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RCP
January 24th, 2010, 06:13 PM
Does anyone have a definitive link to the RRP Rules as it applies to pressure washing? I have been told and read several articles with conflicting messages.
Where does it specify that water has to reclaimed and disposed of?
I see lots of laws/rules that DEP/OHSA have, but not RRP.

Msargent
January 24th, 2010, 06:19 PM
Local lead lady here told me no way to pwr wash. Maybe if you can adjust flowrate and turn down pressure, She advised me to only rinse with garden hose.

y.painting
January 24th, 2010, 06:42 PM
Local lead lady here told me no way to pwr wash. Maybe if you can adjust flowrate and turn down pressure, She advised me to only rinse with garden hose.

:stunned: .

SLS-Construction
January 24th, 2010, 06:42 PM
Nothing that I recall in there besides external containment.

Quick search on the words
3 results on water - none applied (2 were on interior cleaning, the other was in an area stating what you can get lead poisoning from)
Reclaim - nada

JasonW
January 24th, 2010, 06:55 PM
For some reason "containment" and "pressure washing" don't seem to fit well. I wouldn't want that thing on any of my pre 78' jobs after April 22.

RCP
January 24th, 2010, 08:08 PM
I agree, let's not even consider the issues of soil sampling! Just trying to clarify the rules.
The EPA say PW is allowed as it is not considered abrasive, so it is not considered renovation. There are many local laws that deal with runoff.
But I find nothing that says pressure washing falls under RRP.

Greg Di
January 24th, 2010, 09:17 PM
You are supposed to take the lead contaminated mop water and "dump it into the toilet" according to the manual so maybe they just never thought of reclamation. It wouldn't be the first time they didn't think something through.

WarnerConstInc.
January 24th, 2010, 09:28 PM
You are supposed to take the lead contaminated mop water and "dump it into the toilet" according to the manual so maybe they just never thought of reclamation. It wouldn't be the first time they didn't think something through.

That water goes right down the street and gets turned back into my drinking water? WTF?

The end of town I live on is the oldest and from what I have been told by a few friends at the water department, we still have lead service pipes.:smash:

RCP
February 4th, 2010, 07:53 PM
I sent an email to the head of my state's DEQ about containment.

The response

R4D - I could not find any specific requirements in the Lead-Based Paint (LBP) Renovation, Repair, and Painting (RRP) Rule that requires the collection of waste water from power washing beyond the requirement to dispose of the waste properly, however, I believe best work practices that are outlined in the HUD Guidelines and elsewhere strongly recommend the collection of waste water and there may be specific Utah Division of Water Quality regulations prohibiting the discharge of lead contaminated waste water to the surface waters and/or storm drains in Utah. We can look into this a get back to you with additional information.

SLS-Construction
February 4th, 2010, 08:09 PM
HUD requirments - in case your wondering


D. Disposal Requirements. The Abatement Subcontractor shall contact the Regional EPA, state, local, and all other pertinent authorities to determine lead- based paint debris disposal requirements. If applicable, the requirements of the Resource Conservation and Recovery Act (RCRA) must be complied with, as well as any or all other applicable federal, state, county, or local waste requirements.

The Owner/ Consultant will supply the Abatement Subcontractor with a list of some of the appropriate agencies. During or after the actual abatement, the Abatement Subcontractor shall not leave any debris in the yard or near- by property, incinerate debris, dump debris by the road, place debris in any unauthorized dumpster, or introduce lead contaminated (non- filtered) water into storm sewers (shall not be poured down yard inlet or street drain) or sanitary sewers (shall not be flushed down toilet or any other household/ residential/ commercial type drain system). All waste water shall be labeled "filtered" (using 5 micron filter) or "non- filtered." All non- filtered waste water containers shall be labeled "hazardous waste" and with a date the Abatement Subcontractor began to collect contaminated water in that container.


Basically if you filter it with a 5 micron or better filter it can go down the drain

Eieio
February 4th, 2010, 08:26 PM
So what would you do with the water? How would you contain or recycle it??

Leo G
February 4th, 2010, 08:37 PM
I'm sure with about $3000 worth of equipment.

WarnerConstInc.
February 4th, 2010, 08:48 PM
I'm sure with about $3000 worth of equipment.

:laugh3::laugh3::laugh3:

Extra words...

Highland
February 6th, 2010, 07:18 PM
Most of the houses we wash are vinyl siding so no lead worries. Very few pre 1978 houses still have the origional paint so no lead paint residue is going to be washed off.

Eieio
February 6th, 2010, 07:19 PM
Most of the houses we wash are vinyl siding so no lead worries. Very few pre 1978 houses still have the origional paint so no lead paint residue is going to be washed off.



What would you do if you were pressure washing a pre 1978 house?

Highland
February 6th, 2010, 07:31 PM
If it had been repainted at some point after 1978 I wouldn't do anything different than I would for any new house. It's not likely that I would wash off all the new paint and some of the old pre1978 paint.


If it was a pre 1978 house with origional paint not flacking or peeling on it I would probably still wash it the same way. If it had peeling or flacking paint that the washer would knock off, I would give the owners the lead paint phamplet and still wash it but with a tarp beneath the areas I am washing.

Eieio
February 6th, 2010, 07:37 PM
I follow you. I am curious because I can't figure out away that the run off water would be contained..

Even if you lay a tarp down, what do you do with the run off water??

Highland
February 6th, 2010, 07:50 PM
You can't contain the runoff unless the house is surrounded by concrete. Then you would use a water dam and a recycle unit like you have to do when cleaning gas stations.

RCP
February 6th, 2010, 08:25 PM
I am still trying to figure it out, I did find an option in the attached pdf.
Still does not make sense to me!:rolleyes3:

Highland
February 6th, 2010, 08:49 PM
The attachment says that the DEP is not enforcing collection of the water on residential homes if using normal cleaning solutions such as soap and bleach.
If it ever gets to the point where they are enforcing this, washing a house will become too expensive for most home owners to hire someone else to do it. The home owners will then find a way to do it themselves, defeating to process of collecting contaminates.

They keep using the terms "power washing and pressurewashing". Most professionals use low pressure when washing homes. This washes the dirt, mold and mildew off but doesn't usually wash off paint.