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In this section of the Campus Tour you will find information on the following:

Employee Training

Aboveground Storage Tanks

Deicing Chemicals

Drums

Floor Drains

Lead-Acid Battery

Paints/Aerosols

Solvents/Parts Washing

Transformers

Underground Storage Tanks

Spill Prevention, Control and Countermeasures Plan

Vehicles Use, Fueling, Washing

Waste Oils

Transportation Safety Topics (New May 2020!)

 

All transportation operations generate hazardous waste at some time or other, and handling it is a nuisance, to say the least. If you run a maintenance facility, chances are you're faced with this problem a lot. You may have thought that the only environmental regulations that apply to your maintenance facility relate to hazardous waste. Ask yourself do my colleagues, or I, perform the following tasks:

  • Replace lead-acid batteries
  • Use or store pesticides
  • Use a parts cleaner that contains solvents
  • Apply paint or use aerosols
  • Store fuel or other chemicals in an aboveground or belowground tank
  • Wash vehicles
  • Generate waste oil, waste oil filters, waste rags, waste absorbents
  • Use drums to store waste or chemicals
  • Generate used antifreeze

As you go through this section, you'll find the information you need on environmental regulations, written in everyday language. As you follow these regulations and best practices, you'll do more than just avoid fines and negative publicity. You can also take satisfaction in the fact that you will:

  • Contribute to a safer workplace,
  • Help reduce operating costs by minimizing waste,
  • Save money by preventing the costly cleanups caused by pollution, and
  • Have a positive impact on the environment.

Employee Training

Training employees on proper procedures to reduce your facility's impact on the environment is a best practice. More detailed training information is provided in the regulatory requirements sections of the tour. Employee training may include the following:

 

  • Spill response training for personnel who handle hazardous material,
  • Fork lift training,
  • Storm water pollution prevention education,
  • Right-to-know awareness training,
  • Hazardous materials management,
  • Emergency preparedness, and
  • Awareness-level training, for example, a general overview of the school's environmental management system.

Aboveground Storage Tanks (AST)

Chances are, your grounds and vehicle maintenance facility uses an aboveground storage tank (AST) to contain one of these liquids:

  • Gasoline or diesel used for fueling vehicles
  • Diesel or heating oil used for heating buildings or powering emergency generators
  • Liquid wastes, such as oils or paints

Environmental regulations for this type of storage vary, depending on what’s being stored, where it’s being stored (inside or outside), how much is being stored (the volume of the AST itself) and whether the contents are classified as hazardous or regulated waste. Here are some of the regulations you should consider:

Under the Emergency Planning and Community Right-to-Know Act, you are required to report the storage of certain chemicals at certain quantities.

 

If you store waste paint or waste oil in an AST, you must meet hazardous waste regulations.

 

If your annual fueling of maintenance vehicles exceeds maximum legal levels, you must install Stage 2 vapor recovery equipment.

 

You may be required to implement a Spill Prevention Control and Countermeasure Plan if you store petroleum products above certain threshold volumes.

 

Aboveground Storage Tanks Best Practices

Even when not required by environmental regulations, the following best practices are recommended. In some instances, best practices presented here are required by regulations.

 

AST Vehicle and Equipment Fueling

Your facility may have a fueling system (diesel, gasoline, etc.) for vehicles or equipment that involves aboveground storage tanks. To minimize the potential for fuel spills and leaks and reduce their potential to enter the storm sewer system, implement the following best practices:

  1. Cover catch basins with storm drain covers while fueling.
  2. Make certain that spill kits containing dry, absorbent materials for spill response are located near the area of fueling and that staff are trained in their use.
  3. Ensure that the transfer of fuel from/to fuel tanks and/or aboveground storage tanks is monitored by an attendant.
  4. Provide spill response training for personnel (in most states this is required by law).
  5. Post signs that give fueling instructions, spill response procedures, emergency contact information and best practices.
  6. Check loading/unloading equipment (valves, pumps, flanges, and connections) regularly for leaks. Replace worn or broken equipment.

AST Outdoor Handling of Material

To minimize the likelihood of discharge of pollutants to storm drains from outdoor loading and unloading of material involving aboveground storage tanks, adhere to the following best practices:

  1. Avoid transferring materials close to storm drain inlets.
  2. Transfer liquids only in paved areas. Portland cement paving should be used if the liquid is asphalt reactive.
  3. Provide contractors and haulers with copies of pertinent best management practices (BMPs). Require contractor/hauler adherence to BMP specifications. Verify proper waste disposal practices of contractors.
  4. Protect all loading/unloading activities from rainfall, run-on and wind dispersal to the maximum extent practicable. Viable options include conducting loading/unloading under existing cover, or moving indoors.
  5. Maintain adequate supplies of spill response equipment and materials in accessible locations near areas where spills may be likely to occur.
  6. Clean up minor spills immediately.
  7. Conduct regular inspections of storage and containment equipment and promptly correct deficiencies to this equipment as necessary.

AST Outdoor Storage of Material

Storing material outdoors, whether it is equipment, chemicals or containers, can result in potential storm water contamination. Follow these best practices to minimize potential impacts to storm water runoff:

  1. Avoid dispensing from drums positioned horizontally in cradles. Dispensing materials from upright drums equipped with hand pumps is preferred. Always use drip pans and self-closing spigots if dispensing from horizontally positioned drums.
  2. Store drums and containers on pallets or other structures to keep the container out of contact with storm water.
  3. Store all materials in their original containers or containers approved for that use. Ensure that all containers are appropriately sealed. Store empty containers indoors or under cover before moving them off-site.
  4. Properly label all chemical containers with information, including their contents, hazards, spill response and first aid procedures, manufacturer's name and address, and storage requirements. Maintain copies of MSDS on file for any materials stored and/or handled.
  5. Reduce the quantities of chemicals stored outside to the minimum volume required based on variables such as release potential, usage, storage capacity, and chemical shelf life.
  6. Maintain adequate supplies of spill response equipment and materials in accessible locations near areas where spills may be likely to occur.
  7. Post signs at all chemical storage locations in clearly visible locations noting the materials stored, emergency contacts, and spill cleanup procedures.
  8. Perform and document periodic inspections in a logbook. Inspection items should include the following: external corrosion, structural failure, spills and overfills due to operator failure, failure of piping system (pipes, pumps, flanges, couplings, hoses, and valves), visually inspect new tanks or containers for loose fittings, poor welds, and improper or poorly fitted gaskets, and Inspect tank foundations and storage area coatings.
  9. Whenever possible store materials under a roof or otherwise cover stored materials to minimize storm water impacts.
  10. Make sure dumpster covers are closed except when adding trash to prevent infiltration and subsequent release of oils to receiving waters.

AST Waste Handling and Disposal

Best practices related to waste handling and disposal include the following suggested activities:

  1. Perform regular housekeeping activities in waste storage areas.
  2. Reuse or recycle materials whenever possible.
  3. Inspect waste management areas for spills and waste management containers for leaks.
  4. Track waste generated, evaluate the process generating the waste and look for ways to reduce waste generation.
  5. Characterize waste streams.
  6. Find substitutes for harmful chemicals; properly dispose of unusable chemical inventory.
  7. Segregate and separate wastes.
  8. Do not dispose of liquid wastes such as oils or hazardous materials into dumpsters.
  9. Maintain adequate supplies of spill response equipment and materials in accessible locations near areas where spills may be likely to occur.
  10. Equip waste transport vehicles with spill containment equipment.
  11. Perform and document in a logbook periodic inspections of hazardous and non-hazardous waste storage areas. Inspection items should include the following: external corrosion, structural failure, spills and overfills due to operator error, failure of piping system (pipes, pumps, flanges, couplings, hoses, and valves), visually inspect new tanks or containers for loose fittings, poor welds, and improper or poorly fitted gaskets, and inspect tank foundations and storage area coatings.

Deicing Chemicals

Drums

If you're like most people, you probably think that, as long as your storage drums are labeled and not leaking, you don't have anything to worry about. Unfortunately, that's not the case. Whether you use drums to store chemicals, hazardous waste or solid waste, there are issues like these that you need to be aware of:

  • Requirements for different storage areas, based on storage length (e.g., less than 90 days, up to 180 days, etc.).
  • Proper labeling and signage.
  • Secondary containment issues.
  • Storage compatibility.
  • Segregation of different waste types.
  • Staff training requirements.
  • Recordkeeping requirements.
  • Access to Safety Data Sheets.
  • Definitions of hazardous waste.

Drums Best Practices

Even when not required by environmental regulations, the following best practices are recommended. In some instances, best practices presented here are required by regulations.

 

Drum Outdoor Handling of Material

To minimize the likelihood of discharge of pollutants to storm drains from outdoor loading and unloading of drummed material, adhere to the following best practices:

  1. Avoid transferring materials close to storm drain inlets.
  2. Transfer liquids only in paved areas. Portland cement paving should be used if the liquid is asphalt reactive.
  3. Provide contractors and haulers with copies of pertinent best management practices (BMPs). Require contractor/hauler adherence to BMP specifications. Verify proper waste disposal practices of contractors.
  4. Protect all loading/unloading activities from rainfall, run-on and wind dispersal to the maximum extent practicable. Viable options include conducting loading/unloading under existing cover, or moving indoors.
  5. Maintain adequate supplies of spill response equipment and materials in accessible locations near areas where spills may be likely to occur.
  6. Clean up minor spills immediately.
  7. Conduct regular inspections of storage and containment equipment and promptly correct deficiencies to this equipment as necessary.

Drum Outdoor Storage of Material

Storing material outdoors, whether it is equipment, chemicals or containers, can result in potential storm water contamination. Follow these best practices to minimize potential impacts to storm water runoff:

  1. Avoid dispensing from drums positioned horizontally in cradles. Dispensing materials from upright drums equipped with hand pumps is preferred. Always use drip pans and self-closing spigots if dispensing from horizontally positioned drums.
  2. Store drums and containers on pallets or other structures to keep the container out of contact with storm water.
  3. Store all materials in their original containers or containers approved for that use. Ensure that all containers are appropriately sealed. Store empty containers indoors or under cover before moving them off-site.
  4. Properly label all chemical containers with information, including their contents, hazards, spill response and first aid procedures, manufacturer's name and address, and storage requirements. Maintain copies of SDSs on file for any materials stored and/or handled.
  5. Reduce the quantities of chemicals stored outside to the minimum volume required based on variables such as release potential, usage, storage capacity, and chemical shelf life.
  6. Maintain adequate supplies of spill response equipment and materials in accessible locations near areas where spills may be likely to occur.
  7. Post signs at all chemical storage locations in clearly visible locations noting the materials stored, emergency contacts, and spill cleanup procedures.
  8. Perform and document periodic inspections in a logbook. Inspection items should include the following: external corrosion, structural failure, spills and overfills due to operator error, failure of piping system (pipes, pumps, flanges, couplings, hoses, and valves), visually inspect new tanks or containers for loose fittings, poor welds, and improper or poorly fitted gaskets, and inspect tank foundations and storage area coatings.

Drum Waste Handling and Disposal

Best practices related to waste handling and disposal include the following suggested activities:

  1. Perform regular housekeeping activities in waste storage areas.
  2. Reuse or recycle materials whenever possible.
  3. Inspect waste management areas for spills and waste management containers for leaks.
  4. Track waste generated, evaluate the process generating the waste and look for ways to reduce waste generation.
  5. Characterize waste streams.
  6. Find substitutes for harmful chemicals; properly dispose of unusable chemical inventory.
  7. Segregate and separate wastes.
  8. Do not dispose of liquid wastes such as oils or hazardous materials into dumpsters.
  9. Maintain adequate supplies of spill response equipment and materials in accessible locations near areas where spills may be likely to occur.
  10. Equip waste transport vehicles with spill containment equipment.
  11. Perform and document in a logbook periodic inspections of hazardous and non-hazardous waste storage areas. Inspection items should include the following: external corrosion, structural failure, spills and overfills due to operator failure, failure of piping system (pipes, pumps, flanges, couplings, hoses, and valves), visually inspect new tanks or containers for loose fittings, poor welds, and improper or poorly fitted gaskets, and inspect tank foundations and storage area coatings.

Floor Drains

You may find yourself walking around the inside of a grounds/vehicle maintenance facility building and notice, perhaps, a drain or two in the floor and say to yourself, "Hmm, I wonder what's at the other end of those floor drains and what gets drained?"

It is important to take some time to understand any requirements associated with floor drains. For example, if the drains lead to a surface water body, chances are they would need to be permitted for discharge. Or, if the drains just go to the ground, then underground injection control (UIC) regulations may be applicable. Similarly, if floor drains discharge directly to a publicly owned treatment works (POTW), then their requirements would apply to your facility.

So, if you have one or more floor drains in your grounds/vehicle maintenance work area, you may want to continue on and learn what requirements may be associated with the floor drains in your facility and what you need to do to make sure the drains are compliant and are not endangering the environment.

 

Floor Drains Best Practices

Even when not required by environmental regulations, the following best practices are recommended. In some instances, best practices presented here are actually required by regulations.

 

Vehicle and Equipment Washing & Drains

Vehicle and equipment washing have the potential for contaminating receiving waters through the discharge of grit, oil and other contaminants. State and federal regulations have strict guidelines concerning the discharge of vehicle wash water; check the regulatory section (NPDES) of this facility area for more regulatory information. Your facility may also have local regulations as well.

  1. Soapy or oily vehicle wash waters must either be collected for off-site disposal or discharged to the sanitary sewer, if allowed by the local sewer authority.
  2. Consider using a commercial car wash if your facility is not equipped properly.

General Maintenance/Repair Work & Drains

 When performing general vehicle repair/maintenance work near floor drains, implement the following to the maximum extent practical:

  1. Drain and crush oil filters (and oil containers) before recycling or disposal. Store crushed oil filters and empty lubricant containers in a leak-proof container.
  2. Drain and properly dispose of all fluids and remove batteries from vehicles and equipment.
  3. Use biodegradable products and substitute materials with less hazardous properties where feasible.
  4. Maintain clean equipment by eliminating excessive amounts of external oil and grease buildup. Use water-based cleaning agents or non-chlorinated solvents to clean equipment.
  5. Store mechanical parts and equipment that may yield even small amounts of contaminants (i.e., oil or grease) away from drains.
  6. Sweep or vacuum the shop floor frequently.
  7. Designate specific areas indoors for parts cleaning.
  8. Clean up any spills promptly.
  9. Keep rags, mops, absorbents, and other cleanup supplies readily accessible to all work areas.
  10. Never sweep or flush wastes into a floor drain.
  11. Promptly transfer drained fluids to a designated waste storage area.
  12. Place bulk fluids, waste fluids, and batteries in secondary containment to capture accidental spills.
  13. Service "pits" should have concrete floors and not earthen floors or floors with drains.
  14. Service bays within the facility should be segregated by operation (brakes, radiator, oil changing, etc.) to avoid cross-contamination.

Lead-Acid Batteries

In the old days, when we changed a vehicle battery, we threw out the old one and never gave it a second thought. Today, we know better. We know that:

  • Individuals who become poisoned by lead can experience symptoms including irritability, stomachaches, poor appetite, diarrhea, colic, distractibility, and lethargy;
  • Lead acid typically consists of 40 percent sulfuric acid, a corrosive that can burn skin; and
  • The improper disposal of lead-acid batteries can contaminate soil and water. The toxic metal will typically not dissolve in water, biodegrade, dissipate, or decay, making it an environmentally persistent and extremely hazardous contaminant.

Given the potential health, safety and environmental impact of lead-acid batteries, many states require vehicle maintenance facilities to recycle them. Community planning and right-to-know laws may also be applicable.

Continue through this section to learn more about the basic principles underlying pertinent regulations, as well as ways you can protect your co-workers and the environment from the improper handling of lead-acid batteries.

Lead-Acid Battery Best Practices

Even when not required by regulations, the following best practices for lead acid batteries are recommended.

  • Handling Lead-Acid Batteries (Use of Personal Protective Equipment)
  • Lead-acid batteries that are damaged or missing a cap can leak acid. Battery acid can severely damage your eyes and skin, so personal protective equipment should be worn when handling batteries. More specifically, follow these guidelines:
    1. Wear acid-resistant gloves and safety glasses;
    2. Double-bag damaged batteries in polyethylene plastic bags that are at least 6-mils in thickness;
    3. I you can replace a missing battery cap, do so immediately, otherwise consider a battery with a missing cap "damaged" and double-bag the battery in 6-mil polyethylene plastic bags.

Storage & Labeling

    1. Small quantities of lead-acid batteries should be stored in acid-resistant tubs; large quantities should be stored in an isolated area with no floor drains; and spent lead-acid batteries should be stored indoors (or if outdoors, under a cover) and on an impervious surface.
    2. Freezing temperatures may cause spent battery cases to crack.
    3. Storage areas should be sealed with an acid-resistant material and have a containment berm.
    4. Piles of lead-acid batteries that are being stored on pallets should not be stacked higher than three feet, and the piles should be covered and stored within an enclosed area. (Ideally, lead-acid batteries should be stored in a single layer because stacking increases the risk of short circuits and acid leaks.)

Spills & Acid Debris

    1. Keep the following supplies in your lead-acid battery storage area: acid-resistant gloves; a supply of polyethylene plastic bags (six mils* or thicker, and sized to contain the largest battery expected); rags or disposable wipes for acid leak clean-up; appropriate absorbent for spill clean-up; and a weather-resistant pen or marker for marking used or damaged batteries with the date they were taken out of service.
    2. It is also a good safety precaution to have an eyewash station in the area, or a sign indicating the location of the nearest eyewash.
    3. Keep a supply of lime or baking soda on hand to neutralize acid spills.
    4. If there is a battery acid spill: a) double-bag the leaking battery in 6 mil polyethylene plastic bags; b) clean the spilled battery acid with rags or disposable wipes and use appropriate absorbent; and c) manage the clean-up material as hazardous waste by placing it in an acid debris waste accumulation container. Clean-up debris would also contain lead and would have to be managed as such, not just as an acidic waste.

Lead-acid batteries can be universal wastes and managed according to the requirements in 40 CFR 273, or reclaimed according to the requirements in 40 CFR 266, or managed as a RCRA hazardous waste under the requirements contained in 40 CFR 262.

*Mil - A unit of measurement in the English system that is measured in thousandths of an inch. (i.e., .001 = one thousandth of an inch or 1.0 mil)

 

Paints/Aerosols

In a busy facility, partially used aerosol cans and paint buckets can stockpile fast. Don't let too many accumulate! The best practice is to establish a system to use, store, and dispose of these products--before they become a problem for you. Examples of materials contained in aerosol cans and paint materials in a ground/vehicle maintenance facility include, but are not limited to:

  • Brake cleaners
  • Spray paints
  • Miscellaneous lubricants (e.g., WD-40)
  • Used paint buckets
  • Old cans of previously used paint

Depending on the contents of your facility's aerosol cans, or depending on the nature of your paint materials, air emissions (e.g., VOC limits), hazardous substance reporting, or hazardous waste generator requirements may apply to your facility. For example, with respect to aerosol cans: Depleting the propellant in an aerosol can may result in contents remaining in the can, which may be hazardous waste. If the nozzle of an aerosol can is broken or clogged and can no longer be used, then the can remains under pressure, rendering the can a hazardous waste. If the can is empty of both propellant and contents, then the can is truly empty and non-hazardous.

Paint spray booths are another matter. If you have one, it may trigger specific air quality regulations or hazardous waste requirements (for the spray booth filters or water for water curtain type spray booths). To learn more about these requirements, as well as best management practices, continue through this activity area.

 

Paints/Aerosols Best Practices

Even when not required by environmental regulations, the following best practices are recommended. In some instances, best practices presented here are actually required by regulations.

 

Aerosols/Paint Management

  1. Implement a "first in, first out" use pattern for aerosol cans and order new cans on an as needed basis to ensure that cans are used up prior to opening new cans.
  2. Carefully determine whether spent aerosol cans are hazardous or non-hazardous. If contents and/or propellant remain(s) in the can, it is likely a hazardous waste; if there is neither content nor propellant, then it is likely a non-hazardous waste.
  3. To minimize disposal costs, ensure that truly empty aerosol containers are either sent to a scrap-metal recycler or disposed of in the trash.
  4. Minimize excess liquid paint by making efficient use of paint "poured" for use (i.e., use what you pour).

Outdoor Handling of Material (Paints)

To minimize the likelihood of discharge of pollutants to storm water from outdoor loading and unloading of paint materials, adhere to the following best practices:

  1.  Avoid transferring materials close to storm drain inlets.
  2. Transfer liquids only in paved areas. Portland cement paving should be used if the liquid is asphalt reactive.
  3. Provide contractors and haulers with copies of pertinent best management practices (BMPs). Require contractor/hauler adherence to BMP specifications. Verify proper waste disposal practices of contractors.
  4. Protect all loading/unloading activities from rainfall, run-on and wind dispersal to the maximum extent practicable. Viable options include conducting loading/unloading under existing cover, or moving indoors.
  5. Maintain adequate supplies of spill response equipment and materials in accessible locations near areas where spills may be likely to occur.
  6. Clean up minor spills immediately.
  7. Conduct regular inspections of storage and containment equipment and promptly correct deficiencies to this equipment as necessary.

Outdoor Storage of Material (Paints)

Storing material outdoors, whether it is equipment, chemicals or containers, can result in potential storm water contamination. Follow these best practices to minimize potential impacts to storm water runoff:

  1. Avoid dispensing from drums positioned horizontally in cradles. Dispensing materials from upright drums equipped with hand pumps is preferred. Always use drip pans and self-closing spigots if dispensing from horizontally positioned drums.
  2. Store drums and containers on pallets or other structures to keep the container out of contact with storm water.
  3. Store all materials in their original containers or containers approved for that use. Ensure that all containers are appropriately sealed. Store empty containers indoors or under cover before moving them off-site.
  4. Properly label all chemical containers with information, including their contents, hazards, spill response and first aid procedures, manufacturer's name and address, and storage requirements. Maintain copies of SDSs on file for any materials stored and/or handled.
  5. Reduce the quantities of chemicals stored outside to the minimum volume required based on variables such as release potential, usage, storage capacity, and chemical shelf life.
  6. Maintain adequate supplies of spill response equipment and materials in accessible locations near areas where spills may be likely to occur.
  7. Post signs at all chemical storage locations in clearly visible locations noting the materials stored, emergency contacts, and spill cleanup procedures.
  8. Perform and document periodic inspections in a logbook. Inspection items should include the following: external corrosion, structural failure, spills and overfills due to operator error, failure of piping system (pipes, pumps, flanges, couplings, hoses, and valves), visually inspect new tanks or containers for loose fittings, poor welds, and improper or poorly fitted gaskets, and inspect tank foundations and storage area coatings.

Waste Reduction and Recycling (Paints)

To minimize the amount of waste generated at your facility, consider the following:

  1. Mix only the amount of paint needed for a job.
  2. Use self-contained sinks and tanks when cleaning with solvent.

Solvents/Parts Washing Best Practices

Even when not required by environmental regulations, the following best practices are recommended. In some instances, best practices presented here are actually required by regulations.

 

Parts Cleaner/Degreaser

To assist in reducing potential impacts to the environment or worker exposure from parts cleaning, the following best practices should be followed:

  1.  Keep the parts cleaner closed when not in use.
  2. Reduce solvent evaporation by increasing freeboard and placing hoods or covers on all parts cleaning tanks.
  3. Utilize less toxic non-chlorinated solvent cleaners or aqueous-based cleaners to reduce worker exposure and hazardous waste generation.
  4. Use one multi-purpose solvent instead of many different solvents to increase recycle potential of the solvent.
  5. Consider using a service to maintain your parts cleaning unit.
  6. Consider pre-cleaning parts with a rag or wire brush.

Waste Handling and Disposal for Solvents/Parts Washing

  1.  Perform regular housekeeping activities in waste storage areas.
  2. Reuse or recycle materials whenever possible.
  3. Inspect waste management areas for spills and waste management containers for leaks.
  4. Track waste generated, evaluate the process generating the waste and look for ways to reduce waste generation.
  5. Characterize waste streams.
  6. Find substitutes for harmful chemicals; properly dispose of unusable chemical inventory.
  7. Segregate and separate wastes.
  8. Do not dispose of liquid wastes such as oils or hazardous materials into dumpsters.
  9. Maintain adequate supplies of spill response equipment and materials in accessible locations near areas where spills may be likely to occur.
  10. Equip waste transport vehicles with spill containment equipment.
  11. Perform and document in a logbook periodic inspections of hazardous and non-hazardous waste storage areas. Inspection items should include the following: external corrosion, structural failure, spills and overfills due to operator error, failure of piping system (pipes, pumps, flanges, couplings, hoses, and valves), visually inspect new tanks or containers for loose fittings, poor welds, and improper or poorly fitted gaskets, and inspect tank foundations and storage area coatings. 

Waste Reduction and Recycling

To minimize the amount of waste generated at your facility, consider the following:

  1. Recycle automotive fluids, solvents, cleaners, absorbents, and wash waters when the useful life is finished.
  2. Use self-contained sinks and tanks when cleaning with solvents.
  3. Reuse water used in flushing and testing radiators.
  4. Automotive fluids are not acceptable for disposal to the sanitary sewer, storm drain, or garbage.
  5. Reduce hazardous waste generated by minimizing the potential for cross-contaminating of wastes by ensuring, for example, that parts cleaners that do not contain listed wastes are segregated from listed wastes from other sources (for example, aerosols); and that non-hazardous materials (e.g., rags, oils, etc.) are not contaminated by parts washer solvents that are listed hazardous wastes.

Transformers

An electrical transformer: it's an everyday piece of equipment--and also a possible risk. Don't wait for a problem to arise before raising the questions that can help you avoid a time-consuming, expensive and potentially dangerous situation:

  • Who "owns" the transformer--the college or university, the electrical company or someone else?
  • Does the transformer contain polychlorinated biphenyl (PCB)-based oil?
  • If not, is the transformer labeled "non-PCB"?
  • If so, is the school following all the requirements of the Toxic Substance Control Act?
  • If located outdoors and if there were a leak, would transformer oil be contained on the pavement, or would its release impact soil or water?

Transformers Best Practices

Manufacture of PCBs was halted in the 1970s, but some PCBs may still be found in transformers, capacitors, heat transfer systems and hydraulic systems. Even when not required by regulations, the following best practices are recommended:

 

  1. All PCB transformers should be leak proof.
  2. Buildings used to store transformers should have a roof and walls that prevent rainwater from reaching the stored material and items; the floor should be impermeable with continuous curbing that is a minimum of 6" high.
  3. No drain valves, floor drains, expansion joints, sewer lines or other openings that would permit liquids to flow from the curbed area should be present in buildings/areas used to store transformers.
  4. The floor and curbing in the building/area used to store transformers should be constructed of continuous smooth and impervious materials, such as Portland cement concrete, to prevent penetration of PCBs.
  5. The storage facility should be located above flood water level.
  6. Transformer oil should be stored in proper storage containers such as steel drums without a removable head designed, constructed and operated with safety requirements for flammable and combustible liquids.
  7. All transformers should be labeled with respect to the PCB content of the transformer oil (e.g., "Non-PCB Containing Oil") and the labels should be maintained in legible condition.

 Underground Storage Tanks (UST)

♦ Tip: Ask yourself these questions:  Do you know if you have a tank? When was it last tested? How would you know if it was leaking?

 

An underground storage tank (UST) is a tank and any underground piping connected to the tank that is used to contain gasoline or other petroleum products or chemical solutions and that is placed in such a manner that at least 10 percent of its combined volume is underground.

 

Many campuses have underground tanks for fuel oil, to serve automotive trades education programs, or to operate transportation support depots. 

 

A Spill Prevention, Control and Countermeasure (SPCC) Plan may be required. Best practices include inspections, secondary containment and spill plans. Local/state regulations may also impact these tanks. 

FAQ: Do all tanks have to meet federal EPA regulations? 

  • The following USTs do not need to meet federal requirements for USTs: 
  • Farm and residential tanks of 1,100 gallons or less capacity holding motor fuel used for noncommercial purposes; 
  • Tanks storing heating oil used on the premises where it is stored; 
  • Tanks on or above the floor of underground areas, such as basements or tunnels; 
  • Septic tanks and systems for collecting storm water and wastewater; 
  • Flow-through process tanks; 
  • Tanks of 110 gallons or less capacity; and 
  • Emergency spill and overfill tanks. 
  • Some state/local regulatory authorities, however, may include these tank types--be sure you check with these authorities. 

The federal regulations for spill prevention planning emphasize the protection of surface waters, especially in case of spills.

 

Regulations covering bulk petroleum storage originally involved portions of the Federal Water Pollution Control Act (FWPCA) and Clean Water Act (CWA). The passage of the Oil Pollution Act (OPA) established additional provisions relating to oil spill response. These regulations included spill prevention and response planning, spill response training, and facility design and inspection. A requirement within these regulations establishes priorities for protection and mitigation of vulnerable resources that may be at risk and for preparing effective cleanup and removal efforts. The regulations also establish procedures for notification to the EPA and state agencies in the event of certain discharges of oil.

The major elements of the oil pollution prevention regulations include:

  • Spill Prevention, Control and Countermeasure (SPCC) Plans
  • Recordkeeping and Reporting
  • Emergency Preparedness and Response

Spill Prevention Control and Countermeasure Plan

SPCC Planning regulations contained in 40 CFR 112 were amended July 17, 2002, to serve two purposes: reduce the regulatory burden placed on facilities subject to the provisions, and to clarify certain requirements.

 

If a facility has a preparedness, prevention and contingency (PPC) plan, the required SPCC elements may be incorporated into it. Each SPCC Plan (the Plan) must be reviewed and certified by a registered professional engineer (PE) who is familiar with the provisions of 40 CFR Part 112, has examined (or his/her agent has examined) the facility and attests that the plan has been prepared in accordance with good engineering practices and 40 CFR 112 requirements, and that the facility has established procedures for required inspections and testing. In his/her certification of the SPCC plan, the PE also attests that the SPCC plan is adequate for the facility (40 CFR 112.3(d)).

 

According to the federal Oil Pollution Prevention regulations, facilities that are required to develop and implement an SPCC plan are those that have the potential to discharge oil to navigable waters of the United States and:

  • Have significant petroleum storage capacity aboveground, meaning 1,320 gallons or more, of oil stored in containers or operating equipment, including mobile equipment, having a capacity equal to or greater than 55 gallons (Note: containers that are "permanently closed" are excluded from this threshold); or
  • Have underground storage capacity of 42,000 gallons or more. However, underground storage tanks (USTs) regulated by 40 CFR 280 and 281 (RCRA's provisions for USTs) are excluded from this threshold, as are completely buried storage tanks that are "permanently closed;" or
  • Have been required by the EPA to prepare and implement an SPCC plan.

The amended regulations exempt containers less than 55 gallons in capacity from all SPCC requirements (40 CFR 112.1(d)(5)). The SPCC plan describes potential release scenarios that might reasonably be expected from the facility, then offers appropriate measures to prevent, control and/or mitigate those potential incidents. These measures may include both physical controls and operational procedures.

Facilities subject to SPCC planning requirements that were in operation on or before August 16, 2002, must amend and implement their amended plan by October 31, 2007. Operations commencing between August 16, 2002, and October 31, 2007, subject to SPCC planning requirements must prepare and implement their SPCC plan in accordance with SPCC regulations by October 31, 2007. Any operations subject to the SPCC regulations that commence following the October 31, 2007, must have their SPCC plan in place and implemented before beginning operations (40 CFR 112.3(a) and 112.3(b)).

With respect to amendments to an SPCC plan:

  • EPA may require a facility to amend its SPCC plan after the agency reviews the SPCC plan on site; or after the agency reviews information required to be submitted to the agency in the event the facility discharges oil in quantities exceeding threshold limits (see Recordkeeping and Reporting section below). Such amendments must be implemented within six months of the change(s) to the SPCC plan (40 CFR 112.4(d)).
  • Whenever there is a change in facility design, construction operation or maintenance that materially affects the potential for discharge of a petroleum product, the SPCC plan must be amended (40 CFR 112.5(a)). Such amendments must be implemented within six months of the change.
  • Facilities must review their SPCC plans at least every five years and amend them to include more effective prevention and control technologies if the facility determines, based on its review, that the modified technologies will reduce the potential for an oil discharge. The amended SPCC plan must include (or reference) a certification statement signed by the owner/operator of the facility, indicating whether he/she will amend the SPCC plan. Amended SPCC plans must be implemented within six months of the amendment.

With the exception of amendments required by the EPA, a PE must certify any technical amendments to an SPCC plan (i.e., amendments that require any engineering judgment; administrative changes such as names, telephone numbers, etc., need not be certified by a PE) (40 CFR 112.5(c)). 

  • The format of the SPCC plan may vary from the format provided in the regulations. However, in this case, the SPCC plan must include a cross-reference of its provisions to the requirements listed in the SPCC rule (40 CFR 112.7).
  • Deviations from the substantive requirements (with the exception of secondary containment requirements) are allowed, provided that the SPCC plan includes a discussion of reasons for nonconformance with the requirement and explains how an alternative measure will provide equivalent environmental protection.
  • The facility's SPCC plan must include a demonstration of drainage controls, containment and diversionary structures, monitoring equipment, personnel training, inspection and recordkeeping systems, security, and spill cleanup procedures.

The Plan must address areas around bulk storage tanks, pipelines and potential sites of spills into navigable U.S. waters. It also must ensure that:

  • Areas enclosed by secondary containment dikes (i.e., storage tanks and transfer sites) are properly maintained.
  • Dikes and curbing are kept in good repair and free of snow/rain water, to ensure adequate capacity.
  • Piping, transfer manifolds and supports are leak-free.
  • Maintenance tests and incident and training records are kept up-to-date.

If it is not practicable to provide secondary containment (e.g., dikes, berms, retaining walls, curbing, diversion ponds, etc.) for oil storage containers, tanks, and oil-containing operating equipment, then the facility must (40 CFR 112.7(d)):

  • Clearly explain in the SPCC plan why this is the case
  • Conduct periodic integrity testing of bulk storage containers and leak testing of valves and piping
  • Include in the SPCC plan an oil spill contingency plan according to the provisions of 40 CFR 109, and a written commitment of manpower, equipment and materials for adequately responding to a discharge (unless the facility has already in place a Facility Response Plan in accordance with 40 CFR 112.20)

Facility inspections should be performed in accordance with written procedures developed for the facility by the owner or operator. These written procedures and a record of the inspections (e.g., usual and customary business records for tests and inspections), signed by the appropriate supervisor or inspector, should be made part of the SPCC plan (or be referenced by the Plan) and maintained for a period of three years (40 CFR 112.7(e)).

 

The July 2002 amended SPCC rules require that facilities whose field-constructed, aboveground containers are undergoing repair, alteration, reconstruction, or change in service that might affect the risk of a discharge or failure due to brittle fracture or other catastrophe, must be evaluated for such a risk (40 CFR 112.7(i)).

  • A facility subject to the SPCC regulations must ensure that rainwater from diked areas does not leave the diked area (e.g., discharge to storm drains or other navigable waters) bypassing the facility treatment system without verifying that the water will not cause a discharge of oil. In addition, the facility must keep records of such storm / bypass events; records required by an applicable NPDES permit to record bypass events may be used for this SPCC planning requirement (40 CFR 112.8(c)(3)).
  • The Plan must provide for testing and inspection of each aboveground container, as appropriate, to determine its integrity (40 CFR 112.8(c)(6)).
  • The Plan also must provide for regular examinations of all aboveground valves and pipelines by operating personnel. These examinations should include an assessment of the general condition of such items as flange joints, expansion joints, valve glands and bodies, catch pans, pipeline supports, valve locking and metal surfaces. Integrity testing (e.g., hydrostatic testing) must also be conducted on a regular schedule and when material repairs are done (40 CFR 112.8(d)(4)).
  • Buried piping installed or replaced on or after August 16, 2002, must have protective wrapping and coating and cathodic protection (or otherwise satisfy the corrosion protection provisions for piping in 40 CFR 280 or 281) (40 CFR 112.8(d)(1)).

The SPCC plan must be carefully thought out and prepared in accordance with good engineering practices, and it must have the full approval of a management level with sufficient authority to commit the necessary resources (40 CFR 112.7). It also must include a discussion of facility conformance with the elements listed in 40 CFR 112.7, including:

  • A facility diagram / site layout plan. Completely buried USTs otherwise exempt from the applicability threshold criterion must be included on the diagram. (40 CFR 112.7(a)(3)).
  • A prediction of the direction, rate of flow and total quantity of petroleum products that could be discharged from the facility as a result of each major type of failure (such as tank overflow, rupture or leakage) in cases where such a failure may reasonably be predicted (40 CFR 112.7(b)).
  • Appropriate containment and/or diversionary structures or equipment to prevent discharged petroleum products from reaching surface water (40 CFR 112.7(c)).
  • Full fencing and provision for locking or guarding entrance gates when the facility is unattended (40 CFR 112.7(g)(i)).
  • Designated personnel accountable for spill prevention ((40 CFR 112.7(f)).
  • Instruction for personnel who handle oil, both in the operation and maintenance of equipment to prevent discharge of petroleum products, in the content of applicable pollution control laws and regulations, and the contents of the facility's SPCC plan (40 CFR 112.7(f)).
  • Annual personnel briefings to highlight known spill events, potentially malfunctioning components, and recently developed preventive measures (40 CFR 112.7(f)).

Recordkeeping and Reporting for SPCC

If the facility is normally attended at least four hours a day, a complete copy of the SPCC plan must be kept on site (or at the nearest field office for unattended facilities). The plan must be made available to EPA personnel for on-site review any time during normal working hours (40 CFR 112.3(e)).

While the regulations do not specifically require that SPCC training provided to personnel (as per 40 CFR 112.7(f)) be documented, maintaining records of SPCC training provided will help demonstrate the extent to which training requirements are met.

A facility must submit the SPCC plan and amendments to the EPA and appropriate state agency whenever it has done either of the following (40 CFR 112.4(a)):

  • Discharged more than 1,000 gallons of petroleum products into surface water in a single spill event.
  • Discharged more than 42 gallons petroleum products into surface water in each of two reportable spill events within 12 months.

Under either of the above circumstances, the facility must also submit the following both to the EPA and to the appropriate state agency (40 CFR 112.4(a)):

  • Facility name, location, and owner.
  • Maximum oil storage capacity and normal daily throughput.
  • Description of the facility, including a location map, a topographical map and flow diagrams.
  • Analysis of the cause of the spill, including a failure analysis of the system in which the failure occurred.
  • Description of the corrective actions taken, including a description of equipment repairs and replacements.
  • Additional preventive measures planned or taken to minimize the possibility of recurrence.

Emergency Preparedness and Response for SPCC

Non-transportation related onshore facilities that "could reasonably be expected to cause substantial harm to the environment" by discharging oil into surface water or adjoining shorelines must prepare a facility response plan and submit it to the EPA (40 CFR 112.20). Facilities are generally considered to pose a threat of substantial harm through discharge of oil only if they transfer oil over water to or from vessels, or if they store a million gallons or more of oil or petroleum products (see Attachment C-I to Appendix C of 40 CFR Part 112). It is unlikely that a college or university would meet either of these criteria. Nonetheless, organizations that require SPCC plans must complete a certification stating in essence that they perform neither of these activities (Section 3.0 of Appendix C of 40 CFR Part 112).

The Clean Water Act prohibits the discharge of oil into surface water in "such quantities as may be harmful" (33 USC 1321(b)(3)). Under federal regulations, this definition includes discharges of oil that violate applicable water quality standards or that cause a film, sheen or discoloration on the water or adjoining shorelines (40 CFR 110.3). A facility that discharges oil to surface water in a potentially harmful quantity must immediately notify the National Response Center (NRC) at 1-800-424-8802 (40 CFR 110.6).

 

Vehicles

Vehicle and Equipment Fueling

Your facility may have a fueling system (diesel, gasoline, etc.) for vehicles or equipment that involves aboveground storage tanks. To minimize the potential for fuel spills and leaks and reduce their potential to enter the storm sewer system, implement the following best practices:

  1. Cover catch basins with storm drain covers while fueling.
  2. Make certain that spill kits containing dry, absorbent materials for spill response are located near the area of fueling and that staff are trained in their use.
  3. Ensure that the transfer of fuel from/to fuel tanks and/or aboveground storage tanks is monitored by an attendant.
  4. Provide spill response training for personnel (in most states this is required by law).
  5. Post signs that give fueling instructions, spill response procedures, emergency contact information and best practices.
  6. Check loading/unloading equipment (valves, pumps, flanges, and connections) regularly for leaks. Replace worn or broken equipment.

Vehicle Use Best Practices

To assist in mitigating potential impacts to the environment from vehicle driving, follow these best practices:

  1. Keep tire pressure at the recommended level to improve fuel efficiency.
  2. Make certain that the vehicle's exhaust meets inspection requirements to minimize impacts to air quality.
  3. Ensure that your equipment/vehicles undergo regular tune-ups, and change the oil frequently. This will prevent your car's gas mileage from declining as it gets older and extends the life of the vehicle.
  4. Avoid making off-campus errands during rush hours. Congested conditions with their slow speeds, frequent acceleration, and stop-and-go movement increase air pollution. Also, if you find yourself doing multiple errands off-campus throughout the day, try to combine the errands. When you first start a car after it's been sitting for more than an hour, it pollutes up to five times more than when the engine is warm.
  5. Buy "green" vehicles.
  6. Avoid idling; this will conserve fuel. (Note: Many states have limits on the number of minutes idling may last.)

Vehicle Washing

Every time you wash a car or truck, water contaminated with oil, grit, antifreeze, and other automotive fluids rinses off. This runoff has the potential to find its way into bodies of water and ultimately contaminate them--a violation of state and federal regulations. Also, if your floor drain is tied into the local sewer system, the treatment plant may have discharge limits that you are required to meet.

You can take action to address the issue. You might simply cover your floor drains with a concrete patch, or install an oil/water separator. If you wash vehicles at your facility--especially if you're not sure where the runoff goes--it is highly recommended that you review key points of the National Pollutant Discharge Elimination System regulations that are covered in detail in the links that follow.

 

Vehicle Washing Best Practices

Even when not required by environmental regulations, the following best practices are recommended. In some instances, best practices presented here are actually required by regulations.

 

Non-Stormwater Discharges
Most grounds/vehicle maintenance facilities have outdoor activities that include but are not limited to equipment/material cleaning and maintenance. These activities may result in liquids being released to pavement, which could result in non-stormwater discharges to the storm drain system. The following activities may assist in minimizing non-stormwater discharges:

  1. Inspect the storm drain system, including catch-basins, inlets and pipes, and discharge points (at least quarterly) for evidence of non-stormwater discharges resulting from grounds/vehicle maintenance activities.
  2. Eliminate non-stormwater discharges to the storm drain system such as vehicle/tools/equipment wash water, saw-cut slurry, and building washing.
  3. Keep catch basin inlets free of debris.

Vehicle and Equipment Washing

Vehicle and equipment washing have the potential for contaminating receiving waters through the discharge of grit, oil and other contaminants. State and federal regulations have strict guidelines concerning the discharge of vehicle wash water; check the regulatory section (NPDES) of this facility area for more regulatory information.

  1. Soapy or oily vehicle wash waters must either be collected for off-site disposal or discharged to the sanitary sewer, if allowed by the local sewer authority.
  2. Consider using a commercial car wash if your facility is not equipped properly.

Waste Oils

A vehicle maintenance facility that doesn't generate waste oil? Impossible! Making waste-oil management simple? Very possible. In many states, waste oil is classified as a state-regulated hazardous waste. Here are just a few important considerations for handling, recycling and disposing of it:

  • Recycle waste oil instead of disposing of it. In many states, the volume you recycle doesn't affect your standing as a waste generator--whether large, small or conditionally-exempted.
  • Be aware that if waste oil is classified a hazardous waste in your state, a large-quantity generator status may be applied to your entire campus if you generate waste oil above certain levels.
  • Check to see whether mixing used oil with other petroleum products or solvents triggers a different waste classification.
  • Storing more than 1,320 gallons in combined total aboveground storage or 42,000 gallons combined total underground storage of used may require you to implement a Spill Prevention, Control and Countermeasure (SPCC) Plan.
  • If state regulations permit, crush used oil filters over a waste oil drum to increase the amount of oil extracted from the filter--and also decrease disposal costs.
  • Waste oils containing PCBs must be properly handled according to PCB requirements.

Transportation Safety Topics (New! 5/2020)

Resources on Work Zone Safety

 


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