plan proposed by Mick, Rowland & Associates. The EPA found that septic systems were effectively treating waste when maintained properly and that a centralized sewer system was not needed and could harm the environment and burden homeowners with high costs. Studies by various organizations supported the EPA's conclusion that the lakes were already improving in water quality.
1. The document discusses various types of environmental legislation and regulations aimed at protecting air, water, and land from pollution, including the Clean Air Act, Clean Water Act, and Safe Drinking Water Act.
2. It also covers the four main phases of environmental contamination: water contamination from industrial and agricultural waste; air contamination from vehicles, agriculture, and mining; noise contamination from transportation, construction, and industry; and soil contamination which can affect both ecosystems and human health.
3. Different remediation methods are discussed for treating contaminated groundwater, surface water, soil, and sediments in order to remove pollutants and restore environmental quality.
Waterkeeper submission: Review of Ontario’s Environmental Bill of Rights and ...LOWaterkeeper
Waterkeeper submitted these recommendations to the Environmental Commissioner of Ontario in response to the Ministry of the Environment and Climate Change’s call for public comments as part of its review of Ontario’s Environmental Bill of Rights (“EBR”).
The EBR is a uniquely Ontarian, powerful tool to bring citizens, government, and business together to protect the province’s environment. Over the years, issues with the EBR and its implementation have emerged. This review is a welcome opportunity to improve the EBR without undermining or compromising original protections.
One aspect of the EBR’s importance that deserves highlighting is its value to charities. Political activity by charities is limited. Partisan activities are prohibited. Tools such as those created under the EBR are often the sole means by which charities can
participate in government decision-making.
Similarly, the EBR is a safeguard for Ontario residents who may not have geographic, political, social, or professional access to government. As such, this review is an important opportunity to re-assert the authority of the EBR when it comes to decision-making in Ontario.
In addition to these comments, Lake Ontario Waterkeeper / Swim Drink Fish Canada wholly endorses the detailed comments submitted on November 4, 2016 by the Canadian Environmental Law Association (“CELA”).
The Port Authority of New York and New JerseyProposal for .docxssusera34210
The Port Authority of New York and New Jersey
Proposal for Performing an Environmental Impact Statement and Alternatives Analysis for Modifying or Replacing the Lincoln Tunnel Helix
Proposal for Performance of an Environmental
Impact Statement and Alternative Analysis
–
For Modifying or Replacing the
Lincoln Tunnel Helix
Prepared by:
Greenfield Environmental Consulting
Issued: April 21st, 2015
The Port Authority of
New York and New Jersey
Table of Contents:
Section A – Firm Qualifications and Experience ……………………………………....3
A.1 – Governmental Regulations and Laws …………………………………………………. 4
A.2 – Guideline Documents …………………………………………………………………. 7
A.3 – Environmental Permits ……………………………………………………………….. 12
A.4 – NEPA Lead Agency ………………………………………………………………….. 13
A.5 – Environmental Documentation ……………………………………………………….. 14
Section B – Staff Qualifications and Experience ……………………………………..16
B.1 – Organizational Chart ………………………………………………………………….. 17
B.2 – Personal Profiles and Individual Experience …………………………………………. 18
Caulfield, Christopher ……………………………………………………………………….. 18
Greenleaf, Luke ……………………………………………………………………………… 23
Anderson, David …………………………………………………………………………….. 25
Zyndorf, Oren ……………………………………………………………………………….. 27
Schroeder, Alison …………………………………………………………………………… 30
Lombardi, John …………………………………………………………………………….... 32
Mahmud, Anna …………………………………………………………………………….... 34
Martin, Jonathan …………………………………………………………………………….. 37
Mugabel, Abdul ……………………………………………………………………………... 38
Section C – Technical Approach ……………………………………………………..40
C.1 – Preparation of Environmental Impact Statement ……………………………………... 41
C.2 – No-Action Alternative ………………………………………………………………... 43
C.3 – List of Alternatives to be Reviewed ………………………………………………….. 44
C.4 – Environmental Impact Statement Table of Contents …………………………………. 48
C.5 – Data Analysis Sources ………………………………………………………………... 54
C.6 – Safety Measures ……………………………………………………………………..... 56
C.7 – Public Participation …………………………………………………………………… 59
Section D – Cost and Timetable ……………………………………………………...60
D.1 – Project Schedule ……………………………………………………………………… 61
D.2 – Cost Estimate and Budget …………………………………………………………..... 62
Firm Qualifications and Experience
A
Section
A.1
Governmental Regulations and Laws
Law is defined as the principles and regulations established in a community by some authority and applicable to its people, whether in the form of legislation or of custom and policies recognized and enforced by judicial decision. Laws are actually rules and guidelines that are set up by the social institutions to govern behavior. Laws are made by government officials. Laws must be obeyed by all, including private citizens, groups and companies as well as public figures, organizations and institutions. Laws set out standards, procedures and principles that must be followed. Regulations can be used to define two things; a process of monitoring and enforcing legislations and a written instrument ...
The document discusses point source water pollution and regulations. It provides background on key policies and acts related to water quality regulation, such as the Clean Water Act. It also summarizes different regulatory approaches for point sources, including command-and-control regulations and market-based mechanisms like effluent taxes and tradable permit systems. Overall, the document presents an overview of point source pollution issues and the evolution of policies in the United States to regulate industrial and municipal wastewater discharges.
This document provides an evaluation report of Rhode Island's pump-out facilities from 2014. It discusses the background and history of no discharge areas, describes the inspections of 67 facilities, and reports the results. Key findings include: 63 of 68 facilities inspected were functional, with only 1 failing the pump test of emptying 5 gallons in under a minute. The report provides recommendations to improve the program and compliance with protecting Rhode Island waters.
Three key federal laws regulate water and wastewater treatment:
1. The Clean Water Act establishes water quality standards and regulates discharges into surface waters through the National Pollutant Discharge Elimination System permitting program. It also requires the establishment of Total Maximum Daily Loads for impaired waters.
2. The Safe Drinking Water Act regulates public water systems and establishes maximum contaminant levels for over 100 drinking water contaminants. It requires water systems to monitor contaminant levels and report results.
3. States are primarily responsible for enforcing these laws and must adopt regulations that are at least as stringent as the federal standards. Compliance involves obtaining proper permits, meeting discharge limits, monitoring and reporting water quality data, ensuring treatment
This document discusses Simix Surface Solutions' actively green self-cleaning nanoparticle technology. It highlights benefits like reduced maintenance costs, water and energy savings, and improved indoor air quality. The technology uses titanium dioxide and potassium silicate coatings that stay clean longer and remove pollutants. Applying the coatings to buildings, transportation and other surfaces provides disruptive sustainability benefits like multi-year exterior self-cleaning and energy efficient indoor air purification.
Similar to San Antonio Environmental Seminar August 2006 (20)
Infrastructure Challenges in Scaling RAG with Custom AI modelsZilliz
Building Retrieval-Augmented Generation (RAG) systems with open-source and custom AI models is a complex task. This talk explores the challenges in productionizing RAG systems, including retrieval performance, response synthesis, and evaluation. We’ll discuss how to leverage open-source models like text embeddings, language models, and custom fine-tuned models to enhance RAG performance. Additionally, we’ll cover how BentoML can help orchestrate and scale these AI components efficiently, ensuring seamless deployment and management of RAG systems in the cloud.
UiPath Test Automation using UiPath Test Suite series, part 5DianaGray10
Welcome to UiPath Test Automation using UiPath Test Suite series part 5. In this session, we will cover CI/CD with devops.
Topics covered:
CI/CD with in UiPath
End-to-end overview of CI/CD pipeline with Azure devops
Speaker:
Lyndsey Byblow, Test Suite Sales Engineer @ UiPath, Inc.
Unlocking Productivity: Leveraging the Potential of Copilot in Microsoft 365, a presentation by Christoforos Vlachos, Senior Solutions Manager – Modern Workplace, Uni Systems
For the full video of this presentation, please visit: https://www.edge-ai-vision.com/2024/06/building-and-scaling-ai-applications-with-the-nx-ai-manager-a-presentation-from-network-optix/
Robin van Emden, Senior Director of Data Science at Network Optix, presents the “Building and Scaling AI Applications with the Nx AI Manager,” tutorial at the May 2024 Embedded Vision Summit.
In this presentation, van Emden covers the basics of scaling edge AI solutions using the Nx tool kit. He emphasizes the process of developing AI models and deploying them globally. He also showcases the conversion of AI models and the creation of effective edge AI pipelines, with a focus on pre-processing, model conversion, selecting the appropriate inference engine for the target hardware and post-processing.
van Emden shows how Nx can simplify the developer’s life and facilitate a rapid transition from concept to production-ready applications.He provides valuable insights into developing scalable and efficient edge AI solutions, with a strong focus on practical implementation.
GraphSummit Singapore | The Art of the Possible with Graph - Q2 2024Neo4j
Neha Bajwa, Vice President of Product Marketing, Neo4j
Join us as we explore breakthrough innovations enabled by interconnected data and AI. Discover firsthand how organizations use relationships in data to uncover contextual insights and solve our most pressing challenges – from optimizing supply chains, detecting fraud, and improving customer experiences to accelerating drug discoveries.
Maruthi Prithivirajan, Head of ASEAN & IN Solution Architecture, Neo4j
Get an inside look at the latest Neo4j innovations that enable relationship-driven intelligence at scale. Learn more about the newest cloud integrations and product enhancements that make Neo4j an essential choice for developers building apps with interconnected data and generative AI.
Goodbye Windows 11: Make Way for Nitrux Linux 3.5.0!SOFTTECHHUB
As the digital landscape continually evolves, operating systems play a critical role in shaping user experiences and productivity. The launch of Nitrux Linux 3.5.0 marks a significant milestone, offering a robust alternative to traditional systems such as Windows 11. This article delves into the essence of Nitrux Linux 3.5.0, exploring its unique features, advantages, and how it stands as a compelling choice for both casual users and tech enthusiasts.
Cosa hanno in comune un mattoncino Lego e la backdoor XZ?Speck&Tech
ABSTRACT: A prima vista, un mattoncino Lego e la backdoor XZ potrebbero avere in comune il fatto di essere entrambi blocchi di costruzione, o dipendenze di progetti creativi e software. La realtà è che un mattoncino Lego e il caso della backdoor XZ hanno molto di più di tutto ciò in comune.
Partecipate alla presentazione per immergervi in una storia di interoperabilità, standard e formati aperti, per poi discutere del ruolo importante che i contributori hanno in una comunità open source sostenibile.
BIO: Sostenitrice del software libero e dei formati standard e aperti. È stata un membro attivo dei progetti Fedora e openSUSE e ha co-fondato l'Associazione LibreItalia dove è stata coinvolta in diversi eventi, migrazioni e formazione relativi a LibreOffice. In precedenza ha lavorato a migrazioni e corsi di formazione su LibreOffice per diverse amministrazioni pubbliche e privati. Da gennaio 2020 lavora in SUSE come Software Release Engineer per Uyuni e SUSE Manager e quando non segue la sua passione per i computer e per Geeko coltiva la sua curiosità per l'astronomia (da cui deriva il suo nickname deneb_alpha).
AI 101: An Introduction to the Basics and Impact of Artificial IntelligenceIndexBug
Imagine a world where machines not only perform tasks but also learn, adapt, and make decisions. This is the promise of Artificial Intelligence (AI), a technology that's not just enhancing our lives but revolutionizing entire industries.
Why You Should Replace Windows 11 with Nitrux Linux 3.5.0 for enhanced perfor...SOFTTECHHUB
The choice of an operating system plays a pivotal role in shaping our computing experience. For decades, Microsoft's Windows has dominated the market, offering a familiar and widely adopted platform for personal and professional use. However, as technological advancements continue to push the boundaries of innovation, alternative operating systems have emerged, challenging the status quo and offering users a fresh perspective on computing.
One such alternative that has garnered significant attention and acclaim is Nitrux Linux 3.5.0, a sleek, powerful, and user-friendly Linux distribution that promises to redefine the way we interact with our devices. With its focus on performance, security, and customization, Nitrux Linux presents a compelling case for those seeking to break free from the constraints of proprietary software and embrace the freedom and flexibility of open-source computing.
Essentials of Automations: The Art of Triggers and Actions in FMESafe Software
In this second installment of our Essentials of Automations webinar series, we’ll explore the landscape of triggers and actions, guiding you through the nuances of authoring and adapting workspaces for seamless automations. Gain an understanding of the full spectrum of triggers and actions available in FME, empowering you to enhance your workspaces for efficient automation.
We’ll kick things off by showcasing the most commonly used event-based triggers, introducing you to various automation workflows like manual triggers, schedules, directory watchers, and more. Plus, see how these elements play out in real scenarios.
Whether you’re tweaking your current setup or building from the ground up, this session will arm you with the tools and insights needed to transform your FME usage into a powerhouse of productivity. Join us to discover effective strategies that simplify complex processes, enhancing your productivity and transforming your data management practices with FME. Let’s turn complexity into clarity and make your workspaces work wonders!
HCL Notes und Domino Lizenzkostenreduzierung in der Welt von DLAUpanagenda
Webinar Recording: https://www.panagenda.com/webinars/hcl-notes-und-domino-lizenzkostenreduzierung-in-der-welt-von-dlau/
DLAU und die Lizenzen nach dem CCB- und CCX-Modell sind für viele in der HCL-Community seit letztem Jahr ein heißes Thema. Als Notes- oder Domino-Kunde haben Sie vielleicht mit unerwartet hohen Benutzerzahlen und Lizenzgebühren zu kämpfen. Sie fragen sich vielleicht, wie diese neue Art der Lizenzierung funktioniert und welchen Nutzen sie Ihnen bringt. Vor allem wollen Sie sicherlich Ihr Budget einhalten und Kosten sparen, wo immer möglich. Das verstehen wir und wir möchten Ihnen dabei helfen!
Wir erklären Ihnen, wie Sie häufige Konfigurationsprobleme lösen können, die dazu führen können, dass mehr Benutzer gezählt werden als nötig, und wie Sie überflüssige oder ungenutzte Konten identifizieren und entfernen können, um Geld zu sparen. Es gibt auch einige Ansätze, die zu unnötigen Ausgaben führen können, z. B. wenn ein Personendokument anstelle eines Mail-Ins für geteilte Mailboxen verwendet wird. Wir zeigen Ihnen solche Fälle und deren Lösungen. Und natürlich erklären wir Ihnen das neue Lizenzmodell.
Nehmen Sie an diesem Webinar teil, bei dem HCL-Ambassador Marc Thomas und Gastredner Franz Walder Ihnen diese neue Welt näherbringen. Es vermittelt Ihnen die Tools und das Know-how, um den Überblick zu bewahren. Sie werden in der Lage sein, Ihre Kosten durch eine optimierte Domino-Konfiguration zu reduzieren und auch in Zukunft gering zu halten.
Diese Themen werden behandelt
- Reduzierung der Lizenzkosten durch Auffinden und Beheben von Fehlkonfigurationen und überflüssigen Konten
- Wie funktionieren CCB- und CCX-Lizenzen wirklich?
- Verstehen des DLAU-Tools und wie man es am besten nutzt
- Tipps für häufige Problembereiche, wie z. B. Team-Postfächer, Funktions-/Testbenutzer usw.
- Praxisbeispiele und Best Practices zum sofortigen Umsetzen
GraphSummit Singapore | The Future of Agility: Supercharging Digital Transfor...Neo4j
Leonard Jayamohan, Partner & Generative AI Lead, Deloitte
This keynote will reveal how Deloitte leverages Neo4j’s graph power for groundbreaking digital twin solutions, achieving a staggering 100x performance boost. Discover the essential role knowledge graphs play in successful generative AI implementations. Plus, get an exclusive look at an innovative Neo4j + Generative AI solution Deloitte is developing in-house.
UiPath Test Automation using UiPath Test Suite series, part 6DianaGray10
Welcome to UiPath Test Automation using UiPath Test Suite series part 6. In this session, we will cover Test Automation with generative AI and Open AI.
UiPath Test Automation with generative AI and Open AI webinar offers an in-depth exploration of leveraging cutting-edge technologies for test automation within the UiPath platform. Attendees will delve into the integration of generative AI, a test automation solution, with Open AI advanced natural language processing capabilities.
Throughout the session, participants will discover how this synergy empowers testers to automate repetitive tasks, enhance testing accuracy, and expedite the software testing life cycle. Topics covered include the seamless integration process, practical use cases, and the benefits of harnessing AI-driven automation for UiPath testing initiatives. By attending this webinar, testers, and automation professionals can gain valuable insights into harnessing the power of AI to optimize their test automation workflows within the UiPath ecosystem, ultimately driving efficiency and quality in software development processes.
What will you get from this session?
1. Insights into integrating generative AI.
2. Understanding how this integration enhances test automation within the UiPath platform
3. Practical demonstrations
4. Exploration of real-world use cases illustrating the benefits of AI-driven test automation for UiPath
Topics covered:
What is generative AI
Test Automation with generative AI and Open AI.
UiPath integration with generative AI
Speaker:
Deepak Rai, Automation Practice Lead, Boundaryless Group and UiPath MVP
Climate Impact of Software Testing at Nordic Testing DaysKari Kakkonen
My slides at Nordic Testing Days 6.6.2024
Climate impact / sustainability of software testing discussed on the talk. ICT and testing must carry their part of global responsibility to help with the climat warming. We can minimize the carbon footprint but we can also have a carbon handprint, a positive impact on the climate. Quality characteristics can be added with sustainability, and then measured continuously. Test environments can be used less, and in smaller scale and on demand. Test techniques can be used in optimizing or minimizing number of tests. Test automation can be used to speed up testing.
Climate Impact of Software Testing at Nordic Testing Days
San Antonio Environmental Seminar August 2006
1. BMPs and Regulations for Cosmetic Mobile Power Pressure Washing * San Antonio Water System by Robert M. Hinderliter Environmental Chairman, United Association of Contract Cleaners Website: www. UAmCc.org President, Delco Cleaning Systems of Fort Worth 2513 Warfield Street, Fort Worth, Texas 76106-7554 Phone: 800-433-2113, Fax: 817-625-2059 www.dcs1.com , www.pressurewash.com , www.ikeca.com Note: The products and/or methods shown or depicted in this seminar may be covered by U.S. Letters of Patent . Copyright 2006, Delco Cleaning Systems of Fort Worth, All Rights Reserved (8:15 or 1:15)
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3. Reality of Enforcement What Regulators are actually enforcing. What the Contract Cleaner actually needs to know. What Contract Cleaners are actually doing How Contract Cleaners can be Profitable
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6. Maximum Fines/day/violation for OFF PROPERTY DISCHARGE : City--$2,000, States--$10,000, EPA--$27,500 Civil EPA--$20,000 & 4 years in jail Criminal Note that the EPA has ‘Civil’ and ‘Criminal’ Penalties.
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10. 4. “ Point Source ” means any discernible, confined, and discrete conveyance, including but not limited to, any pipe, ditch, channel, tunnel, conduit, well, discrete fissure, container, rolling stock, concentrated animal feeding operation, landfill, leachate collection system, vessel or other floating craft from which pollutants are or may be discharged. 5. “ Non-Point Source” : Any source of pollution not associated with a distinct discharge point. 6. AHJ : Authority Having Jurisdiction. 7. POTW : Public Owned Treatment Works (Sewer Plant) 8. MS4 : M unicipal S eparate S torm S ewer S ystem (Storm Sewer Piping. Also includes street gutters and drain ditches along the highway if they empty into waters of the state.)
11. 9. BMP : Best Management Practices means schedules of activities, prohibition of activities, maintenance procedures, and other management practices to prevent or reduce the pollution of the MS4 and waters of the United States. BMPs also include treatment requirements, operating procedures, and practices to control plant site runoff, spillage or leaks, sludge or waste disposal, or drainage from raw material storage. 10. Hazardous Waste may be corrosive, reactive, or toxic. 11. 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. 12. Illicit Discharge: Any discharge to an MS4 that is not composed entirely of storm water with some exceptions.
13. Federal Water Pollution Control Act of 1972 o The Federal Water Pollution Control Act of 1972 set the basic structure for regulating discharges of pollutants to waters of the United States and gave the CWA it current form. And established a national goal that all waters of the U.S should be fishable and swimmable. This is the act that first caused Municipalities to do an Environmental Assessment of themselves. Most Regulators refer to the CWA as being passed in 1972. o URL: http://www.epa.gov/region5/water/cwa.htm
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16. As long as the water in the child’s wading pool is higher that the wash water on the outside of the wading pool it will seal off the storm drain. Note the window screen around the bottom of the sump to filter out debris, sand, & dirt. Does not give a real professional image but it works!
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18. November 1991 . Dan and John Cassello in Connecticut start washing Coca Cola Trucks on a canvas tarp over a vinyl tarp. Berms on the side were made of PVC sewer pipe and rolled up tarp across the ends. Note the sump pump in the far right hand corner. The canvas trap was very heavy when wet.
24. Who is an Environmentalist? Everybody is an “Environmentalist”! However, how one interprets that is usually based on how it affects their “economic revenue stream” (income, wages, business revenue). An Environmental Regulator brought this information to my attention. Example: A large segment of the “Coin-op car wash industry” believes that home owners should not be exempt for car washing discharge to storm sewer as this creates a large source of pollution to our storm sewers. This also holds true for charities (churches, girl scouts, boy scouts, etc). Because of Political Activity by the Coin-Op Car Wash Association (with a $500,000.00 budget) the San Diego Regional Water Quality Control Board banned charity washing during February of 2001 .
25. Typical Power Washing Pollution Typical pollutants in waste washwater that Mobile Power Wash Contractors typically encounter are: Detergents Fats Oils Grease Gasoline Solids Solvents Heavy Metals Herbicides Insecticides Pesticides Total Dissolved Solids Anti-Freeze Emulsified Oil High pH levels caused by Acid Brighteners Fertilizers
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27. The waste stream can also be greatly affected by the season. For example in the winter it is common to apply salt, sand, or other deicing materials to the roads. Mobile Power Wash Cosmetic Cleaners need to avoid Hazardous waste if at all possible because POTWs generally do not accept Hazardous Waste.
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30. NPDES for Phase II For Municipalities & Urban Areas (UAs) whether incorporated or unincorporated were due March 10, 2003 For all UA's 50, 000 to 100,000 population Under 50,000 population if notified by the AHJ because of a significant environmental problem. A 5 year plan was required, filings were done 2003, 2004, & 2005, delayed was due to 9th Circuit Court of appeals ruling. “Getting Step with Phase II Workshops” were conducted by the EPA for Municipalities and UAs during 2005 & 2006.
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34. Applications for Phase II NPDES permits are due March 10, 2003 from owners of all MS4s located in urban areas (UA’s) with total populations of at least 50,000 and population densities of at least 1,000 persons per square mile. (These MS4s are automatically required to have permits under Phase II). Note: MS4s located in areas with populations of at least 10,000 and population densities of at least 1,000 persons per square mile may be required to obtain a Phase II NPDES permit at the discretion of the EPA or state permitting authority. MS4s located in these less populated areas will have 180 days to file an application from the time they are notified that they are required to obtain a Phase II permit. (Ref: http://www.epa.gov/npdes/regulations/phase2.pdf)
35. These regions may do their NPDES Permits by themselves, combine or hire outside agencies to apply for their NPDES Permits. Notice in the Annual Report for the City of Fort Worth that Co-Permittees are Tarrant County Water District and Texas Department of Transportation, Fort Worth District.
36. A city is responsible for the combined total discharge of their storm water per their NPDES Permit. It is not uncommon for municipalities to give exemptions to some companies. Some (including Kitchen Exhaust) contract cleaners have been able to get these exemptions and discharge wash water to the storm drains. These discharges to storm drain have been insignificant when combined with the total storm drain discharge of the municipality. Note: These discharge permits are not a release from liability for damage to the storm drains from these discharges!
37. As a general rule NPDES Permits are not practical for Mobile Power Wash Contract Cleaners. The average time to obtain this type of permit has been 18 months and they do not apply in Municipalities.
38. Cities can either treat all of their sanitary and storm water or go the point source of the pollution and require remediation before discharge to sanitary sewer. St. Louis, Indianapolis, Sacramento, and San Francisco are examples of cities that treat all of their wastewater in certain portions of the cities through their Combined Sewer System. Most cities go to the point source and require remediation before discharging to the sanitary sewer. It is significantly less expensive for the cities to require point source remediation than to remediate the pollution at their POTW’s.
39. One of the key elements of the NPDES Permit for the municipalities requires the cities to create and enforce an ordinance, which bans pollutant discharges to the storm drain . The city of Fort Worth ordinance reads: “A person commits an offense, punishable by a fine, if he introduces or causes to be introduced, any discharge to the storm drain system that is not entirely composed of Stormwater.” The EPA did grant certain exemptions to this rule and the various cities have also enacted specific exemptions for their area.
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41. If anyone offers to sell you an EPA approved product (like detergent) ask to see the documentation. I have never had a company be able to produce this documentation for routine maintenance washing. The EPA does not have an approval process for Products, Processes, or Technology.
42. EPA set the standards for cities and states thru their National Pollution Discharge Elimination System Program (NPDES Permits).
43. State’s Responsibilities for Stormwater discharge The EPA can delegate many of the permitting, administrative, and enforcement aspects of the CWA to the states. Then a state becomes a “ Designated State ” (Texas is a designated state). The EPA is still responsible for oversight of state programs. That is because Congress feels that local regulators who know the community can administer the CWA locally better than the EPA can from Washington DC.
44. Cities Responsibilities for Stormwater Discharge Each city can decide what products, processes, and technology they are going to use to meet EPA Guidelines. This means the rules will vary from city to city and sometimes from site to site within the same city. Most Metropolitan areas will have different rules for each city! This is mainly caused by: jealousy between regulators, different interpretations of the CWA, & different technologies and capabilities of the POTWs.
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47. Most of the time Contract Cleaners will be dealing with the local municipality for discharge to their sanitary sewer system connected to their POTW. Usually Kitchen Grease Cleaners will discharge to grease traps on site. Check with the chef to follow this practice. It is not unusual for the Kitchen Exhaust Cleaner to discharge the grease trap under the Risk Management Scenario without asking. Truck Washing and Flat Work Contract Cleaners will be discharging to sand traps when available, like at wash bays.
48. The regulating line of authority is Federal, State, Regional, County, and city. This means that if a city gives you a permit to discharge wash water to storm sewer and you contaminate State waters you are liable to the state! If you get a discharge permit from the state and contaminate federal waters you are liable to the EPA! Note: a discharge permit does not relieve you from liability for contamination clean up.
49. Mobile Power Wash Operators must deal with the City, County, Regional or State Governments who must deal with the EPA for their NPDES permits which specify their Discharge Limits. In most cases this is going to be the local Municipality, but not always. Oregon, South Carolina, & Wisconsin have state programs and California and Florida have regional programs. Kansas City, San Francisco, and Sacramento have metropolitan area programs.
50. Who do you contact at your local municipality for information and permits for Environmental Power Washing Procedures in their city? The problem is that city governments were established before the Clean Water Act was passed. Because there is no standard structure for city governments there are several departments that may be in charge of Power Washing Activities depending on what the government structure is. If the city government has been updated then there will be an Environmental Department. Typically contractors get caught up in the referral system that is a continuous loop with no end. (8:45 or 1:45)
51. In some Phase II Urban Areas the Fire Department is in charge of Fires Suppression, Emergency Medical Treatment, Storm Water Issues, plus more. It is not uncommon for the Fire Department to be a Voluntary Agency.
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56. A lot of AHJs state that their interpretation and enforcement of the CWA as being “fact” rather their interpretation and enforcement standard. It is not unusual for this to vary from one regulator to the next within the same department. This has caused some confusion within the Power Wash Contractor Community on exactly what the CWA is and its application to specific situations. Of course if one is receiving a citation at that moment that is the standard! AHJ Variation
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58. Effectiveness of the Citation If a citation is given to the Company instead of the contractor it is more effective. It keeps the company from merely changing contract cleaners and puts the company on notice to do things properly.
59. NPDES Permit Violation A violation of their NPDES Permit because of detergents will move waste wash water discharges to the Storm Drain to the top of the list. This has happened in several cities. Regulators will rarely fine Mobile Power Wash Contract Cleaners the maximum but will make certain that the operator does not benefit financially while breaking he law.
60. Environmental Power Washing Items Risk Management Risk Management does not mean zero risk. You will never reach zero risk. What you need to do is reduce your risk as much as possible and still be economically profitable. Almost everyone exceeds the speed limit by a small amount where they do not think that they will receive a traffic ticket. And most of the time they do not get a traffic ticket, but not always! This is risk management. Bankruptcy is now a Risk Management Tool!
61. Risk Takers Usually Government Employees are not risk takers . And usually Entrepreneurs are risk takers . Government Employees survive by not taking risks or being noticed. Do not expect regulators to rule in your favor or interpret the regulations in your favor if it requires a risk on their part. Dilution is the solution to the pollution. The CWA says not to do this, but I have had regulators tell me to do it. Which I did under “Risk Management” scenario.
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63. The longer you recycle with the same water the dirtier (more contaminated) it will become. Therefore, you will have to rinse with fresh water and limit your recycle time. Recycling units that will deliver “Drinking Water Quality” discharge water are very expensive and not economically viable for Mobile Wash Contract Cleaners at the present time. Recycle units need to deliver 5 to 20 micron filtered water in order for the water to be recycled through high pressure pumps. This needs to be through a series of filters as a 5 micron filter will immediately stop up with unfiltered power wash wastewater.
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65. Note the berm for wash water containment and the sump pump pit in the lower left hand corner of the wash pad.
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67. Washwater Control Devices Water Control Devices: Sump pumps; wet/dry Vac with and without sump pumps, vacuum sludge filtering systems; Vacu-Booms; Portable Dams; Drain Covers; Portable Vinyl Wash Pits; Portable Vinyl Wash Pads, surface cleaners with vacuums attached for water capture, plumbers drain Plugs, sand bags, rubber mats, temporary berms, water Dykes.
68. A Portable Dam sealing off a storm drain, and a sump pump with a window screen filter for discharge to a sand trap.
69. A small hand held surface cleaner with vacuum attachment. Imagine two pie pans separated by about ¼” to form a vacuum chamber with pick up around the edges. The tube at the top of the surface cleaner is the vacuum connection and the trigger gun on the left is from your pressure washer.
70. A close up of the Steel Eagle Hand Held Surface Cleaner in the previous slide.
71. A 24 inch vacuum recovery surface cleaner. Note the 4 vacuum connections on top of the surface cleaner. The pressure washer trigger gun hooks ups up at the top left of the picture just out of view.
72. Hot Water Washing Detergents and Hot Water are emulsifiers . The discharge is considered Special Waste . The Special Waste from washing activities will have to be added to any other Special Waste that your customer is generating. This Special Waste requires reporting if it exceeds a threshold amount. The threshold amount varies from state to state (for Texas and most other states it is 220 pounds per month). To date I am not aware of any contractor that has be affected by this requirement. The EPA does not define Hot Water . Some regulators define it as any water that is elevated in temperature from the tap or outlet. This temperature can vary greatly. In the City Fort Worth we were able to define Hot Water as any water above 110 F.
73. Cold Water Washing In most areas cold water washing with no chemicals is considered no worse than a rain event. Therefore cold water washing can be discharged to the storm drain if oil and grease areas are precleaned, and the discharged wash water is filtered through an oil absorbent filter to remove any oil sheen, and a screen to remove sand & debris. Discharging wash water from a sump pump to a Sand Trap.
74. A window screen has been installed in the drain above to catch the debris, sand, rocks, and dirt. Some municipalities will accept this amount of remediation.
75. Here a window screen and oil absorbent booms have been installed before the drain. Some municipalities will accept this amount of remediation before their drains. The oil absorbent booms will remove the free oils and greases.
76. An oil absorbent boom before a vacuum boom with a portable dam after the vacuum boom to catch accidental discharges. The oil absorbent boom removes the oil sheen and free oil and grease.
77. Note the the oil sheen is only before the oil absorbent boom!
78. Note the the oil sheen is only before the oil absorbent boom!
79. Common cold waterpower booster : zero degree rotating nozzles, and surface concrete cleaners. This zero degree rotating nozzle is used for cleaning vertical grease exhaust shafts (ducts) with either zero or 15 degree nozzles with hot water and chemicals.
80. Zero Degree Rotating Nozzles. Commonly used by Kitchen Exhaust Cleaners with high pressure hot water and chemicals to clean Kitchen Grease Exhaust hoods, ducts, and equipment. Used by Surface Cleaners with high pressure cold water for exterior building and surface cleaning without chemicals for discharging into the storm drain. Precleaning oil and grease spots is usually required.
81. Two examples of surface cleaners with without water recovery capability. Normally these units will handle water up to 5 to 8 GPM, 150 to 200 F, 2000 to 4000 PSI. These units have to be hooked up to a high pressure washer. They are an accessory or tool to increase the production and capability of your pressure washer.
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84. Waste materials from dry cleanup such as absorbents, paint chips, etc. may often be disposed of in the trash (dumpster). In general, you must generate less than 220 pounds of a particular type of waste each month to quality to use these “Conditionally Exempt Small Quantity Generator” (ECSQG) programs.
85. Detergents and Acids Biodegradable detergents are not OK for discharging to the Storm Drain (Sewer) . They increase the BOD (biological oxygen demand) of the water, which may kill living organisms. “Biodegradable” does not mean non-toxic . The Regional Director of EPA Region 6 gave me the following example: A dead horse in a stream is biodegradable but it will kill the stream with all of the decay! The Term “Biodegradable” simply means that the product will not harm bacteria in the sewage treatment plant (POTW) and that it breaks down faster than more conventional products.
86. Phosphate Detergents are fertilizers. In water they cause the algae and moss to grow, which depletes the oxygen supply, causing the fish to die. Neutralize acid cleaners with: baking soda (sodium bicarbonate), soda ash (sodium carbonate), alkaline or caustic detergents & bleach. Use common house hold products if possible if an accidental discharge occurs resulting in observation by Regulating Authorities.
87. Truck Washing For Truck Washing Evaporation and drag-off normally account for 20 to 50% of water loss mainly depending on how warm or hot the ambient temperature is. The washing of Hauling Compartments (Interior of trailers and tankers) should be limited to non-hazardous inert and biodegradable materials.
88. Wastewater Remediation Wash Water Filtration, Remediation Devices: Storm Sewer Drain Screens; Oil Absorbent Pillows, Booms & Pads; Vacuum Systems with Filtration; Pretreatment Units; Limited Recycling Units; Total Recycling Units, flocculation, absorbing media, etc.
89. Mobile Power Wash Recycling Recycling Equipment and Portable Wash Pads are like the ABCs of the alphabet. They are but two tools for Environmental Power Washing. Generally the most expensive tools to use. Other avenues are generally less expensive and more cost effective. Contracts often go to whoever can capture the wash water in the least expensive manner and direct it to Sanitary Sewer. If you recycle long enough the wash water will become hazardous waste. You will need to have a “ Hazardous Waste Haulers Permit ” and dispose of your wash water as “ Hazardous Waste ”. You can no longer discharge to the Sanitary Sewer.
90. Presently most states (including Texas) do not regulate used non-hazardous wash water. Note: some areas of California do regulate used wash water transportation. Also Michigan regulates the transportation of used wastewater for amounts of over 55 gallons. If you are transporting a regulated waste every load will have to be manifested and you will have to obtain the proper permits. If the owner of the waste and the carrier are the same registration is not required. Remember your customer is the owner of the waste.
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92. Oil-water separators cannot be used for treating water-soluble chemicals such as anti-freeze and solvents, and detergents that emulsify oil, or the emulsified oil itself. A lot of POTWs discourage the use of recycle units because they concentrate the waste. Because of the heavy oil and grease load from Kitchen Grease Exhaust Cleaning it is generally not competitive to recycle your waste water from this activity. It is generally best to dispose of your waste water into the grease trap on site. Heavy deposits of grease should be appropriately collected (scraping for example) and deposited into a grease container on site if possible. Note: do not deposit grease into the garbage dumpster.
93. Avoid Hazardous Waste A lot of Contractors limit their operations to cosmetic cleaning and avoid: degreasing, two-step chemical cleaning, aluminum brightening, battery cleaning, & the washing of chemical trucks that may produce Hazardous Waste . Treated wood shingles are often treated with a toxic material. Treated shingles should be dry cleaned only. Runoff from cleaning may be toxic to plants in a landscaped area and should never be discharged to the storm drain or sanitary sewer.
94. Wastewater Discharge Discharge wastewater to Sanitary Sewers as this is the most economical location. If it is not available, then discharge to a Commercial Waste Disposal Facility. This trailer contains a waste water holding tank and Filter Cleaning Tub. The waste water was hauled to disposal site on location away from the lake.
95. A Filter Tub was used to clean the Hood Grease Exhaust Filters in. The waste water was extracted with a Vacuum Sludge Filtering System and discharged to the holding tank above, about 100 feet away.
96. Waste Water was discharged to the restaurant’s septic system by gravity flow under supervision of the chef.
97. Normally you should never dispose wash water to storm drain (note: because so many people confuse the tems “Sanitary Sewer” and “Storm Sewer” it recommended that the tem “Storm Drain” replace “Storm Sewer”.
98. The discharge to the Municipal Sanitary Sewer Systems by Contract Cleaners is insignificant when compared to the total volume that a Municipality processes. When requesting permission to discharge to the Sanitary Sewer always give them an estimate of your volume. Usually “ Hazardous Waste” cannot be discharged to the POTW. A lot of POTWs require contractors that do kitchen grease exhaust cleaning, acid cleaning, two-step chemical cleaning to batch process their wash water and neutralize it before discharging to the sanitary sewer. No off property discharge hazards: 1) soil contamination, ground water contamination, and air contamination. May require soil remediation when property is sold or ground water remediation if contamination becomes known.
99. Sewer Types: Sanitary, Storm, and Combined (sanitary and storm sewer are in the same pipe). Sanitary and combined sewer pipes discharge to the POTW (Public Owned Treatment Works, i.e. sewer plants). Storm drain (sewer) pipes discharge directly to the lakes, rivers, and streams with no remediation. Most outside drains are storm drains and most inside drains are Sanitary Sewer drains. But not always! If you are unsure of whether a drain is a Sanitary Sewer Drain or a Storm Drain ask the Authority in Charge. Sometime this information has been lost over time. Dye or Smoke test may have to be done in order to determine where the drain discharges. In restaurants most floor drains in the kitchen, mop or slop sinks, and disk washing sinks are connected to the grease trap. This is where your waste water should be discharged to. Do not discharge any wastewater into a drain or sewer system if you do not know where it leads and empties into.
100. Discharge wash water to: Sand traps, grease traps, oil/water separators, clarifiers, Utility Sinks, Clean-outs, inside floor drains, commodes, and sinks which are connected to the Sanitary Sewer. They are located at: Truck Wash Bays, Coin-op Car Wash Bays, Automatic Car Washes at Gas Stations, restaurants, and Clean Out Stubs on the outside of buildings where they are connected the Sanitary Sewer. Avoid disposing of your wash water to septic systems or injection wells if possible. These discharge locations are being phased out as of January 1, 2008. You should obtain the permission of the “discharge location owner” who is probably the Waste Generator before discharging your used wash water on the job site. For kitchen exhaust cleaning this would be the chef. POTWs are designed to handle sewage related wastes and wastewater, not industrial wastes containing chemicals, metals, oil, etc. (9:15 or 2:15)
104. Storm Drain the empty directly into Lake Tahoe Beautiful Lake Tahoe
105. Discharging into Manholes is strictly forbidden no matter where they are located. It is not only dangerous to remove the lid from a manhole but it is also illegal in most cities. Manholes are City Property! Washington, DC had a problem with explosive gases building up in the sewers. There would be random explosions blowing off the manhole covers. Sometimes electrical lines and other wiring are in the storm sewers. Caution Do Not Remove Storm Sewer Covers, they are city property.
106. Pretreatment varies for discharging to sanitary sewer from none to extensive and can change at anytime. Most changes in discharge limits are a result of an EPA Fine for violations of an NPDES permit. Caution Do Not Remove Sanitary Sewer Covers, they are city property
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108. Wash Water Disposal Options: Wash Water Hauling to proper disposal facility; Direct Discharge Sanitary Sewer; Pretreatment Units then discharge to sanitary sewer; Limited Recycling Units; Total Recycling Units; wash water capture and discharge to sanitary sewer without remediation. Note: Some municipalities prefer that you do not recycle your wash water because recycling concentrates the waste. Some POTWs have “Trucked Wastewater Disposal Sites” to received “Trucked Wastewater”. These sites may be at the POTW or remote locations. You have to make the phone calls in your market area (survey) to see what your disposal options are.
109. An example of waste water capture and proper disposal. Not Rocket Science! Think, Imagine, Conceive, Action
110. For Kitchen Exhaust Waste Water Capture starts with draping the hood and funneling the water into a 55 gallon barrel. Note the protection of the ranges and fryers.
111. A hole is cut into the plastic sheeting to allow access to the bottom of the kitchen exhaust hood for high pressure hot water cleaning. In this case 5 gpm at 200 F.
112. Draping a for a roof fan cleaning. Discharge to Sanitary Sewer.
113. Scott Hyde showing the grate in the bottom of a Filter Tub for power washing Grease Exhaust Filters. The grate sets about 4 off the bottom of the Filter Tub.
114. Power Washing grease exhaust filters in the filter tub. Note the drain hose at the bottom of the tub draining wash water by gravity flow into the grease trap which is connected to the sanitary sewer.
115. Metals like lead and zinc are sometimes found in the outlet water from the tap in higher concentration than the POTW allows! Also Cadmium and Zinc are found in vehicle cleaning compounds in higher concentrations than some POTW allows. No visible oil sheen on the surface of water means 15 mg/l or less of oil.
116. Sludge Collection The least expensive method of collecting your dirt, sand, and debris is right off of your wash surface before entering your wash water pumping equipment. A $20.00 broom and shovel is an inexpensive method of picking up dirt and debris. The lower the level of technology used to collect the sludge the less expensive the collection is . The cheapest place to collect dirt, sand and sludge is right off the wash pad or out a grease duct, fan, or hood.
118. Sludge Disposal Options Sludge disposal options: Put into a Sand Trap; let dry then put into a Dumpster, put the sludge in a 55 gallon drum and have a licensed sand trap service haul the sludge to a proper disposal site, leave with the customer for disposal. The sludge belongs to your customer. Let the customer haul his own sludge to a proper disposal site. You cannot haul it for him unless you are licensed waste hauler. The Waste Disposal site will manifest every load, and if the generator of the waste and the hauler are not the same a registration waste transporter number is required. This is also true of regulated wastewater hauling. You are required to keep the manifest records for 3 years.
119. For Kitchen Exhaust Cleaning collected grease should be disposed into a grease container (grease dumpster if available), and the waste water into the grease trap. Check with the chef to make sure this is acceptable.
120. Let the dirt, sand, and sludge dry before disposal to a dumpster. Presently landfills cannot accept liquid waste. In Texas (and most other states) you can put 220 pounds of dry sludge in your dumpster per month. The sludge should be about as dry as damp sand, like on a beach. If you put the sand in a paint filter no water would run out of it. Remember, if the customer is generating other special waste the dirt and sludge will have to be added to this total. The customer should get permission from their refuse company to follow this procedure.
121. Hydrocarbon Disposal Hydrocarbon disposal: for cosmetic cleaning there is none, all of the oil is absorbed by the sludge: waste oil-recycling company (Safety Clean), leave with the customer. Caution: some state classifies used oil as hazardous waste.
122. Used Oil The EPA has classified used oil (hydrocarbons) as non-hazardous if it is destined for recycling, re-fining, reprocessing or burned for energy recovery . Therefore, you should dispose of your used-oil in the aforementioned manner.
123. Hazardous Waste It should be noted that the states of California, Arizona, Massachusetts, Minnesota, Missouri, New Jersey, New York, Rhode Island, South Carolina and Vermont regulate used oil as a hazardous waste. Special Waste Also some states designate used oil as a special waste and have rules more stringent than those of the EPA, these are Arizona, Illinois, Maine, Michigan, Minnesota, Washington, Wisconsin, and Wyoming . Also some counties have even more rules concerning used oils.
124. Almost No Hydrocarbons For Mobile Power Washing that is limited to cosmetic cleaning of vehicles and flat work there is very little hydrocarbons accumulated. In fact the dirt and sludge will absorb almost all of the free hydrocarbons.
125. Reportable Quantity In Texas waste oil spills of 9 gallons or more will require reporting to the Texas Commission on Environmental Quality (TCEQ). Therefore, leave the hydrocarbons with your customer or only transport small quantities.
126. Hydrocarbon Disposal Facilities You will need to contact your local waste oil recycling company to see what their requirements are for disposing of your waste oil. Generally there will be an extra charge for oil with dirt, sand, and water in it. Find these companies in your yellow pages under OILS-RE-FINED and OILS-WASTE.
127. What is Oil? The EPA stresses that it defines “oil” to include not only crude oil and petroleum products but also non-petroleum oil, such as vegetable and animal oil. (Ref: EPA Enforcement Alert Volume 3, Number 8. Currently Available at http://www.epa.gov/Compliance/resources/newsletters/civil/enfalert/vol3num8.pdf. You may also sign up for email copies of Enforcement Alert at http://www.epa.gov/Compliance/resources/newsletters/civil/enfalert/).
128. Waste Ownership Customer is owner of the waste from cradle to grave. Only Oregon has rules letting the contract cleaner be responsible for disposal of the waste.
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131. House Washing Exemption Note: The EPA exempts residential car washing (as long as it is not a significant contributor of contaminates) from the storm water rules but does not address other washing activities like house or deck washing. In most areas there is no enforcement of the “No Off Property Discharge” rule for house washing or deck washing and sealing. This is because it is seldom done. Direct your waste water to landscaping for bioremediation.
132. Landscaping Discharge When routing wash water to landscaping, check the slope and area to be sure to avoid runoff into a street, gutter, or storm drain. If the soil is very dry, wet it down thoroughly before discharging so that wash water will soak into the soil instead of running off to the street, gutter, or storm drain. Michigan limits landscape discharge in the above scenario to 1,000 gallons per month per acre. You should also limit you discharge to make sure that it does not reach the ground waters through percolation.
133. Discharge to Stormdrain should be free of visible foam and Oil Sheen. Discharge to surface waters must be treated for solids removal. This can be accomplished by filtration, or by directing wash water to a settling basin, like a tank or low spot where the water stops flowing. Discharge to the storm drain should be filtered with an oil absorbent boom or an oil/water separator.
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135. When washing at a construction site usually a “silt fence”, Straw Bern or other similar structure is required. This “silt fence” should also meet the requirements for solids removal from your wash water at construction sites. (Construction Site Storm Water Discharge Permit - BMPs)
140. Compliance and Approval What you need: Letter of approval for Wash Procedures and Letter of Acceptance of your waste from your local regulation authority where you are washing. In most metropolitan areas this will mean a permit from each city you are washing in! Jealousy Between Regulators. In a lot of metropolitan areas the regulators do not respect the competency of each other and there is jealousy between cities. If you try to get approval of your washing procedures by showing city “B” that you already have approval in city “A” expect the requirements to be more restrictive.
141. Drain Plugs It is illegal to install a “Drain Plug” in Municipal Sewer Systems. You could potentially damage the Sewer Systems. Inflatable drain plugs are capable of exerting a lot of force and can damage sewer piping.
142. Presently a lot of Contract Cleaners will get approval for their wash procedures is a major metropolitan city then follow those procedures in other areas without getting the approval of each local regulating authority (Risk Management). It is not uncommon for the homeowner not to be required to capture his wash water from vehicle washing but the contract cleaner is required to capture his wash water.
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144. Notifying Regulating Authorities Regulating Authorities are not required to investigate every complaint. They are not required to keep the informant confidential. One contract cleaner was particularly upset when he turned in his own customer for refusing to upgrade to Environmental Power Washing and they found out who did it! He lost the account. If regulating authorities are going to be able to write a violation based on your complaint you will have to be willing to testify in court. You can protect yourself by making a anonymous complaint . If enough information is given they will still investigate!
145. Benefits of Compliance Of course the biggest benefit in compliance is doing your part in cleaning up the Environment and avoiding fines. Mobile Power Wash Operators who are willing to invest time, money, and equipment in order to offer Environmental Washing Services and obtain the Certification letters from regulating authorities are receiving a tremendous competitive advantage. It is not unusual for these operators to double or triple their business in a year. Their first advantage generally will be increased enforcement of the Clean Water Act for no off property discharge. Since they are the only one that has an approved procedure guess who gets recommended. Of course this exclusive position will only last until someone else gets approval, but by that time you should have already established your reputation.
146. Another problem for some Environmental Contract Cleaners is that enforcement has been like a yoyo in some locations. Enforcement varies from heavy to non-existent then some customers go back to unregulated power washing to save cost. Illegal discharging of wash water is not a high priority item for most municipalities unless they have received a violation from the EPA.
147. Greater Kansas City Metropolitan Area issues “Recommended Pollution Prevention Practices for the Mobile Power Wash Industry” with the following statement: “An NPDES permit is required for discharges onto a parking lot, regardless of whether water leaves the property (into a drainage ditch, storm sewer, river, etc.) or not”. This is the only case I know of where the “No Off Property Discharge Rule” comes under regulating authority. The complete document is at: http://www.dcs1.com/del/delpg5/KCbmp97.html
148. Patents Patented Technology: If you use a wash pad with Air Berms or built in berms for recovery of your wash water you will need a License from Environmental Cleaning Systems, Inc. (ECS, Inc) to use this technology. Contact Doug Latimer or Charles Robinson at 519-621-8244 for this license. If you purchase your water recovery equipment from ECS, Inc. it includes the license to use Patented Technology.
149. If you use a flat tarp wrapped around PVC pipe and 2x4 purchased from Delco Cleaning Systems of Fort Worth for your water recovery you will not need a license from ECS, Inc. If you are not sure whether or not your procedures are covered by Patented Technology contact ECS, Inc. for clarification. Also refer to the settlement agreement between ECS, Inc. and Delco Cleaning Systems of Fort Worth covering this technology. The water recovery items purchased from Delco Cleaning Systems of Fort Worth do not violate ECS, Inc. Patents.
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153. In the Phase II NPDES Permits there is a “no exposure exemption” for business and industry if they can answer no to the following 11 questions: Are any of the following materials or activities exposed to precipitation, now or in the foreseeable future? 1. Using, storing or cleaning industrial machinery or equipment, areas where residuals from using, storing or cleaning industrial machinery or equipment remain and are exposed to storm water. 2. Materials or residuals on the ground or in storm water inlets from spills/leaks. 3. Materials or products from past industrial activity.
154. 4. Material handling equipment (except adequately maintained vehicles). 5. Materials for products during loading/unloading or transporting activities. 6. Materials or products stored outdoors (except final products intended for outside use (e.g., new cars) where exposure to storm water does not result in the discharge of pollutants). 7. Materials contained in open, deteriorated or leaking storage drums, barrels, tanks, and similar containers. 8. Materials or products handled/stored on roads or railways owned or maintained by the discharger.
155. 9. Waste material (except waste in covered, non-leaking containers (e.g., dumpsters)). 10. Application or disposal of process wastewater (unless otherwise permitted). 11. Particulate matter or visible deposits of residuals from roof stacks and/or vents not otherwise regulated (i.e., under air quality control permit) and evident in the storm water outflow.
156. Notice that Item No. 1, 9, 10, & 11 will require the capture and proper disposal of your wash water, and cleaning up of the wash area so there is no residue from wash operations. This will probably allow your customer to claim a “No Exposure Exclusion". When I posed this question to several regulating officials there was an even split on whether a company could claim this “no exposure exemption” or not. If were a contract cleaner I would shop for the answer I needed! (If you do like Mommy answer go to Daddy!)
157. Phase II, “Illicit Discharge Detection and Elimination Minimum Control Measures” is composed of 5 sections: 1. A storm Sewer Map 2. An ordinance prohibition on non-storm water discharge to the MS4 (Municipal Separate Storm Sewer System), 3. A plan to detect and address non-storm water discharges, including illegal dumping, into the MS4
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160. What does the future hold? For Power Wash Contractors of the 21st Century water management will be as important as the pressure washing. You will now have to have a toolbox full of tools for proper water management. Just as a carpenter has more than a hammer in his tool box it will be necessary for the Pressure Wash Contractor to have more that one type of device to capture, control, and clean wash water with. Because washing with a Recycling Systems on a Portable Vinyl Wash Pad is the most expensive way to wash an item this needs to be the option of last resort.
161. The Big Problem Cities or Urban Areas who don't know the pollutants in the discharges or the volumes might be more likely to assume the worst. And since they are on the hook if something goes wrong at their wastewater treatment plant, they may react over-cautiously on allowing discharge to a sanitary sewer. (Notice the effect of the economic revenue stream )
162. Cost of Compliance There is going to be a cost associated with the control of discharged Power Washing Waste Water. Enacting Regulations prohibition the discharge of Power Washing Waste Water to the Storm Drains with enforcement by complaint basis only will have very little effect on stopping this waste water from entering the storm drain system (MS4).
163. Compliance Enforcement Effective enforcement requires a consistent 24/7 enforcement action. Some municipalities have done enforcement programs for night and weekends for a 30 day period. This temporarily solves the program but with the large number of part timers entering the business the effect soon wears off. Within a short period of time the industry is back to unregulated power washing. This creates a yo-yo effect in enforcement and compliance.
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165. As business and government come to grips with what to do with wastewater it is obvious that it has to go somewhere. The most obvious place is for it to go to the POTW. POTWs serve the needs of the community by treating discharges to the sanitary sewer system. In Texas there are no combined sewer systems. Sanitary Sewers go to a POTW for treatment, Storm Sewers (MS4s) discharge straight into an adjacent stream or river. Communities are responsible for their Stormwater Discharges through their TPDES Permits. Programs are required to monitor for water quality and to eliminating illegal discharges. If communities do not provide an economical place for wastewater discharge then this activity will be done nights and weekends to avoid detection.
166. These illegal discharges will end up in the storm sewer. These discharges are typically an insignificant percentage of the contribution of the total contaminates to sanitary sewer and a significant contributor of pollutants to the storm drains. Sooner or later communities will open up their POTWs to these wastewater discharges. The problem is that they have not been doing this in the past, so it is something new!
167. Minimizing the Cost of Compliance The city that has enacted the best overall regulation with a highest level of voluntary compliance is Fort Worth, Texas. This regulation was the result of a “Mobile Power Washing Environmental Protection and Compliance Conference” held during a Public Comment Period. The meeting was attended by about 40 Federal EPA, State, Regional, and Municipal Environmental Regulators and 100 Contract Cleaner and Industry Representatives. Detergents detected in the storm drains has decreased from over 50% of the storm drains to as low as 5% since the ordinance was enacted January 2, 1996. The Fort Worth Regulations are now up on the EPA’s Website as an example.
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169. The best regulation for the elimination of the Yo-yo effect of enforcement is the BASMAA “Pollution Prevention Voucher ”. This certificate should be required to be kept on file by the Contract Cleaner and his customer for a period of three years as adopted by Michigan Department of Environmental Quality. Also Michigan Department of Environmental Quality allows discharging to ground for Cosmetic Cleaning up to 1,000 gallons per month per acre for bioremediation. Adopting the above regulations will produce the highest level of voluntary compliance with the minimum cost . This conclusion is based upon the positive experience of these regulations over time.
170. High Lights of the Fort Worth Code: DIVISION 2, COSMETIC CLEANING A discharge or flow of cold water used in cosmetic cleaning that is not contaminated with any soap, detergent, degreaser, solvent, emulsifier, dispersant or any other cleaning substance may be discharged to the storm drain as long as the storm drain inlet is screened to catch debris and the discharge passes through an oil absorbent pad or boom. No oil sheen may be present in the discharge after it passes through the pad or boom. Screen the storm drain inlet with a 20 mesh or finer screen to catch the debris The total volume of wastewater generated by all the cosmetic cleaners operating in Fort Worth on any given day was not likely to exceed 20,000 gallons; this volume is "insignificant" when compared to the City's total treatment capacity.
171. The Cosmetic cleaner was given to access the sanitary sewer The waste water belonged to the property owner, not the cosmetic cleaner, so the waste water should be discharged on-site if possible. The ideal discharge point would be into a sand or grit trap such as those found in car wash bays. Unfortunately, few sites contain such facilities so the discharge options revert to sinks, toilets, floor drains and clean-out stubs. Discharging through a 400 micron filter to remove the grit and sludge It is up to the property owner to decide which conveyance to discharge into as they own the plumbing system located within their property lines. Discharges into manholes are strictly forbidden, no matter where they are located. (city property)
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173. Cosmetic Cleaners that utilize wash water recycling units fit into "process water" category and must test their effluent at least once annually. $50.00 Permit Fee for first Wash Rig The fee for the permit (which goes to the business) is $25.00. The fee for the registration certificates is $25.00 per wash unit. Preclean liquid accumulations of oil or grease with absorbent clay or a similar material prior to washing. The oil soaked clay should be placed in a plastic bag and disposed to a dumpster. Discharges to the sanitary sewer must not have a temperature greater than 150° F, must not have a pH less that 5.0 or greater than 12.0. Offenses are punishable by a fine of up to $2,000 per day per offense.
174. Hot water is defined as any water over 110°F. Discharges to the storm drain using hot water cosmetic cleaning without any chemicals are approved provided that permission is granted by the Depart of Environmental Mgt prior to using the hot water. This exemption was designed for cosmetic cleaners washing objects such as sidewalks, headstones, walls and other things that are unlikely to be affected by the normal pollutants such as oil and grease. Mobile commercial cosmetic cleaning means "power washing, steam cleaning, and any other mobile cosmetic cleaning operation, of vehicles and/or exterior surfaces, engaged in for commercial purposes."
175. Links to the Fort Worth Code: City of Fort Worth: http://www.fortworthgov.org/DEM/powerwash.htm EPA: http://www.epa.gov/owow/nps/ordinance/documents/FortWorthSW.pdf Michigan Department of Environmental Quality http://www.deq.state.mi.us/documents/deq-ead-tas-powrwash.pdf Delco Cleaning Systems Summary (note: see first) http://www.dcs1.com/del/delpg5/fterpt.html
177. Robert M. Hinderliter (PWNA Environmental Chairman) meets with Robert White (Manager Sacramento County B usiness E nvironmental R esource C enter) October 22, 2002 during the Comment Period for the BMPs for Mobile Power Washing. BERC was very interested in receiving comments from a National Trade Organization on their proposed BMPs. PWNA was initially told that the comment period had ended but that they would be glad to receive comments any way for future revisions. PWNA immediately submitted comments. 12 of 14 items were accepted from PWNA. The final BMPs were released on November 8, 2002.