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Even when not required by regulations, the following best practices 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:
- Wear acid-resistant gloves and safety glasses;
- Double-bag damaged batteries in polyethylene plastic bags that are at least six millimeters in thickness;
- If 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 six-millimeter polyethylene plastic bags.
Lead-Acid Batteries - Storage & Labeling
- 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.
- Freezing temperatures may cause spent batteries’ cases to crack.
- Storage areas should be sealed with an acid-resistant material and have
a containment berm.
- 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.)
Lead-Acid Batteries - Spills & Acid Debris
- Keep the following supplies in your lead-acid battery storage area: acid-resistant
gloves; a supply of polyethylene plastic bags (six millimeter 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.
- 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.
- Keep a supply of lime or baking soda on hand to neutralize acid spills.
- 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 likely contain lead and
would have to be managed as such, not just as 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.
Aerosols/Paint Management
- 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.
- 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.
- To minimize disposal costs, ensure that truly empty aerosol containers are either sent to a scrap-metal recycler or disposed of in the trash.
- Minimize excess liquid paint by making efficient use of paint "poured" for use, i.e., use what you pour.
Pesticides
- Keep pesticides dry and out of the way of activities that might puncture or knock over a jug or rip open a bag or box.
- Put a curb around the floor to prevent chemicals from spreading to other areas, if pesticides spill.
- If a spill does occur, an impermeable (waterproof) floor, such as concrete, should virtually eliminate any seepage of chemicals into the ground. Cleanup should be immediate because many pesticides will penetrate and be absorbed into concrete.
- Post best management practices related to pesticides on the walls of the grounds/vehicle maintenance facility so that they are easily accessible and remind the staff to handle pesticides properly.
- Secondary containment provides an impermeable floor and walls around the storage area, which will minimize the amount of pesticide seeping into the ground if a bulk liquid pesticide storage container should leak.
- Mixing/loading pads provide secondary containment during the dilution or transfer of pesticides to spraying equipment or nurse tanks.
- Store pesticides in original containers that are closed, labeled, and in a secure area out of reach of children and pets. Pesticides should not be stored near food.
- Use rubber gloves when handling pesticides and use an appropriate breathing zone protection if you are using products extensively.
- Do not use or give away banned pesticides or pesticides that are no longer registered for use.
- Do not reuse pesticide containers.
- Consider implementing an Integrated Pest Management (IPM) program at your college or university. IPM combines chemical, cultural, and biological control practices into one program to manage pest populations. In an IPM program, pesticide applications are carefully timed and combined with other pest management practices to reduce the need for frequent applications. Identify the pests, determine pest populations and damage, and make pesticide applications only when necessary, using the lowest rate necessary for adequate pest control. Minimizing the amount of pesticide used reduces costs and helps protect the environment.
- Disposal of pesticide wastes, unused pesticides, residues, and cleanup materials needs to be evaluated to determine if there are any applicable RCRA hazardous waste requirements. A complete discussion of potentially applicable RCRA requirements may be found in the Waste Storage section of the EVC.)
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:
- Keep the parts cleaner closed when not in use.
- Reduce solvent evaporation by increasing freeboard and placing hoods or covers on all parts cleaning tanks.
- Utilize less toxic non-chlorinated solvent cleaners or aqueous-based cleaners to reduce worker exposure and hazardous waste generation.
- Use one multi-purpose solvent instead of many different solvents to increase recycle potential of the solvent.
- Consider using a service to maintain your parts cleaning unit.
- Consider pre-cleaning parts with a rag or wire brush.
Waste Reduction and Recycling
To minimize the amount of waste generated at your facility, consider the following:
- Mix only the amount of paint needed for a job.
- Use self-contained sinks and tanks when cleaning with solvent.
- Do not accept "donations" of paints, chemicals, oil, etc. if it is not absolutely clear what is in the substances and/or if the campus has no immediate use for them. Waste disposal costs can be expensive.
- 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.
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:
- Cover catch basins with storm drain covers while fueling.
- 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.
- Ensure that the transfer of fuel from/to fuel tanks and/or aboveground storage tanks is monitored by an attendant.
- Provide spill response training for personnel (in most states this is required by law).
- Post signs that give fueling instructions, spill response procedures, emergency contact information and best practices.
- Check loading/unloading equipment (valves, pumps, flanges, and connections) regularly for leaks. Replace worn or broken equipment.
Transformers
Manufacture of PCBs was halted in the 1970s, but some PCBs may still be found in transformers, capacitors, heat transfer systems and hydraulic systems.
- All PCB transformers should be leak proof.
- 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.
- 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.
- 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.
- The storage facility should be located above flood water level.
- 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.
- 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.
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:
- 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.
- Eliminate non-stormwater discharges to the storm drain system such as vehicle/tools/equipment wash water, saw-cut slurry, and building washing.
- 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.
- 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.
- Consider using a commercial car wash if your facility is not equipped properly.
Vehicle Use
To assist in mitigating potential impacts to the environment from vehicle driving, follow these best practices:
- Keep tire pressure at the recommended level to improve fuel efficiency.
- Make certain that the vehicle’s exhaust meets inspection requirements to minimize impacts to air quality.
- 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.
- 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.
- Buy "green" vehicles.
- Avoid idling; this will conserve fuel. (Note: Many states have limits on the number of minutes idling may last.)
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:
- Avoid transferring materials close to storm drain inlets.
- Transfer liquids only in paved areas. Portland cement paving should be used if the liquid is asphalt reactive.
- 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.
- 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.
- Maintain adequate supplies of spill response equipment and materials in accessible locations near areas where spills may be likely to occur.
- Clean up minor spills immediately.
- Conduct regular inspections of storage and containment equipment and promptly correct deficiencies to this equipment as necessary.
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:
- 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.
- Store drums and containers on pallets or other structures to keep the container
out of contact with storm water.
- 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.
- 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.
- 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.
- Maintain adequate supplies of spill response equipment and materials in
accessible locations near areas where spills may be likely to occur.
- Post signs at all chemical storage locations in clearly visible locations
noting the materials stored, emergency contacts, and spill cleanup procedures.
- 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.
- Whenever possible store materials under a roof or otherwise cover stored
materials to minimize storm water impacts.
- Make sure dumpster covers are closed except when adding trash to prevent
infiltration and subsequent release of oils to receiving waters.
Waste Handling and Disposal
Best practices related to waste handling and disposal include the following suggested activities:
- Perform regular housekeeping activities in waste storage areas.
- Reuse or recycle materials whenever possible.
- Inspect waste management areas for spills and waste management containers
for leaks.
- Track waste generated, evaluate the process generating the waste and look
for ways to reduce waste generation.
- Characterize waste streams.
- Find substitutes for harmful chemicals; properly dispose of unusable chemical
inventory.
- Segregate and separate wastes.
- Do not dispose of liquid wastes such as oils or hazardous materials into
dumpsters.
- Maintain adequate supplies of spill response equipment and materials in
accessible locations near areas where spills may be likely to occur.
- Equip waste transport vehicles with spill containment equipment.
- 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.
Employee Training
Training employees in proper procedures to reduce your facility’s impact on the environment is a best practice and in some instances a regulatory requirement. More detailed training information is provided in the regulatory requirements sections of the EVC. 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 and waste management,
- Emergency preparedness, and
- Awareness-level training, for example, a general overview of the school’s environmental management system.
General Maintenance/Repair Work
When performing general vehicle repair/maintenance work near floor drains, implement the following to the maximum extent practical:
- 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.
- Drain and properly dispose of all fluids and remove batteries from vehicles, and equipment.
- Use biodegradable products and substitute materials with less hazardous properties where feasible.
- 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
- Store mechanical parts and equipment that may yield even small amounts of contaminants (i.e., oil or grease) away from drains.
- Sweep or vacuum the shop floor frequently.
- Designate specific areas indoors for parts cleaning.
- Clean up any spills promptly.
- Keep rags, mops, absorbents, and other cleanup supplies readily accessible to all work areas.
- Never sweep or flush wastes into a floor drain.
- Promptly transfer drained fluids to a designated waste storage area.
- Place bulk fluids, waste fluids, and batteries in secondary containment to capture accidental spills.
- Service "pits" should have concrete floors and not earthen floors or floors with drains.
- Service bays within the facility should be segregated by operation (brakes, radiator, oil changing, etc.) to avoid cross-contamination.
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