SWM-PS 990803STEPS TO DEVELOP A MUNICIPAL GOOD HOUSEKEEPING PROGRAM
FORUM AGENDA
AUGUST 3, 1999
(8:30 a.m. — 12:00 p.m.)
8:30 — Sign -in and Registration
8:40 — Welcome and Explanation of EPA's Four Components
Keith Kennedy, NCTCOG
8:50 — Explanation of TNRCC Program
Steve Ligon, TNRCC
9:00 — Interdepartmental (13ooperation
Shirin Yousuff, City of Fort Worth
9:20 —.Program Assessment
Carol Stuewe, TNRCC
9:35 — BMP Identification
Cornell Yancy, City of Grapevine
Pippa Couvillion, City of Frisco
10:15 — Establishing Measurable Goals for BMPs,
Jeff Rice, NCTCOG
10:30 — break
10:40 —Employee Training and Education
Shirin Yousuff, City of Fort Worth
11:00 - Tentative Video
11:15 - BMP Implementation
Leslie Calderon, NCTCOG
11:35 — Evaluation of BMP Performance and Open Discussion
Dr. James Caffey, City of Arlington
Forum adjourned at 12:00 p.m.
Watershed Organization Name
Storm Water Contacts in North Central Texas
Title
Phone Fax e-mail
Cast t-orK
City of Allen
Dan Tracy
Civil Engineer
972 - 727 -0167
972 - 727 -0165
dtracy @ci.allen.tx.us
East Fork
City of Balch Springs
William McDonald*
Director of Public Works
972 -557 -6095
972- 286 -7859
East Fork
Collin County
Ruben E. Delgado
Director of Engineering
972 - 424 -1460
972 - 548 -3754
engineering @co.collin.tx.us
East Fork
City of Garland
Philip Welsch*
Storm Water Management
972 - 205 -2189
972 - 205 -2823
pwelsch @ci.gadand.tx.us
East Fork
City of McKinney
David Simons*
Civil Engineering Designer
972 - 542 -2676
972 - 542 -2506
dsimons @mckinneytexas.org
East Fork
City of Mesquite
Matt Holzapfel, P.E.*
City Engineer
972 - 216 -6353
972 - 216 -6360
mholzapf @ci.mesquite.tx.us
East Fork
City of Plano
Kyle Odom*
Environmental Health Specialist
972 - 941 -7143
972 - 941 -7142
kyleo @gwmail.plano.gov
East Fork
City of Plano
Alan Upchurch
City Engineer
972 - 941 -7152
972 - 941 -7397
alanu @gwmail.plano.gov
East Fork
City of Richardson
Tom Moore*
Environmental Health - Water
972 - 238 -4170
972 -644 -2618
tom moore@cor.gov
Elm Fork
Denton County
Steve Rollins
Q uarfi,
940 - 565 -8624
940 - 565 -5657
—
East Fork
City of Rockwall
Chuck Todd
Public Works Director /City
972 - 771 -7790
972 - 771 -7748
Engineer
East Fork
Rockwall County
Bill Bell
County Judge
972 - 882 -0240
972 - 882 -0247
East Fork
City of Rowlett
N. L. Stewart
Director of Public Works
972 - 412 -6286
972 - 412 -6118
East Fork
City of Sachse
Gary Adams
Building Official
972 - 495 -7600
972 - 495 -4104
East Fork
TxDOT - Dallas District
Jay McCurley*
Environmental Quality Specialist
214 - 320 -6207
214 - 320 -6615
jmccurl @mailgw.dot.state.tx.us
Elm Fork
Town of Addison
— ....___._....._.._...__. -- .- -- -- ..._.__.- .... --
Jim Pierce *
Assistant City Engineer
972- 450 -2879
972 - 450 -2834
jpierce @ci.addison.bc.us
Elm Fork
City of Carrollton
Scott Hudson
Division Manager
972 -466 -3058
972 -466 -3175
shudson @ci.carrollton.tx
Elm Fork
City of Coppell
Kent Collins
Graduate Engineer
972 -304 -7019
972 - 304 -3570
kcollins @ci.coppell.tx.us
Elm Fork
City of Corinth
Mike Fairfield
Public Works Director
940 - 497 -2263
940 - 321 -5564
Elm Fork
City of Denton
Dale Hoelting
Drainage Engineer /Fld Plain Adm.
940 -349 -7180
940 - 349 -7334
dehoelti @cityofdenton.com
Elm Fork
Denton County
Steve Rollins
Director of Planning
940 - 565 -8624
940 - 565 -5657
srollins @co.denton.tx.us
Elm Fork
Denton County
Jack Wagner
Director, Centralized Road &
940 - 565 -8690
940 - 565 -5620
Bridge
Elm Fork
City of Double Oak
Richard Cook
Mayor
972 - 539 -9464
972 - 539 -9613
Elm Fork
City of Farmers Branch
Jerry Murawski
City Engineer
972 - 919 -2588
972 - 241 -6305
murawskj @ci.farmers - branch.tx.us
Elm Fork
Town of Flower Mound
Robert Milton
Director of Public Works
972 - 874 -3150
972 - 539 -2798
Elm Fork
City of Frisco
Gary Hartwell
Public Works Director
972 - 335 -5520
972 - 335 -5559
Elm Fork
City of Grapevine
Cornell Yancy
Engineering Drainage Coordinator
817 - 410 -3137
817- 410 -3003
Elm Fork
Town of Hickory Creek
Mike Milisavljevich
Director of Public Works
940 - 497 -2528
940 - 497 -3531
* Member of the Regional Storm Water Management Coordinating Council August 2, 1999
Watershed Organization Name Title Phone Fax e-mail
Elm Fork
City of Highland Village
Tim Huffman
Street Superintendent
972 - 317 -1688
972 - 317 -0998
Elm Fork
City of Irving
Karen C. Siddall
Drainage Utility Specialist
972 - 721 -2772
972.721.2592
publicworks @cityofduncanville.com
Elm Fork
City of Irving
Diane Malas, Ph.D.
Water Pollution Control
972 - 721 -2247
972 - 721 -2280
dmalas @ci.irving.tx.us
Mainstem
City of Hutchins
Curly White
Supervisor
972 - 369 -1300
972 - 225 -5559
Elm Fork
City of Irving
Mike Walter*
Engineering Supervisor
972 - 721 -2789
972 - 721 -2592
mwalter @ci.irving.tx.us
Elm Fork
City of Lake Dallas
Stewart Fairbum*
City Manager
940 - 497 -2226
940 - 497 -4485
scf @ix.netcom.com
Elm Fork
City of Lewisville
T.S. Kumar*
Asst. City Engineer
972 - 219 -3492
972 - 219 -3487
kumar@cityoflewisville.com
Elm Fork
City of Southlake
Charlie Thomas
Deputy Director of Public Works
817 - 481 -5581
817 - 488 -6796
mpolley @ci.southlake.tx.us
Elm Fork
City of The Colony
Pat Dunlap
Public Works Director
972 - 625 -2741
972 - 624 -2298
Elm Fork
City of University Park
Gene R. "Bud" Smallwood
Director of Public Works
214- 987 -5400
214 - 987 -5499
........ .............. _.._....... . .... ..... _ ..... _._.. . ..... _._._..._......__...__.... — - -
caffeyj @ci.arlington.bc.us
Mainstem
City of Cedar Hill
--._-_ .._... .............
Charlie Hastings
-- -- -- -- -- - ----- ......... _ _ - --
Project Engineer in Training
-- - -------- .....
972- 291 -5370
_ .....
972 - 291 -5120
charlie.hastings@cedarhilltx.com
Mainstem
City of Cleburne
Julie Winchell*
Environmental Coordinator
817 - 645 -0961
817- 645 -0926
juliw @cleburne.net
Mainstem
City of Corsicana
Connie Standridge
City Engineer
903 - 654 -4884
903 -654 -4999
Mainstem City of Dallas Larry McDaniel* Manager, Storm Water 214- 670 -8141 214 - 670 -8047 Imcdanie @bigtex.ci.dallas.tx.us
Management
Mainstem Dallas County Public Dale Davidson Project Engineer 214 - 653 -6423 214 - 653 -6416
Works
Mainstem
City of Desoto
Thomas Johnson*
City Engineer
214 - 230 -9614
972 - 230 -5818
Mainstem
City of Duncanville
Dennis Schwartz*
Director of Public Works
972 - 780 -5015
972 - 780 -5077
publicworks @cityofduncanville.com
Mainstem
Town of Highland Park
Meran Dadgostar
Town Engineer
214 - 559 -9384
214 - 559 -9335
Mainstem
City of Hutchins
Curly White
Public Works Director
972 - 369 -1300
972 - 225 -5559
Mainstem
City of Lancaster
Jason Cosby
Public Works Director
972 - 227 -6075
972 - 227 -7220
jcosby @airmail.net
Maingtcm
(itv of Ceonn..illo
.yam.,,
"m Berman
.,6.. uciniaii
.:___.__
Director of Operations
972- 287 -2050
972 -287 -3891
Mainstem
City of Stephenville
Danny Johnson
Director of Public Works
254 - 918 -1223
254 - 918 -1207
djohnson @ci.stephenville.tx.us
Mainstem
City of Waxahachie
Jeff Chambers
Public Works Director
972 - 938 -2101
972 - 937 -5518
jhambers@waxahachie.com
Mainstem
City of Wilmer
Harold Finch
Public Works Director
972 - 441 -6373
972 - 441 -3194
_........ ._ ................_.
West Fork
. ... ....... _......._._._..........._ ... ...... ................ .................. _......................
City of Arlington
..._....._._.._.......__..__...._ ........... . ... _...._.......... - -.... _..._ .. .........
James E. Caffey, Ph.D., P.E.
- _ . ...... _...... - .......... - .... .......... . .. _. . ...... I. ............... - ._... -- ..... . .....
Environmental Manager
_....... ...... . .. - - .._..- - ....__..__.....
817 - 459 -6568
-- - ....... . ........... ............... .
817 -459 -6538
........ .............. _.._....... . .... ..... _ ..... _._.. . ..... _._._..._......__...__.... — - -
caffeyj @ci.arlington.bc.us
West Fork
City of Azle
Mike Shingler*
Director of Community
817 - 444 -2541
817 -444 -7149
mshingler @ci.azle.bc.us
Development
West Fork
City of Bedford
Ronald Sullivan
Senior Engineer
817 - 952 -2246
817 - 952 -2240
West Fork
City of Benbrook
David R. Gattis, AICP*
Assistant City Manager
817 - 249 -3000
817 -249 -0884
cityhall @ci.benbrook.tx.us
West Fork
City of Blue Mound
Bill Harrison
Mayor Pro Tern
817 --
817 - 232 -0665
West Fork
City of Burleson
Kirk Barnes
Environmental Services Manager
817 -447 -5400
817 - 426 -1906
kirktbarnes @hotmail.com
* Member of the Regional Storm Water Management Coordinating Council August 2, 1999
Watershed
Organization
Name
Title
Phone
Fax e-mail
West Fork
City of Colleyville
Randell G. Brown
Public Works Manager
817 - 540 -0609
817 -354 -0469 Randellb @flash.net
West Fork
City of Crowley
Jim McDonald
Public Works Director
817 - 297 -9771
817 - 297 -6178
West Fork
City of Dalworthington
Greg Shugart
City Administrator
817 - 274 -7368
817 - 265 -4401 dwgctyhall @aol.com
Gardens
West Fork
Town of Edgecliff Village
Charles Talbot
Director
817 - 293 -4313
817 - 293 -8726
West Fork
West Fork
West Fork
West Fork
West Fork
West Fork
West Fork
West Fork
West Fork
West Fork
West Fork
West Fork
West Fork
West Fork
West Fork
West Fork
West Fork
West Fork
West Fork
West Fork
West Fork
West Fork
West Fork
West Fork
West Fork
City of Euless
City of Euless
City of Everman
City of Forest Hill
City of Fort Worth
City of Grand Prairie
City of Haltom City
City of Hurst
City of Keller
City of Kennedale
City of Lake Worth
Town of Lakeside
City of Mansfield
City of North Richland
Hills
Town of Pantego
City of Richland Hills
City of River Oaks
City of Saginaw
City of Sansom Park
Tarrant County
TxDOT - Fort Worth
District
City of Watauga
Town of Westover Hills
City of Westworth Village
City of White Settlement
Paul Kruckemeyer
Andrea Baxter
Earl Keaton
Michael Duehring
Gene Rattan*
Lynn S. Hurley
Greg Van Nieuwenhuize
Jim Sparks
Michael H. Barnes
Michael Box
Terry Highfill
Bill Boomer
David McCarver
Gregory W. Dickens
Ronald Gibson
John Cherry
Tommy Troutman
Dolph Johnson
Marvin Gregory
Robert Berndt*
Dean Tesmer*
Johnnie Reagan
Robert Ralph
Nancy Tsavis
Mark White
City Engineer
Assistant Director
City Manager
Director
Environmental Manager
Environmental Specialist
City Engineer
City Engineer
Director of Public Works
Director of Development
Director of Public Works
City Engineer
Public Works Director
Public Works Director
Director
Public Works Director
Public Works Superintendent
Public Works Director
Superintendent
Enviromental Specialist
Environmental Quality Supervisor
Director of Public Work & Parks
Public Works Director
Director
Director of Public Works
817- 685 -1629
817 -685 -1646
817- 293 -0525
817 -534 -3591
817 - 871 -5463
972 - 237 -8058
817- 222 -7750
817 - 788 -7080
817 -431 -1055
817 -478 -5418
817- 237 -1211
817- 335 -5065
817 -473 -9371
817 - 581 -5521
817 -254 -1765
817- 595 -6629
817 - 626 -5421
817- 232 -4640
817- 626 -3791
817- 884 -2634
817- 370 -6627
817- 514 -5837
817 - 737 -3127
817 - 738 -3673
817 - 246 -4971
817- 685 -1617
817 -685 -1664
817 - 551 -7549
817 -534 -4207
817 - 871 -5464
972 - 237 -8228
817- 222 -7755
817 - 788 -7097
817 -431 -2051
817 -483 -0720
817- 237 -1333
817- 238 -9187
817 -477 -1416
817 -656 -7538
817- 265 -1375
817- 595 -6652
817- 624 -2154
817- 232 -9868
817- 624 -2258
817 -884 -1178
817- 370 -6759
817 -427 -0935
817- 737 -3130
817 - 738 -0535
817 - 246 -8761
rattang@ci.fort-worth.tx.us
jcumming @ci.grand - prairie.tx.us
enadept@flach. net
kellerpw @gte.net
dmccarver@mansfield-tx.com
nrhpwadm @airmail.net
djohnson @ci.saginaw.tx.us
rberndt@tarrantcounty.com
dtesmer@mailgw.dot.state.b(.us
johnniereagan @ci.watauga.tx.us
* Member of the Regional Storm Water Management Coordinating Council August 2, 1999
�R NEW
Proposed Phase II
y.
6 Minimum Measures
• Public education and outreach on storm water
impacts
• Public involvement/participation
One in a Series of Forums for the
• Illicit discharge detection & elimination
Regional Storm Water Management
Program of North Central Texas
• Construction site stormwater runoff control
• Post-
Irving Central Library Auditoriu
construction stormwater management in
new development & redevelopment
August 3, 1999
• roiiu ion preventiontgood housekeeping for
municipal operations
Pollution Prevention /Good Housekeeping
Pollution Prevention /Good Housekeeping
for Municipal Operations
for Municipal Operations (cont.)
• You must develop and implement a cost - effective
EPA recommends that, at a minimum,
operations and maintenance program to prevent or reduce
you consider the following as
pollutant runoff from municipal operations.
components of your program:
- Maintenance activity schedules
• Provide employee training
and inspections to reduce
• Park and open space maintenance
floatables and other pollutants
• Storm drain system maintenance
- Controls for reducing pollutants
g p " s
• Fleet maintenance
from streets, parking lots,
• Building management
corporation yards, and solid
waste s operations
• Planning
- Proper disposal of waste removed
from storm drains
- Assess water quality impacts of
new flood control projects
STEPS TO DEVELOP A MUNICIPAL GOOD
HOUSEKEEPING-P2 RO RAM
STEPS TO DEVELOP A MUNICIPAL GOOD
HOUSEKEEPING P2R GRAM
an77--
sta e & Street 8 Road Storm Sewer Rec din =Par Waste Flood Buildi
k_Meintenance P.,. on Maintenance Y 9 Mainw Transfer I Control I Maintenance
i Interdepartmental Cooperation
ning and Education Plan
Implementation
Dlementation Phase
STEPS TO DEVELOP A MUNICIPAL GOOD
HOUSEKEEPING P2ROGRAM
Landsce e& Street &Road Stone Sewer R dm fleet Waste Flood Buildin
Perk Maintenance Operations Maintenance 9 Maintenance Transfer Control Maintenance
Interdepartmental Cooperation
Plan
Development
-'� Phase
STEPS TO DEVELOP A MUNICIPAL GOOD
HOUSEKEEPING P2R GRAM
.Canasta e 8 Street & Roed Storm Sewer Fleet r 7--' Flood Buildin
Perk Maintenance Operations Maintenance Regdiny Maintenance Transfer Conhol Maintenance
Plan
Evaluation/
Modification
Phase
i Interdepartmental Cooperation i
Establishing Measurable Goals for BMPs
• Under Phase II, EPA requires "measurable goals" to be
specified for each of the six minimum control measures
• Permittees required to identify the BMPs and associated
measurable goals in NOI
• Meant to gage permit compliance and program
effectiveness
• "Measurable goals" unique to Phase If
• EPA recognized that some Phase I management plans
include similar provisions
- inspection of a specific number of storm drains per year
— stencil inn stnrm eirain inhnfc each nnrmif .sew
- operate a permanent, year -round HHW facility
MOST COMMONLY USED BMPs THROUGOUT THE REGION
i8X O BB
go% ■ H
0
68% 68Y.
Ba% 64% 88% 68% ® G
6oX 60% 58%
of
52% 52%
E
0
MM
■0
no
13 U
o cc
■ dd
B H F G I K L M 0 0 U cc dd
B
Cohim llMerb ye-apingand ickingluplitterrequiarly.
H
Keep outside areas (dumpstens parking bra, etc.) free of trash and debris, and regularly dean them to
revers lutars build
F
Label all storm drain InleLa on municipal rounds with 'No Durr ' message
G
Clean u Its Immodesty to minimize safety hazarda and deter Ili
I
Use absorbent for liquid ' wills and sweeping and m000lm to clean outside areas.
K
Use designated wash areas, preferably covered, to prevent contact with storm water. Berm wash area. or
use other measures to contain wash water.
L
Property contain and dispose of clean materials ra towale absorbers materiels etc.
M
Cover fuel arses.
O
Pave fueling areas with concrete rather than asphah, or apply a sealant to protect asphalt from spilled
fuels.
O
Ua. absorbent materials or smell iRs end for oral claeni rather then hors down the area.
U
Recycle reases dl 811iters arsitreez cleans adutbm bamerles and h rausc 8lransmleaon fluids.
«
Use lardscaping pesticides and fanilizers wtv as needed.
rid
Avoid over -water to revers ezces. runoff.
Establishing Measurable Goals for BMPs
• Measurable goal definition
- The expected outcome for a minimum control measure
or particular BMP expressed in a manner that can be
evaluated or assessed (NCTCOG, 1999)
• Concepts
- month and year BMP fully implemented
- frequency of proposed action
- percentage reduction in usage of potential pollutants
- percentage reduction in pollutants discharged
• Examples
- recycling program fully implemented by specified date
- training of appropriate employees conducted annually
- percentage reduction in annual pesticide use
- percentage reduction in floatables discharged
SELECTED CONTROL BMPs USED BY
SURVEY RESPONDENTS
BMP
i
BMP
F
Label all storm drain inlets on municipal grounds with 'No Dum i ' mewede
G
Claan u sills Immedia l to minimize safe hazards end deter s ilgn .
1
Use absorbent for I' uid s ills and swell i and m in to clean outside areas.
K
Use designated wash areas, preferably covered, to prevent contact with storm
water. Berm wash areas or use other measures to contain wash water.
M
Coverfuali areas
O
Pave fueling areas with concrete rather than asphah, or apply a sealant to protect
es halt Proms illad fuels.
O
Use absorbent materiels or mop up small spills, and for general cleaning rather the
hosing down the area.
cc I
Use landscaping pesticides and fertilizers onl as needed
dd..
Avoid over- waterin to prevent excess runoff
What New Programs
Do You Need?
• What's already being done?
— Quantify current programs
— Who manages these programs?
• Define where gaps exist
• Define which program elements are right
for your community
Setting the Right Course
Takes Time To...
• Conduct a thorough evaluation of
options
• Involve the public and build
consensus
• Make organizational adjustments, if
needed
• Get funding mechanisms in place
• Build the framework for regional
solutions
The sooner you start, the sooner you'll
see results.
Why Get Started Now?
After all...
• Phase II Rule is not finalized
• Tool box is not developed
• NPDES permitting
authorities (i.e. TNRCC)
have not defined additional
requirements
• Permitting time line seems
like a long way_ off (no
immediacy)
EPA Expected Costs of
Proposed Phase ll Implementation
First Permit Cycle
Percentage of Low End of Per High End of Per
Municipalities Capita Costs Capita Cosa
Expected to Incur ($ per Capita) ($ per Capita)
Measure: Costs ( %)
Public Education 39 $0.02 $0.34
Illicit Discharge Detection and 90 $0.04 $2.61
Elimination
Post Construction Storm Water 4 $1.09 $1.09
Management
re
J
S
S
E
Environmental Protection Workshop for Supervisors:
Do y2u know the correct answer, to these?
1. Can liquid paint go in the trash?
2. Is it okay to wash city vehicles with soapy water over a storm drain?
3. Who is contacted if there is a large ( >25 gallons) spill on the ground?
4. Can absorbent with auto fluids be disposed of in the trash?
5. Why must you never wash auto fluids and other chemicals down storm drains?
6. How is the information from the "Workplace Chemical List" used?
7. Why is it important to keep a current MSS binder' ?
8. Where do you pickup drums for storing hazardous &; regulated wastes?
9. How do you arrange for disposal of your hazardous and regulated wastes?
Good Housekeeping & Stormwater Protection
Topics Covered by the City of Fort Worth:
What a hazardous waste is and how to identify them
Smart chemical management principles
m' How to manage specific wastes that can contribute to
storm water pollution
What to do if there is a chemical spill at a city facility
how to minimize use and disposal of hazardous wastes
The City's Storm Water Quality Program
ar Evidence of stormwater pollution
ar Best Management Practices
Disposal of household chemical waste
What Is Considered A "Hazardous Waste "?
A waste is a discarded material that cannot be directly used in another process, and that must
be disposed of or recycled. A hazardous waste is a waste with one or more of the following
characteristics:
♦ Ignitable- chemicals that can be easily set on fire (flashpoint of less than 14F)
♦ Corrosive- acids and bases (pH of 2 or less or pH of 12.5 or higher)
♦ Reactive- normally unstable, or reacts violently with water, or is a sulfide or cyanide bearing
waste that generates toxic gases
♦ Toxic - poisonous if eaten, inhaled, or absorbed through the sidn
♦ Listed Hazardous Wastes- a list of known hazardous wastes in
provided in 40 CFR 261, Subpart D
9/15/98
Product Labels
A product's label is the most important way to find out about a product's hazards
(if there are any). Always read the label before you move, handle, or open a
chemical container. A label can tell you the following:
' The identity of the chemical, and what "chemicals" are contained in the product
The name and address of the company that manufactured or imported the
chemical
' The chemical's health hazards
' Storage and handling instructions
Protective clothing, equipment, and procedures
If a label is removed from a container, be sure to re- attach it. or write the
contents on the container! 100A
Material Safety Bata Sheets
Almost every chemical whether it is a hand cleaner or a pesticide has a'Material Safety
Data Sheet., It is important that when a chemical is purchased an MSDS accompanies the
package.
An MSDS provides all the information you need to know about how to properly store, use,
and dispose of a chemical. If the product's label does not provide adequate information,
always refer to the M5D5.
If you can not locate the MSD5, call the manufacturer (their number is usually on the
product's label) They can fax you one.
Always be sure to have the latest version of the product's M50S. Product formulations
may change.
Information provided on an MSDS includes:
Section I:
Supplier's Information
Section II:
Hazardous Ingredients /Identity Information
Section III:
Physical /Chemical Characteristics
Section IV:
Fire and Explosion Hazard Data
Section V:
Reactivity Data
Section VI:
Health Hazard Data
Section VII:
Precautions for Safe Handling and Use
Section VIII:
Control Measures
9/15/98
2
Smart Chemical Management Principles
• Only buy the amount you need what you need and can reasonably
use!
• Always ask yourself - "Is there a less hazardous alternative
product that I can use that will be safer to use and that will not
create a disposal problem ?"
• Make sure you have an MSDS for each chemical used
• Make sure each product is properly labeled!
• Flammable chemicals should be stored in a fire proof cabinet, away
from corrosive and toxic chemicals
• The best way to get rid of a product is to use it up!! If you can't
use it, find someone who can
• Don't store incompatible chemicals together (see attached list)
• Always make sure chemicals are stored in containers
that are compatible with the product
• If you must dispose of a product,
call Environmental Management
Wastes That Can't Go In The
Trash
(Note: these are also referred to as "REGULATED WASTES ")
9/15/98
3
Disposal of Paint and Thinner Waste
Hazardous Wastes that Non Hazardous
Wastes: n Ua be Wastes:
Hazardous:
Solvent based
Painting tools
Latex paints
paints (alkyd
(rollers, brushes,
(water based)
or oil based)
rags, drop cloths,
etc.)
Solvents and
Blasting abrasive
Latex paint
thinners
"wash" without
any solvent
Lead paint
chips
8
How to Manage Used Oil
Used oil is not considered a hazardous waste by the TNRCC, but it is still regulated
by the state under 30 TAC Chapter 324.
Used oil is easy and inexpensive to manage. Some key rules to follow are:
0 Containers used to store used oil must be good condition. Drums are provided by
the city's used oil recycler, but do not accept any dented or corroded drums for
storing the oil;
*The drums that are used must be labeled the words 'USED OIL" with letters 3"
tall;
• The recycler will transport the used oil from your site. You are not permitted to
transport more than 55 gallons of used oil without registering with the state as a
used oil transporter;
• Never dump used oil on the ground or down the drain. Contact Environmental
Management if you spill 25 gallons or more of used oil onto land or any amount that
creates a sheen in water;
*Always store drums of used oil on pallets; and
• Make sure any amount of used oil you accumulate is shipped out in 30 days or less
(month to month at least).
9
9/15/98
4
How to Manage Used Oil cost.
• Always store used oil in open top 55 gallon UN approved drums tanks designed for
storing used oil
0 Used oil and filters shipped to the recycler using a bill of lading or similar shipping
document. Please forward the originals to Environmental Management, and keep a
copy for your records.
*There must be sufficient spill equipment to handle a spill of at leas gallons f
every 55 gallon drum of oil and filters.
• Never mix used oil with other auto fluids, except:
-t transmission and hydraulic fluids, MOTOR MOTOR
-> petroleum based nonhazardous lubricating fluids, OIL OIL
O t�
-► hydraulic, cutting, gear and cooling oils, and IOW-40 10w -30
-� synthetic oils
Used oil mixed with other wastes or auto fluids can't be recycled and may have to be
handled as hazardous waste!
to
How to Manage Used Oil Filters
As with used oil, used oil filters are easy to manage. They are not considered
a hazardous waste stream, but they are still regulated by the state under 30
TAC Chapter 330.
The rules for managing used oil filters are as follows:
• Used oil filters including filter components cannot be disposed of in municipal landfills.
• Containers used to store used oil filters must be in good condition and not leaking
or rusted
• Used oil and filters shipped to the recycler using a bill of lading or other similar
document. Please forward the originals to Environmental Management, and keep a
copy for your records. These documents must be retained for at least three years.
• The drums that are used must be labeled the
words 'USED OIL FILTERS' with letters 3" tall
9/15/98
5
Managing Lead Acid Batteries
The EPA and TNRCC require spent lead acid (auto) & gel cell batteries to be
recycled or returned to the manufacturer order to exempt them from the
hazardous waste regulations. Lead acid batteries are prohibited from the
landfills and incinerators, largely because of their large lead content.
Some wise practices for managing lead acid batteries are:
=* DO NOT place batteries in the dumpster
=> Defective batteries and those still under warranty should be returned to the
supplier for credit
Where ever possible, store batteries to be recycled indoors in a designated area
Place batteries on wooden pallets, one battery high only
Keep neutralizing caustic available in the event a battery le
acid and call Environmental Management for clean -up.
Designated Waste Storage Areas
Each division /section at a city property should have its own waste storage
area. Additionally, a different waste storage container should be used for
each waste stream unless you are permitted to combine different wastes by
DEM.
Each waste storage area should be located in an area where:
There is controlled traffic
The division /section responsible for the area can control who deposits
waste
A bobtail truck can sample, and remove the drums without interfering
with the sites operations
Note: If you generate a lot of waste (on average, more
than 220 lbs /month at one address), you have many
additional requirements. Environmental Management
will provide additional training for staff at such locations
as is needed.
9/15/98
6
Waste Storage Site Assessment by DEM
As needed, OEM will go to each site that generates
hazardous or other regulated wastes to ensure that
wastes are being properly stored, and to make sure that
there are adequate supplies to ensure the safe and
complaint storage of the wastes.
A "Waste Storage Site Assessment Form" will be
completed, and a copy provided to the site supervisor so
that he /she will know the corrective actions that must be
taken.
14
What are Some Procedures that may Create a Spill or Release Outdoors?
Some examples:
• Consolidation of used motor oil in drums
• Consolidation of waste fuels from city vehicles or planes
• Application of pesticides /fungicides /outdoors
• Painting processes
• Changing machinery lubricant
• Chlorinating City pools
• Pumping gas or diesel
Whenever you are engaged in one of these process, or any other similar
procedure, please use caution to avoid a spill! Contaminated soil or grass is
both labor intensive and expensive to remediate. The Department of
Environmental Management can provide each site with spill response supplies
for small spills. Please use these them.
If you have spilled a toxic material, or a large quantity of a substance, please
call the Fire Department at 922 -3000. They will secure the scene, and call
Environmental Management for clean -up. 15
9/15/98
7
What is the Proper Procedure to Follow if there is a Spill?
Small Spills (generally, non - reportable spills per TAB
For spills or releases of automotive fluids onto land, departments may clean these
upon their own. But, the waste from the spill (absorbent pads, kitty litter) should
be handled as a hazardous waste. Contact Environmental
Management (561 -3700) for waste pick -up.
Large Spills (generally, reportable spills per TAC):
For spills of larger than 25 gallons of an automotive fluid on land and /or water
and spills of any quantity of a hazardous substance, or when in doubt, call the
Fire Department at 911 (or 922- 3000). The Fire Department is called as the
first responder to secure the scene. They may then contact the Environmental
Management Spill team to handle the clean up.
If you are ever in doubt about the substance that has spilled,
call 911!
16
Absorbent with Auto Fluids (oil, gasoline, antifreeze, & others) is a
Class I waste - it can't go in the trash! Contact DEM for disposal at
X8504.
,IIIIj� Remember!
)I:
Il�! Absorbent
i+ i with Auto
Fluids
Cannot go in �•�
the Trash.
Place it in
WIs this special
drum
Used OiI j <= /
Absort>�tt
re..—
9/15/98
N.
Waste Minimization Strategies
More often than not, any process or procedure where chemicals are used can
benefit from waste minimization. Ask yourself the following questions:
• Is there a less hazardous chemical that I can use?
• Am I buying only the quantity I need?
• Can another department or division use any leftover product?
• Can a waste be recycled and used on site in another process?
• Am I doing everything I can to reduce the volume and
toxicity of the waste produced in my processes?
j
a4F*
O 1s
0
Look for Less Hazardous Chemical Alternatives
There are certain key words on a product's label (required by federal regulations)
that will tell you if it is hazardous or not:
Danger: A product with this word on its label indicates a high degree of exposure
hazard. A taste to a teaspoon full of this product could be fatal. Example: pesticides
and drain cleaners.
Warning: A product with this word on the label is dangerous, but less so than one
with 'danger" on its label. Example: cleaning products
Caution: Products with caution on their label are less hazardous than those with
'warning' or danger,' but can be fatal if a large enough dose in ingested. Example:
Non -toxic cleaners
A smart practice is to buy read a product's label and determine whether it is
hazardous. If one of the above words appear on the label, see if there is another
product that is less hazardous.
'O'Remember, if it's hazardous to you, it's hazardous
(and therefore, very expensive) to dispose of
19
9/15/98
9
Look for Less Hazardous Chemical Alternatives, cont.
Another smart strategy is to AVOID products that fall into one or more of
these categories:
♦ Chlorinated Compounds: such as "trichloroethane" or "methylene
chloride ". Look for the prefix "chloro -" on the label;
♦ Aerosols: Spraying causes the contents of a container to:be:broken
down into small particles that can be inhaled. While sprays drC,1 dick
and easy to apply, they are hard to focus. This causes clou�l�f4he
aerosol to spread to nearby surfaces. =�`�, f'."I
P Y ...
♦ Sodium Hydroxide or Lye: These are caustic substances "that can-
cause severe burns. They are often found in drain openers";_;
♦ Phenols: These are toxic to the skin and if ingested, can,; se your
circulatory system to fail
♦ Petroleum distillates: These are compounds extracted from crude
oil. They are flammable and often found in solvents.
zo
Smart Paint Management Reduces Waste!
• Buy only the amount you need. Reducing waste at its source is the best way
to avoid having to deal with leftover paint disposal.
• If You store paint properly it will last for years. Paint manufacturers
suggest that painters cover paint can openings with plastic wrap and make
sure the lid is tightly secured, then store the paint can upside down to
create a tight seal around the lid to keep paint fresh.
° Leftover paint should be used up. Properly stored paint can be used for
touch -up jobs and smaller projects. Smaller quantities of similar colors of
latex paint can be blended and mixed for use as a primer on larger jobs.
• Leftover point can be donated or exchanged. bo you know another painter
who may need some point? Is there a small amount of a certain color you
need? Try contacting another city painter who you can exchange with. It
will save you both money and time.
zr
9/15/98
10
What does the Water Quality Division Do?
The Department of Environmental Management Water Quality Division is
responsible for maintaining and monitoring water quality in urban lakes,
rivers, neighborhood creeks, and storm drains.
Storm drain systems are designed to remove storm water runoff quickly
from urban areas. In this part of the country, storm drain systems are
separate from sewage systems, and untreated runoff flows directly to the
nearest bodies of water.
The Problem: Contaminated Storm Water Runoff
Unfortunately, any pollutants such as pesticides, oil, and detergents that are
present on urban land, streets, or other surfaces are carried along. This also
means that anything a person might pour into or dispose of in a storm drain
inlet goes directly into a body of water the next time it rains.
22
It is
VERY
IMPORTANT
to protect
storm drains
from
oo I I utants!
23
9/15/98
11
Unfortunately, any
pollutants such as
pesticides, oil,
detergents, fuels
(gasoline and diesel),
and emulsified asphalt
that are present on
urban land, streets, or
other surfaces are
carried along with the
rain.
2.1
9/15/98
12
Q. Is there just sand and mud going down storm
drains, or are chemicals also entering them?
A. 5ee below:
This is a *passive
skimmer "that was
placed in a storm drain
at an ESD facility. It
selectively absorbs
hydrocarbons (oil,
grease) to reduce the
amount washed down
the drains.
The brown areas are
absorbent
contaminated with
pollutants. The
skimmer had only been
in use for 2 weeks.
26
To Help Avoid Stormwater Pollution Caused By Your Various Activities,
We Recommend The Following "Best Management Practices"
• Maintain all vehicles and heavy equipment. Inspect frequently for leaks,
especially at 'deadlines."
• Conduct all vehicle/equipment maintenance and refueling at one location—
away from storm drains.
• Use drip pans or drop cloths to catch drips and spills if you drain and replace
motor oil, radiator coolant, or other fluids on -site.
• Collect all used fluids, store in separate containers and recycle whenever possible.
• Sweep up dry spilled materials immediately. Never attempt to bury them or "wash
them away' with water.
• Use and maintain curb inlet protection such as silt fencing, hay bales, oil
absorbent boom, etc.
• dean up spills on dirt areas by digging up and properly disposing of contaminated soil.
• Report significant spills to the Fire Department. They will contact us to assist
with the clean up as needed.
• Clean up leaks, drips, and other spills immediate .
• Cover stockpiles and excavated soil with secured tarps or plastic sheeting.
27
9/15/98
13
Pesticides are also a BIG problem in wastewater!
The Problem:
Traces of certain pesticides sometimes get into Fort Worth's sewer system,
then they go through the treatment plant, and into the Trinity River.
Unfortunately, these pesticides have been arriving at the Trinity River at levels
high enough to harm the river's water quality!
Village Creek Waste Water Treatment Plant is an award winning facility, but it was
never
designed to remove pesticides.
The two pesticides of particular concern are: MALATHION $ DIAZINON
What City of Fort Worth Employees Can Do To Help:
./Stop using either of this chemicals! If you have any at your facility,
don't use it & complete a Hazardous Waste Disposal Request Form to
have it disposed of.
./Never pour pesticides or allow rags, etc. with its residue to be washed
down any sinks,tubs, or drains.
,(Avoid over - application of pesticides and over -spray onto pavement. 28
Information about the
Environmental Collection Center
0
K/Ikr /
w(nrniin �
Pool rise _ _ Kill - -0- Weed
Latin Point
29
9/15/98
14
Introducing:
' Captain Crudl
What is the Environmental Collection Center?
The City of Fort Worth has established a regional program to help people
dispose of their household chemical wastes in an environmentally responsible
manner.
The Environmental Collection Center (ECC), located at 6400 Bridge
Street in Fort Worth. It is open to residents of Fort Worth and participating
cities on:
• Thursdays and Fridays from 11 a.m. until 7 p.m. and on
• Saturdays from 5) a.m. until 3 p.m.
The number for the ECC information line is (817) 871 -5257.
30
9/15/98
15
Reducing Stormwater Pollution:
A Guide for City of Fort Worth
Employees
Background Information
Urban stormwater is one of the most significant sources of pollution in our
nation's rivers and lakes„ Urban stormwater is the third largest source of
impairment in lakes and fourth largest source of river damage. One of the
reasons urban areas contribute so much pollution is that 63% of the US
population lives in urban areas, which collectively account for only 2% of the
nation's land area. Because of this problem, the Environmental Protection
Agency (EPA) has issued a National Pollution Discharge Elimination System
(NPDES) Permit to cities with a population of over 100,000 people, such as
the City of Fort Worth.
This means that Fort Worth must closely control the amount of pollutants
that enter the storm drain system.
The City of Fort Worth Department of Environmental Management's Water
Quality Division is responsible for maintaining and monitoring water quality in
urban lakes, rivers, neighborhood creeks, and storm drains.
Storm drain systems are designed to remove storm water runoff quickly
from urban areas. In this part of the country, storm drain systems are
separate from sewage systems, and untreated runoff flows directly to the
nearest bodies of water.
Unfortunately, any pollutants such as pesticides, oil, detergents, fuels
(gasoline and diesel) or even emulsified asphalt that are present on urban
land, streets, or other surfaces are carried along with the rain. Anything a
person might pour or dump onto the ground or dispose of in a storm drain
inlet goes directly into a body of water the next time it rains.
c: stormwater guide 1
Revision: 3/99
Do we do anything now that
helps reduce stormwater
pollution ??
By implementing a number of street operation and maintenance activities,
the Streets Division helps the City stay in compliance with our Stormwater
Discharge (NPDES) Permit to "reduce the discharge of pollutants to the
maximum extent practicable."
Some of the ways the Streets Division helps the City minimize pollutants in
our storm drain system are:
♦ conduct-roadway spill cleanups (as required)
♦ street sweeping associated with seal coating projects
conservative use of deicing salt in a 1:29 ratio
♦ cleaning of curb /drainage inlets
♦ cleaning of borrow ditches and channels
Why Should We Implement "Best Management Practices" ?
There are additional "best management practices" or "BMPs" that can be
followed by divisions to further reduce pollutants that enter the City's
storm drain system.
Some of the activities that may contribute to stormwater pollution are:
Soil excavation and grading operations often contribute to urban runoff
pollution. By loosening large amounts of soil and sediment, earthmoving
activities can cause sediment to flow into storm drains. Sediment is the most
common pollutant washed from work sites, creating multiple problems once it
enters local lakes, rivers, and streams. Sediment clogs the gills of fish,
c: stormwater guide 2
Revision: 3/99
blocks light transmission and increases water temperature. This disturbs
the food chain upon which both fish and people depend.
Sediment also carries with it other work -site pollutants such as pesticides,
cleaning solvents, cement wash, asphalt, and car fluids like motor oil, grease
and fuel. Thus, poorly maintained vehicles and heavy equipment leaking fuel
and oil at construction sites also contribute to stormwater pollution.
To Help Avoid Pollution Caused By These Activities, We Recommend The
Following "Best Management Practices"
• Avoid excavation and grading activities during wet weather. Schedule
excavation and grading work for dry weather.
• Use as little water as possible for dust control.
• Maintain all vehicles and heavy equipment. Inspect frequently for leaks.
• Conduct all vehicle /equipment maintenance and refueling at one
location —away from :storm drains.
• Perform major maintenance, repair jobs, and vehicle /equipment washing
off -site.
• Use gravel approaches where truck traffic is frequent to reduce soil
compaction and limit -the tracking of sediment into streets.
• Use drip pans or drop cloths to catch drips and spills if you drain and
replace motor oil, radiator coolant, or other fluids on -site.
• Collect all used fluids, store in separate containers and recycle whenever
possible.
• Do not use diesel oil -to lubricate equipment or parts.
• If gasoline or diesel is used to wash out asphalt from truck beds, please
make every effort to collect the solvents for disposal. Or, use a less
hazardous chemical such as D -TAR for removal of asphalt.
• Sweep up dry spilled materials immediately. Never attempt to bury them
or "wash them away" with water.
• Use and maintain curb inlet protection such as silt fencing, hay bales, oil
absorbent boom, etc,)
• Clean up spills on dirt areas by digging up and properly disposing of
contaminated soil (Call Environmental Management at 871 -5468 for
disposal assistance).
c: stormwater guide 3
Revision: 3/99
• Report significant spills to the Fire Department. They will contact us to
assist with the clean up as needed.
• Clean up leaks, drips, and other spills immediately.
• Never hose down "dirty" pavement or surfaces where materials have
spilled. Use dry cleanup methods whenever possible.
• Construct diversion dikes to channel runoff' around the site. Line
channels with grass or roughened pavement to reduce runoff velocity.
• Cover stockpiles and excavated soil with secured tarps or plastic
sheeting.
Questions?
Call Environmental Management's Storm Water Quality Division
at 871 -5451.
c: stormwater guide 4
Revision: 3/99
Monitoring Program Delivery
Systems May Involve
• Strategic planning
• Comprehensive planning
• Tracking the number of capital projects
implemented
• Determining actual maintenance
frequencies and production rates
Monitoring Program Delivery
Systems May Involvf;
• Linking goals to outcomes in program
evaluation methods
• Measuring regulatory compliance
• Achieving public participation goals
Evaluation of Quantifiable
Outputs
• Set a goal - number of samples, percent of
responses within 24 hours. arrive at spills
within one hour
• Apply manpower to an operations strategy
• Measure or count successes out of total
• Compare against goal
• Reset goal, revise strategy or adjust resources
Monitoring Program Effectiveness
Includes Physical measurements that
determine how well the program is meeting
its goals. Common steps involve:
• Stream gauging and water quality sampling
• Channel bank erosion monitoring
• Fish habitat/population monitoring
• Sediment deposition monitoring
More Specific Measure
• East Bouldin Creek, Austin, Texas
• Most polluted creek in Austin
• Implemented non - structural and educational
best management practices
• To evaluate effectiveness. historical data
was used to select two baseline watersheds
• Ambient water quality and benthic
macroinvertebrate data .vas collected for
statistical comparison
Evaluating Public Involvement
and Education Programs
• Operation: Water Works conducted by the
City of Olympia. Washington, and partners
• Assessment of how effective the program has
been at reducing threats to the environment
from business sources
• Analyzed the projects activities and outcomes
• How well the goals set were achieved
Levels of Evaluative Evidence
Inputs (staff and volunteer time, money and
materials) that contribute directly to the
delivery of the activities (educational
involvement)
Reactions of targeted at certain participants
Personal reactions Contribute to participants
acquiring new Knowledge. Attitudes, Skills
and /or Aspirations
Levels of Evaluative Evidence
• Changes in KASA then lead to practice
changes
• These changes in behavior produce the
hoped -for end result
TABLE OF CONTENTS
Storm Water Phase II Proposed Rule Fact Sheet Series: Pollution
Prevention /Good Housekeeping Minimum Control Measure
Flow Chart: Steps to Develop A Municipal Good Housekeeping
P2rogram
Pollution Prevention for Municipal Operations
Best Management Practices (BMPs) For Municipal Operations
Useful References
Case Studies
United States Office of Water
Environmental Protection (4203)
Agency
EPA 833 -F -99 -010
April 1999
Fact Sheet 2.8
�
EPA Storm Water Phase II
Proposed Rule
Storm Water Phase II
Propsed Rule
Facia Sheet Series
Overview
1.0 - Storm Water Phase II
Proposed Rule Overview
Small MS4 Program
2.0 - Small MS4 Storm Water
Program Overview
2.1- Who's Covered? Deskination
and Waivers of Regulated Small
MS4s
2.2 - Urbanized Areas: Definition
and Description
Aitrunwn Cotarol Areasures
2.3 - Public Education and
Outreach Minimum Control
Measure
2.4 - Public Participation/
Involvement Minimum Control
Measure
2.5 - lAiat Discharge Detection and
Elimination Minimum Control
Measure
2.6 - Construction Site Runoff
Control Minimum Control Measure
2.7 - Post - Construction Runoff
Control Minimum Control Measure
2.8 - Pollution Prevention/Good
Housekeeping Minimum Control
Measure
2.9 - Permitting and Reporting:
The Process and Requirements
2 "pderal and State -Owned
-ogram Implementation
C ction Program
31 rstruction Program
Ow, V
kWv trial "No Exposure"
4.0 - Conditional No Exposure
Exemption for Industrial Activity
Pollution Prevention/Good Housekeeping
Minimum Control Measure
This fact sheet is based on the Stonn Water Phase 11 Proposed Rule. Therefore, the infonnation provided herein is subject to
change upon publication of the final Phase 11 rule in November 1999. A revised series of fact sheets will be provided at that
titne. A comprehensive list of the current fact sheets is in the text box at left.
This fact sheet profiles the proposed Pollution Prevention/Good Housekeeping for Municipal
Operations minimum control measure, one of six measures the owner or operator of a Phase II
regulated small municipal separate storm sewer system (MS4) would be required to include in its
storm water management program to meet the conditions of its National Pollutant Discharge
Elimination System (NPDES) permit. This fact sheet outlines the Phase H Proposed Rule
requirements and offers some general guidance on how to satisfy them. It is important to keep in
mind that the small MS4 owner or operator would have a great deal of flexibility in choosing exactly
how to satisfy the minimum control measure requirements.
Why Is Pollution Prevention/Good Housekeeping Necessary?
The Pollution Prevention/Good Housekeeping for municipal operations minimum control measure
is a key element of the proposed regulated small MS4 storm water management program. This
measure would require that the small MS4 owner or operator examine and subsequently alter their
own actions to help ensure a reduction in the amount and type of pollution that (1) collects on streets,
parking lots, open spaces, and storage and vehicle maintenance areas and is discharged into local
waterways; and (2) results from actions such as environmentally damaging land development and
flood management practices or poor maintenance of storm sewer systems.
While this measure is meant primarily to accomplish the goal of improving or protecting the quality of
receiving waters by altering the performance of municipal or facility operations, it also can result in a
cost savings for the small MS4 owner or operator, since proper and timely maintenance of storm
sewer systems can help avoid repair costs from damage caused by age and neglect.
What Is EPA Proposing?
Re cognizing the benefits of pollution prevention practices, the proposed rule would require an
owner or operator of a regulated small MS4 to:
❑ Develop and implement an operation and maintenance program with the ultimate goal of
preventing or reducing pollutant runoff from municipal operations into the storm sewer
system;
❑ Include employee training on how to incorporate pollution prevention/good housekeeping
techniques into municipal operations such as maintenance of parks and open spaces, fleets,
buildings, and storm water systems, as well as land development planning. To minimize
duplication of effort and conserve resources, the MS4 owner or operator cguld use training
materials that are available from EPA, their State or Tribe, or relevant organizations;
❑ Determine the appropriate best management practices (BMPs) and measurable goals for this
minimum control measure. Some program implementation approaches, BMPs (i.e., the
program actions/activities), and measurable goals are suggested below.
Fact Sheet 2.8 — Pollution Prevention/Good Housekeeping Minimum Control Measure Page 2
What Are Some Guidelines for Developing and
Implementing This Measure?
The intent of this control measure is to ensure that existing
municipal or facility operations are performed in the most
appropriate way as to minimize contamination of storm water
discharges.
EPA encourages the small MS4 owner /operator to consider the
following components when developing their program for this
measure:
What Would Be Appropriate Measurable Goals?
Measurable goals, which would be required for each minimum
control measure, are meant to help gauge permit compliance
and program effectiveness. The measurable goals, as well as the
BMPs, would greatly depend on the needs and characteristics of
the owner /operator and the area served by its small MS4. The
measurable goals should be chosen using an integrated approach
that would fully address the requirements and intent of the
minimum control measure. An integrated approach for this
minimum measure could include the following measurable goals:
Maintenance activities, maintenance schedules, and Target Date
long -term inspection procedures for structural and non-
1 year............
structural controls to reduce floatables and other
pollutants discharged from the separate storm sewers;
Controls for reducing or eliminating the discharge of
pollutants from areas such as roads and parking lots,
maintenance and storage yards (including salt/sand
storage and snow disposal areas), and waste transfer
stations. These controls should include programs that
promote recycling (to reduce litter), minimize pesticide
use, and ensure the proper disposal of animal waste;
Procedures for the proper disposal of waste removed
from the separate storm sewer systems and the areas
listed in the bullet above, including dredge spoil,
accumulated sediments, floatables, and other debris; and
Ways to ensure that new flood management projects
assess the impacts on water quality and examine
existing projects for incorporation of additional water
quality protection devices or practices. EPA encourages
coordination with flood control managers for the purpose
of identifying and addressing environmental impacts
from such projects.
The effective performance of this control measure hinges on the
proper maintenance of the BMPs used, particularly for the first
two bullets above. For example, structural controls, such as
grates on outfalls to capture floatables necessitate that the outfalls
be cleaned out regularly, while non - structural controls, such as
training materials and recycling programs, need to be updated
periodically.
2 years..........
3 years..........
4 years..........
Contact
Activity
Pollution prevention plan (the new BMPs and
revised procedures) completed; employee
training materials gathered or developed;
procedures in place for catch basin cleaning
after each storm and regular street sweeping
Training for appropriate employees completed;
recycling program fully implemented
Some pollution prevention BMPs incorporated
into master plan; a certain percentage reduction
in pesticide and sand/salt use; maintenance
schedule for BMPs established
A certain percentage reduction in floatables
discharged; a certain compliance rate with
maintenance schedules for BMPs; controls in
place for all municipal/facility areas of concern
For Additional Information
Ow U.S. EPA Office of Wastewater Management
•
Phone: 202 260 -5816
• E -mail: SW2 @epa.gov
• Internet: www.epa.gov /owm/sw2.htm
Reference Documents
ow Storm Water Phase H Proposed Rule Fact Sheet
Series.
• Contact the U.S. EPA Water Resource Center at
202 260 -7786 or at waterpubs @epa.gov
• Internet: www.epa.gov /owm/sw2.htm
ow Storm Water Phase II Proposed Rule, published on
Jan. 9, 1998 in the Federal Register (63 FR 1536).
• Internet: www.epa.gov/owm/sw2.htm
Landscape & Park Street & Road Storm Sewer Recycling Fleet Waste Flood Building
Maintenance Operations Maintenance Maintenance Transfer Control Maintenance
EPA's 4 Recommended Components
of a Good Housekeeping P2rogram
• Maintenance activities, maintenance
schedules and long term inspection
procedures
• Controls for reducing or eliminating
the discharge of pollutants
• Procedures for the proper disposal of
waste
• Ways to ensure that new flood
management projects address the
water quality impacts
Interdepartmental Cooperation
11 Program Assessment 11
II BMP Identification II
his.
co Establish Measurable Goals for BMPs
U
U
Z
(� Employee Traininq and Education
II BMP Implementation II
I Evaluation of BMP Performance
LEGEND
F=-] Plan Development
Phase
Plan Implementation
Phase
Plan Evaluation/
Modification Phase
GROUNDS MAINTENANCE
Areas where building or grounds maintenance is conducted can contribute contaminated
runoff when measures have not been taken to prevent discharges. The overuse of
pesticides and fertilizers, over - watering and inadequate erosion control may result in an
illegal discharge.
• Utilize native vegetation to reduce water, fertilizer or pesticide needs.
• Use landscaping pesticides and fertilizers only as needed.
• Avoid over - watering to prevent excess runoff.
• Use integrated pest management (IPM) where appropriate.
• Sweep paved surfaces, rather than hosing down or using blowers.
• Do not dispose of grass clipping and leaves by dumping them into the storm drain.
• Properly contain and dispose of wash water, sweepings and sediments.
• Use non -toxic substitutes for chemicals when possible.
• Regularly inspect and clean storm drains, also stencil inlets with "No Dumping ".
• Clean up spills immediately to minimize safety hazards and deter spreading.
• Control litter by sweeping and picking up trash on a regular basis.
• Educate employees on pollution measures.
SOIL MANAGEMENT PRACTICES
• Have the pH and fertility of your soil tested. Your soils may not require any fertilizer. If
fertilizer is required, follow the recommendations on the container.
Test your soil for degree of compaction. Relatively well compacted soils are unhealthy for
plants and can convey as much runoff as pavement. To test for degree of soil compaction, try
advancing a screwdriver into the ground without pounding. If the screwdriver does not
penetrate easily, the soil is relatively well compacted.
• Aerate well- compacted soil with a hand or mechanical corer. Do not use spike -type rollers:
these actually make compaction worse.
Examine soil texture and drainage. Neither very sandy nor heavy clay soils provide a good
foundation for lawns or other plantings. To examine soil texture, squeeze a handful of soil
into a ball. If the soil remains in a clump, it has too much clay. In general, soil with a good
texture will stay somewhat spongy.
If the soil is too sandy, add compost or other organic matter to hold nutrients and prevent
leaching.
If the soil has too much clay, add organic matter and sandy loam for coarseness. Mixing
sand with clay will produce a soil similar to concrete.
4
POLLUTION PREVENTION FOR MUNICIPAL
OPERATIONS
The following excerpt was taken from the Natural Resource Defense Council's Report on Storm Water
Strategies: Community Responses to Runoff Pollution, Chapter 5.
A wide range of municipal operations can affect storm water quantity and quality. The
Natural Resource Defense Council's (NRDC) case studies reveal that some local
governments have been able to manage their municipal operations to make a significant
positive contribution to reducing storm water pollution. Successful storm water strategies
address areas of municipal activity in a variety of ways.
First, a number of municipal services primarily provided for other purposes can curb storm
water pollution. Street sweeping, collection of leaves and other yard waste, collection and
recycling of used oil or other substances, and general trash control all keep contaminants out
of urban runoff. Improvement or expansion of such programs significantly assist storm water
pollution prevention, and because people want these programs, builds support for the
broader issue of storm water management.
Second, municipalities engage in a number of activities that directly cause storm water
pollution. They operate and maintain vehicle fleets of municipal buses, police cars, and
garbage trucks. These vehicles emit into the atmosphere nitrogen and particulates which will
eventually end up on the ground and then in the storm water. These vehicles also deposit oil,
grease, and metals onto roads and parking lots. Municipalities apply pesticides and
fertilizers to municipal parks, cemeteries, highway rights -of -way, and golf courses.
Municipalities can include storm water control requirements in all contracts for construction
work and other contracts where such provisions are relevant. Most simply (and a very
common action), timely maintenance of vehicles reduces the amount of oil, grease and
metals left on roads and parking lots. More dramatically, municipal fleets can be converted
to low- emission or zero - emission vehicles powered by natural gas, electricity, or other energy
sources to reduce emissions and thus deposition of nitrogen and particulates. A number of
municipalities reduce or even eliminate the use of artificial pesticides and fertilizers by
employing sound landscaping practices such as planting native species and using integrated
pest management (IPM).
Third, municipalities often manage some type of storm sewer or storm drain system; how
they do so can make the difference between simply moving the water to another place and
successfully addressing storm water pollution. For example, if catchbasins are not properly
cleaned, the materials that collect in them - sediment, trash and other storm water
contaminants — can be resuspended in storm water during a storm and eventually flow into a
stream or waterbody. Local governments have found effective designing devices to reduce
velocity using vegetated swales to facilitate infiltration and purify storm water runoff, or using
preserved natural areas to store or convey storm water.
Fourth, training and education efforts that target municipal officials and agency personnel
have also proven to be important. Park and utility workers educated in integrated pest
management, fertilizer use, and composting; fleet workers educated in fluid disposal;
construction workers educated in erosion controls — all these have made noticeable
differences in the storm water impacts of municipal operations. In municipalities constrained
by human resources, programs that provide training or certification for non - government
personnel, such as citizen construction site or storm drain and outfall inspections have
proven effective. Furthermore, NRDC case studies demonstrate that a well- trained and
informed staff improves interactions with the community, raising community awareness,
improving credibility, and setting positive examples for the community.
Finally, although no local government surveyed had a full program in this area, several local
government officials strongly recommend that periodic environmental audits would make any
program far more successful. A broad -based audit would be particularly useful regarding
problems such as storm water that reflects a cumulation of numerous minor problems. With
environmental audits becoming more popular in industry, methods for such audits of local
governments should be fairly readily available.
Some Common Municipal Operations:
• Street sweeping
• Leaf and yard waste collection
• Recycling and household waste collection
• Building maintenance
• Fleet maintenance
• Grounds maintenance
• Parks, public grounds and golf course maintenance
• Snow and ice control
• Waste management and disposal
• Catchbasing cleaning
• BMP selection, monitoring and maintenance
• Training of municipal officials and agency personnel
• Certification of non-government personnel
National Resource Defense Council, Report on Storm Water Strategies: Community
Responses to Runoff Pollution, Chapter 5. http://www.nrdc.ora/nrdci)ro/storm/ChaD5.htmi
2
BEST MANAGEMENT PRACTICES (BMPs) FOR
MUNICIPAL ACTIVITIES
BMPs are defined as general good housekeeping practices, schedules of activities, pollution
prevention techniques, educational practices, maintenance procedures, prohibitions of
practices and other management practices. BMPs also include treatment practices,
operating procedures, and practices to control site runoff, spillage or leaks, sludge or water
disposal, or drainage from raw material storage.
BMPs FOR THE FOLLOWING ACTIVITIES:
Building Maintenance
• Floors and Outside Impervious Surfaces p. 5
• Parking p.6
• Trash Bins p. 6
Fleet Maintenance
• Vehicle and Equipment Operation, Maintenance and Repair p. 7
• Vehicle and Equipment Fueling p. 7
• Vehicle Washing Facilities p. g
Grounds Maintenance
• Soil Management Practices
P. 9
• Pesticide, Herbicide and Fertilizer Application
P. 10
• Integrated Pest Management (IPM)
P. 11
Materials Loading, Unloading, Handling and Storage
P. 19
• Cleaning Rags
p. 12
• Drum and Barrel Containers
p. 13
• Spills and Leaks
p. 13 -14
Storm Drains and Discharge Points
p.20
• Grates and Basins
p. 15
Training and Education
p. 16
Waste Management and Disposal
• Waste Fluids
p. 18
• Antifreeze
p. 18
• Aqueous Cleaner
P. 19
• Brake Fluid
P. 19
• Oil
P. 19
• Paints
p.20
• Recycling
p.20
3
BIBLIOGRAPHY
City of Arlington Parks and Recreation Department, Rivers, Trails and Conservation
Assistance Program, National Park Service and the North Central Texas Council of
Governments, Creek Care Guide For Residents and Businesses, 1999.
San Diego County Storm Water Management Program, Business Best Management
Practices.
http: / /www.co.san- diecio. ca.us /cnty /cntydepts /landuse %nv health /stormwater /business.html
Texas Natural Resource Conservation Commission, Preventing Nonpoint Source Pollution: A
Guide to Pollution Prevention for Small Businesses, GI- 241 /GBEP T -2, June 1998.
University of Missouri Outreach & Extension Office of Waste Management, Pollution
Solutions: Waste Reduction Assistance for Business, Common P2 Methods.
http: / /outreach.missouri.edu /polsol/
4
BUILDING MAINTENANCE
Areas where building maintenance, repair, remodeling and minor construction are conducted
can contribute contaminants to runoff when measures have not been taken to prevent
discharges.
• Use soil erosion control techniques if bare ground is temporarily or permanently exposed.
• Enclose painting operations, consistent with local air quality operations.
• Properly store and dispose of waste materials generated from the activity.
• Properly store materials that are normally used in repair and remodeling such as paints and
solvents.
• Sweep paved surfaces, rather than hosing down or using blowers.
• Properly contain and dispose of wash water, sweepings and sediments.
• Use non -toxic substitutes for chemicals when possible.
• Regularly inspect and clean storm drains, also stencil inlets with "No Dumping"
• Clean up spills immediately to minimize safety hazards and deter spreading.
• Control litter by sweeping and picking up trash on a regular basis.
• Maintain good housekeeping practices while work is underway.
• Train employees. Your success depends on an effective training Droaram.
CLEANING AND MAINTENANCE OF FLOORS AND OUTSIDE IMPERVIOUS SURFACES
Contaminants from your facility can contribute to polluted runoff when floors and outside
impervious areas such as parking lots are not maintained or cleaned properly.
• Keep outside areas (dumpsters, parking lots, etc.) free of trash and debris, and regularly
clean them to prevent pollutant buildup.
• Use absorbent for liquid spills and sweeping and mopping to clean outside areas.
• Regularly inspect and clean out grease traps.
• Avoid spilling onto floors or other surfaces through good housekeeping.
• Control litter by sweeping and picking up trash on a regular basis.
• Never dispose of wash waters to the storm drain.
• Use "dry" cleaning methods (sweeping, vacuuming, etc.) on sidewalks and parking lots and
dispose of waste properly.
• Use damp mop to clean floors, and contain the wash water for proper disposal (sewer, on-
site treatment, etc.).
• Label all storm drain inlets "No Dumping ".
• Clean up spills immediately to minimize safety hazards and deter spilling.
• Train all employees. Your success depends on an effective traininq program.
5
PARKING LOTS
Parking lots can contribute to pollution if not maintained properly.
• Use dry cleaning methods to clean parking lot pavement — absorbents, brooms, or wire
brushes.
• Clean up sediments and other solids from parking lots immediately to prevent them from
blowing or washing away.
• Mechanically remove loose debris before washing the lot with water.
• Dispose of parking lot debris properly. To determine the proper disposal method, contact the
facility that you expect to take the material to for disposal.
• Clean parking lots early in the day if heavy rains are forecast.
• Assign numbered parking spots for each driver or vehicle. This helps to identify leaking
vehicles so they can be repaired.
• Pressure wash pavement only when necessary. Avoid the use of acids and other harsh
cleaners.
• If pressure washing is used, wash with water only. Be aware that dissolved pollutants or
cleaning products can percolate through underlyinq soils to drinking water supplies.
TRASH BINS
• Don't put liquids in trash bins or trash cans.
• Place trash bins or trash on concrete surfaces.
• Keep lids tightly closed to keep the rain out.
• Assign someone to regularly clean up the ground around trash bins.
• If a trash bin or trash can leaks, immediately repair or replace it.
• Make sure that storage containers are in good condition and lined with a material that will not
deteriorate.
• Trash bins or trash cans stored outside should be watertight, rodentproof, and protected from
R
FLEET MAINTENANCE
VEHICLE AND EQUIPMENT OPERATION, MAINTENANCE AND REPAIR
Your facility can contribute contaminants to runoff when vehicles and equipment are
improperly operated, maintained or repaired. Leaky and poorly maintained equipment and
improper maintenance work areas might result in an illegal discharge.
• Inspect all vehicles and heavy equipment frequently for leaks.
• Conduct all vehicle and equipment maintenance at one location away from storm drains,
preferably on a paved surface under cover.
• Move activities indoors, or cover equipment areas with a permanent roof. Conduct
maintenance only in areas designed to prevent storm water pollution.
• Inspect and clean equipment to prevent leaks and excessive buildup of contaminants. Keep
drip pans and containers under areas that might drip.
• Use drip pans or drop cloths to catch drips and spills if you drain and replace motor oil,
radiator coolant, or other fluids on site.
• Never pour materials down storm drains. Connect process equipment areas to the sanitary
sewer or a facility wastewater treatment system.
• Avoid hosing down work areas. Clean small spills with rags, conduct general clean up with
damp mops and clean larger spills with absorbent material.
• Use non -toxic substitutes for chemicals when possible. Recycle greases, oil & filters,
antifreeze, cleaning solutions, batteries and hydraulic & transmission fluids.
• Do not use diesel to lubricate equipment or parts.
• Clean up spills immediately to minimize safety hazards and deter spreading
• Train employees on discharge prohibitions.
VEHICLE AND EQUIPMENT FUELING
Spilled fuel can contribute contaminants to runoff from your facility. Improperly stored rags
used to clean up spilled fuel may also result in an illegal discharge.
• Covering fueling areas.
• Install perimeter drains or slope the surrounding pavement inward with drainage to a sump or
an oil -water separator.
• Pave fueling areas with concrete rather than asphalt, or apply a sealant to protect asphalt
from spilled fuels.
• Install vapor recovery nozzles to control drips.
• Discourage 'topping off' fuel tanks.
• Use a drip pan to collect drips and avoid spills.
• Use absorbent materials or mop up small spills, and for general cleaning rather than hosing
down the area. Remove the absorbent materials promptly.
• Use a rag cleaning service for contaminated rags used to clean up spills, which can not be
disposed of in trash.
• Transport industrial equipment to a designated fueling area rather than using mobile fueling.
• Clean up spills immediately to minimize safety hazards and deter spreading.
• Train employees on proper fueling and cleanup procedures.
VEHICLE AND EQUIPMENT WASHING AND CLEANING.
Your facility can contribute contaminants to runoff if wash water from equipment and vehicle
cleaning is rinsed onto parking lots or into gutters or storm drains. Improperly stored rags
may also result in an illegal discharge.
• If possible use off -site commercial washing and steam cleaning.
• Use designated wash areas, preferably covered, to prevent contact with storm water. Berm
wash areas or use other measures to contain wash water.
• Designate a washing site for vehicles where water will drain by gravity to the sewer system.
Never discharge wash water to the storm drain. Discharge it to the sanitary sewer after
contacting your local sewering agency to find out if pre- treatment is required, or if possible,
filter and recycle it.
• Alternatively, divert wash water to an open lawn or other vegetated areas so that it can
percolate into the ground.
• If it is not possible to divert wash water to the sanitary sewer or a vegetated area, use atgrade
storm drains fitted with filter fabric bags. These bags can be hung down into the drains' catch
basins to filter out solids from the wash water runoff. The solids can be removed when the
bags are full.
• Protect curb gutter inlets with filter fabric to trap solids from the wash water runoff.
• Post signs in the washing area that states that oil changes are prohibited there.
• Wash vehicles with biodegradable, phosphate -free detergent.
• Use non -toxic cleaning products — baking soda paste for battery heads, cable clamps, and
chrome; baking soda mixed with a mild, biodegradable dishwashing soap for wheels and
tires; white vinegar or lemon juice mixed with water for windows.
• Use a bucket (not a running hose) to wash and rinse cars to conserve water.
• Use alternative washing and cleaning methods to reduce the potential for non -storm water
discharges. If possible, use "dry" cleaning methods, such as wiping down, rather than hosing
vehicles or equipment.
• Avoid pressure washing if possible. Conduct pressure washing only if you are equipped to
capture and properly dispose of all wash water. This area should be bermed to collect the
wash water and graded to direct the wash water to a treatment facility. In addition, use high -
pressure, low- volume water to reduce overspray.
• Another way to recycle water is to use wash water from the final wash step for the first wash
step, which doesn't require clean wash water. Likewise, use final rinse water for the first rinse
step, which doesn't require clean rinse water.
• Make sure that the drains at your facility are installed with grit traps and are routed through an
oil separator.
• Properly contain and dispose of clean up materials (rags, towels, absorbent materials, etc.).
• Label all storm drain inlets "No Dumping ".
• Educate employees on proper washing methods to prevent pollution.
0
PESTICIDES, HERBICIDES AND FERTILIZERS
Through use of simple economical gardening and landscaping practices, you can reduce the
pollutants that run off from the facility. Avoid using chemicals entirely during wet weather.
• Pesticides and herbicides, as potential pollutants, should be stored indoors, unless doing so
will increase risks to health and safety. Indoor storage is preferred because it prevents
containers from weathering, keeps precipitation out, and prevents spills directly into the ground.
• Develop a pesticide and herbicide plan for each landscape that your facility is responsible for
maintaining.
• List specific uses for selected pesticides and herbicides.
• Make a chart containing brands, formulations, application methods, and quantities to be used
for each location.
• Implement safety, storage, and disposal methods for pesticides and herbicides used at each
location
• Use application equipment that can be shut off immediately in an emergency.
• Monitor equipment use and maintenance procedures at each location.
• Implement monitoring, record - keeping, and public notice procedures for pesticides and
herbicides used.
• Establish procedures for reviewing pesticide and herbicide plans annually. Be sure to evaluate
the effectiveness of all treatments used, public concerns, effects on sensitive areas, and any
recent toxicological information.
• Schedule treatments that must take place during the most vulnerable stage in the pest's life
cycle, and when they are least disruptive to naturally existing pest controls.
• Follow the label directions exactly. Never use rough estimates when mixing or applying
pesticides, fertilizers or herbicides.
• Never mix'different pesticides, fertilizers or herbicides unless explicitly instructed to do so on
the product label.
• Immediately triple -rinse or power -rinse empty containers in the field at the time of application.
• Triple rinsing is carried out in these steps:
1. Allow the concentrate to drain from the empty pesticide or herbicide container for 30
seconds.
2. Fill 20 percent of the container with water, replace the lid, and shake the container so
that all interior surfaces are rinsed.
3. Drain the rinse water into the spray tank, allowing it to drain for at least 30 seconds
4. Repeat steps 2 and 3 two more times.
5. Use the rinse water (or "rinseate ") according to label directions.
• Keep your equipment free of leaks to prevent pesticides, herbicides, and other fluids from being
unintentionally deposited onto the ground.
• Clean equipment as soon as you have finished using it — do not leave equipment that contains
pesticides or herbicide residue at the mixing, loading or application site. You can reduce
equipment cleaning by clustering jobs that use the same spray solution.
• Be sure to dispose of containers in accordance with the label directions and with federal, state,
and local laws.
• If empty pesticide or herbicide containers cannot be refilled, reconditioned, recycled, or
returned to the manufacturer, then promptly crush, break, or puncture them so that they cannot
be reused.
10
INTEGRATED PEST MANAGEMENT (IPM)
IPM recognizes that pests are an integral part of the natural system, and works to keep them
at tolerable levels by using cultural, mechanical, and biological controls instead of chemicals.
• When pest controls are needed, identify the pest and its stage of development, and use the
least toxic control possible.
• Work to eliminate conditions favorable to pests and to promote natural controls such as
beneficial insects.
• When treatment becomes necessary, select methods that are least disruptive to natural pest
controls and least hazardous to human health and the environment. Start with cultural,
mechanical, or biological controls.
• Space, thin, and prune shrubs and trees to promote air circulation. This is the most important
thing that can be done to manage plant disease.
• Cultural controls are practices that will keep plants healthy, such as selecting disease -and-
pest- resistant varieties and maintaining a good soil foundation. Redesigning the landscape
so that it doesn't provide any support for the pest can be the most cost - effective long -term
cultural control strategy.
• Mechanical controls include:
1. Removing insect eggs, larvae, cocoons, and adults from plants by hand;
2. Removing weeds by pulling or hoeing;
3. Covering the garden with landscape fabric or mulch to prevent weed germination;
4. Removing pest- infested plant residue in the fall.
• Many organisms feed on or infect pests. These natural enemies frequently prevent the pest
population from reaching damaging levels. Biological controls include predators, parasites,
pathogens, pheromones, and juvenile hormones. See table below for more information
about natural insect control.
NATURAL PREDATORS FOR INSECT CONTROL
Green lacewings Praying mantis, aphids, mealy bugs,
thri s, spider mites
Ladybugs Aphids, Colorado potato beetle
Praying mantis Almost any insect
Ground beetles Caterpillars that attack trees and
shrubs
Parasitic nematodes Grubs, beetles, cutworms, army
worms
Trichogramma wasp Corn borer, cabbage looper, other
(extremely small, non-stinging wasps) worms
Seedhead weevils and other beetles Weeds
11
MATERIALS LOADING, UNLOADING,
HANDLING AND STORAGE
Your facility can contribute contaminants to runoff when loading, unloading and storing
materials. Spills, improper storage and sloppy techniques may result in an illegal discharge.
• Park delivery vehicles so that spills or leaks can be contained.
• Protect materials from rainfall, run -on, run -off and wind dispersal. For example, cover loading
docks to reduce the exposure of materials to rain.
• Use seals or door skirts between trailers and buildings to prevent exposure to rain and use
grading or berming to prevent storm water run -on.
• Position roof downspouts to direct storm water away from loading, unloading and storage
areas.
• Use drip pans under areas that may leak (hose connections, filler nozzles, etc.).
• Sweep parking lots or other surfaces to remove debris blown or washed from loading,
unloading and storage areas.
• Store liquids in a designated area on a paved impervious surface within a secondary
containment. Keep outdoor storage containers in good condition.
• Clean storm drains regularly, and stencil inlets with "No Dumping ".
• Use catch basin infiltration inserts.
• Clean up spills immediately to minimize safety hazards and deter spreading.
• Provide training to employees on spill prevention, containment and cleanup.
CLEANING RAGS
• Moisten rags with a squeeze bottle instead of soaking rags in solvent, cleaning fluids, etc.
• Wring out rags with a hand operated or mop wringer.
• Use separate labeled rag containers for each material. Put a wire rack in the bottom of each
container so the liquid can drain out; collect and reuse or recycle the material.
• Instead of cleaning your own rags, use a commercial laundry service.
• Use rags and absorbents to their limit before cleaning or disposing of them.
• Unless you have determined them to be otherwise, manage disposable rags as hazardous
wastes.
12
DRUM AND BARREL CONTAINERS
Container sizes range from 55- gallon drums, barrels of various sizes, or small liquid
containers such as 5- gallon buckets and 1- gallon cans. The methods for managing bulk
liquid containers are similar regardless of their size: you should train your employees how to
prevent spills and how to respond to spills if they occur.
• Keep containers in good condition, handle them carefully, and replace any leaking ones.
• Inspect containers for signs of leaks or corrosion every week.
• Store containers on a base that is chemically resistant to the container contents. The base
must be leakproof, free of cracks or gaps, and have enough volume to contain the container
contents, plus any rainfall that it may have to hold. It must be designed for ease of inspection
so that leaks can be easily seen.
• Make sure that containers are strong enough to contain the materials they are to hold. Line
containers with materials that will not deteriorate under normal conditions of use.
• Use containers for outdoor storage that are watertight, rodentproof, and tamper resistant.
• Keep products in the original containers that they were received in, if possible. If not, clearly
label the replacement containers. Cover all labels with transparent tape to keep the labels
from falling off or from becoming illegible.
• Keep containers closed except when you fill or empty them.
• Watch for indicators that a drum or barrel is under pressure — such as swelling and bulging —
which may result in a leak or rupture.
• Store drums on pallets to prevent concrete "sweating" that can cause corrosion.
• Provide adequate lighting in storage areas.
• Maintain clean, even floor surface in worker and vehicle traffic areas.
• Keep isles clear of obstructions.
• Maintain sufficient distances between drums containing incompatible chemicals to prevent
reactions in the event of container leak.
• Avoid stacking containers against process equipment.
• Insulate and inspect electric circuitry for corrosion and potential sparking.
• Use large containers instead of small containers whenever possible.
• Empty all drums and containers completely before cleaning or disposing of them to minimize
the amount of waste you generate.
SPILLS AND LEAKS
Spills happen! Yes, even though your employees are properly trained to prevent spills,
sometimes a mistake can result in more than just a drip or splatter. You should be prepared
to respond to spills so that they are contained on site.
13
• Equip floor drains with valves that can be closed in the event of a large spill. Regularly
inspect these valves to ensure that they are functioning correctly.
• Specify cleanup instructions for each material that is handled on site, along with safety
requirements and persons designated for spill response and cleanup.
• Make spill containment and cleanup kits easy to find and use. Conduct initial employee
training with periodic refresher training.
• Contain the spill! If the spill might enter a drain, immediately close the control valve. If no
valve is present, plug or cover the drain inlet (for example with a rubber mat). Turn off any
automatic sumps.
• Cover a powder spill with plastic sheeting to keep it from dusting up or becoming airborne. If
the powder will not react with water, you can contain it by covering it with wet paper towels or
by using a light spray of water. You can sweep or wipe up the wetted powder or paper towels
easily. Dispose of the towels as if they were made of the same chemical as the powder.
• If the spill is a liquid, cover it with an absorbent material that can be swept or scooped up.
Sawdust or vermiculite are good for this purpose. Absorbent booms can be used to contain
and soak up larger spills.
• Remove spilled or leaked waste and accumulated precipitation from sumps or collection
areas in as timely a manner as is possible to prevent overflow of the collection system.
• Unless the material has a high flash point, avoid using emulsifiers and dispersants. The idea
is to contain the spill — not scatter it. Similarly, do not use a hose or wet mop. Using water
adds to the volume of the spill and spreads the material to a larger area.
• Report significant spills to the appropriate authorities immediately and get outside help if
needed.
• Do not put rags that were used to soak up even non - hazardous spills in an uncovered
container. Store them in a covered bin and send them to a professional cleaning service.
• Clean up spills on unpaved areas by digging up stained soil areas. Make sure to dispose of
the contaminated soil properly.
• Use wringable pads or booms to recover spilled materials. If this is not possible, use dry
cleanup methods — such as sawdust, cat litter or rags. Avoid hosing down dirty pavement or
permeable surfaces where liquids have spilled.
• Use oil- absorbent pads, rather than granulated absorbents, to collect oil spills and leaks.
Reclaim both the pads and the used oil.
• Install spill basins or dikes in storage areas.
• Install splash guards and drip boards on tanks and faucets.
• Install overflow control devices on process and storage tanks.
• Specify welded pipe joints instead of threaded joints, which can leak.
• Never leave a container unattended if it is being filled or drained.
• Use a funnel of proper size and material when transferring liquids from one container to
another.
• Place spill collection trays under open containers and under the spouts of liquid storage
containers.
• Use this rule of thumb for your container storage area: the spill containment system should
have sufficient capacity to contain 10 percent of the volume of all containers, or 100 percent
of the volume of the largest container, whichever is greater.
• Use absorbents to their maximum capacity. For more information on using oil- absorbent
pads refer to TNRCC document RG -237, Used Oil Absorbents: Proper Management
Practices.
14
0 ot 4
STORM DRAINS AND DISCHARGE POINTS
�� '� rhs�►�,
Dirt, oil, grease and litter are washed down the storm drain with each rainfall creating polluted
runoff. Polluted runoff from your facility can reach water bodies and other wildlife habitats
and harm fish, birds and human life. Identify every storm drain and stencil each one with the
message "Do Not Dump ". This will inform employees and others that dumping wastes down
these drains is not appropriate.
• Prevent spills from entering storm drains and discharge points.
• Eliminate illegal connections to the storm drain.
• Routinely maintain storage areas to keep any drainage from reaching your site's storm water
management system. If you are not sure where a drain goes to, contact your facility
manager, local wastewater utility, or a plumber. If you're still not sure, have the drain dye -
tested.
• Inspect and clean out all storm drains, discharge point & catch basins.
• Control litter by sweeping and picking up litter regularly.
• Clean mats in a floor- mounted mop sink or use a mat cleaning service.
• Collect all wash water and discharge to the sanitary sewer.
• Use "dry" cleaning methods (sweep rather than hose down) to clean shop floors, materials
processing and storage areas, access roads and parking lots.
• Use secondary containment measures for waste storage areas.
• Label all storm drain inlets "No Dumping ".
• Clean up spills immediately to minimize safety hazards and deter spreading.
• Train all employees on BMPs, good housekeeping practices and spill response. Your
success depends on an effective training proqram.
GRATES AND BASINS
• Prevent pollution down stream of basins by regularly inspecting for and removing debris that
can block grates and lead to localized flooding.
• Inspect catch basins at least twice a year to see if they need cleaning.
• To find out how much material has accumulated in the storage area of your catch basin, insert
a long, thin probe into the storm drain grate. Notice where the probe contacts the debris and
continue probing to the bottom to estimate the depth of accumulation.
• Catch basins should be cleaned out before the storage area is half full. After this level is
reached, solids begin washing out of the basin.
• Cleaning should be done in the spring, in the fall, after trees have shed their leaves, and at
other times as needed.
• Solids removed from catch basins may contain high levels of pollutants such as oils, metals,
chemicals, and nutrients. To determine how to properly dispose of these solids, contact the
waste disposal facility to where they will be sent.
15
TRAINING AND EDUCATION
Employee training for continuous improvement is recognized as one of the best methods to
improve performance, employee morale, and reduce waste and pollution generation.
• Educate employees in erosion controls.
• Train employees about safe handling of materials and wastes.
• Train employees on spill prevention and clean up.
• Train employees on leak prevention and detection.
• Train employees on integrated pest management (IPM).
• Train employees on proper use and disposal of pesticides, herbicides and fertilizers.
• Write procedures for using equipment and materials in simple form and post them for
quick reference. Plastic lamination can protect instructions.
• Require employees to return empty containers before getting new supplies.
• Train employees to recognize and understand the meaning of storm drain stenciling signs.
16
WASTE MANAGEMENT AND DISPOSAL
7 lmm,
r�I
Your facility can contribute contaminants to storm water runoff if wastes are not managed and
disposed of properly. Poor waste management may result in an illegal discharge.
For specific information about classifying your waste and about regulations that might apply
to your facility, refer to the TNRCC publication Guidelines for the Classification and Coding of
Industrial Wastes and Hazardous Wastes (RG -22).
TNRCC Publications Inventory and Distribution
P.O. Box 13087
Austin, TX 78711 -3087
(512) 239 -0028
TNRCC RENEW Catalog
(Resource Exchange Network for Eliminating Wastes)
hftr)://www.tnrcc.state.tx.us/admin/topdoc/t)d/002
• Cover and berm waste storage areas.
• Keep outside areas (dumpsters, parking lots, etc.) free of trash and debris.
• Store wastes indoors when possible.
• Keep waste containers covered.
• Regularly inspect and clean grease traps.
• Use non -toxic substitutes for chemicals when possible.
• Recycle food grease, cleaning solutions, oil, antifreeze, batteries, and fluids.
• Sweep parking lots or other surfaces to remove debris blown or washed from storage areas.
• Store liquids in a designated area on a paved impervious surface within a secondary
containment. Keep outdoor storage containers in good condition.
• Regularly inspect and clean storm drains, and stencil inlets with "No Dumping ".
• Clean up spills immediately to minimize safety hazards and deter spreading.
• Regularly control litter by sweeping and picking up trash and litter.
• Educate employees on proper waste disposal..
17
WASTE FLUIDS
You should be aware that there are certain restrictions on what your facility can discharge to
a sanitary sewer. Every sanitary sewer ultimately connects to a wastewater treatment plant
that is regulated by state and federal permits.
These types of liquid wastes may be subject to sanitary sewer discharge regulations:
• Oils and greases from any source. Oils and greases that solidify when cooled can stop
up sewer systems. In large amounts, oils that remain liquid can coat and inactivate
biological components of wastewater treatment systems.
• Water used to wash equipment and vehicles. This wastewater often carries with it large
amounts of sand and grit, which can settle out in the sewer system.
• Wastes that contain toxic substances. These wastes can kill the bacteria that break down
organic wastes as part of the wastewater treatment process.
• Don't mix different types of waste fluids — store used oils, halogenated solvents, and
antifreeze separately to allow for their recycling.
• Never dump unused cleaning products onto pavement or down a storm drain.
• When you consider buying deicers, cleaners, cures, paints, or other chemical products, select
the ones with the least hazardous chemicals necessary to get the job done.
• Keep waste fluid containers protected from weather.
• Label all waste fluid containers.
• Transfer all waste fluids using a funnel of proper size when transferring liquids from one
container to another.
• Recycle all fluids to the maximum extent possible.
• Use properly designated tanks, containers, and vessels.
• Regularly inspect all tanks, containers, and vessels to ensure their physical integrity.
• Develop a written program for all loading, unloading, and transfer operations. Ensure that all
employees are properly trained in the program's specific tasks.
• Install secondary containment areas or structures where waste fluids are managed.
• Document all waste fluid Willaae.
ANTIFREEZE
• Segregate antifreeze and other coolants from all other waste fluids.
• Never pour antifreeze on the ground.
• Do not pour antifreeze down storm drains, floor drains or sewers.
• Do not mix antifreeze with any other waste liquid.
• For information on antifreeze recycling refer to TNRCC document RG -235, Used Antifreeze
(Used Coolant): Proper Management Practices, or call the Used Oil and Used Oil Filter
Recycling Program at (512) 239 -6695.
ilm
AQUEOUS CLEANERS
• If an aqueous cleaner is used, use pre - cleaning methods such as scraping or wire brushing to
reduce the loading on the aqueous cleaner.
• If using caustic -based cleaning solutions consider switching to detergent -based cleaners.
• Pre -rinse dirty engine parts in a first tank of dirty cleaning solution to remove gross amounts
of grime before transferring to a clean tank for final cleaning and rinse.
• Routinely monitor solution composition and make adjustments if necessary.
• Routinely remove sludge and solids from the solution tanks.
• Screen sludge and solids out before they reach the waste sump.
• Use demineralized water for the cleaning bath make -uD.
BRAKE FLUID
• Collect brake fluid in containers clearly marked to indicate that it is dedicated for that purpose.
• If your waste brake fluid is hazardous, manage it appropriately and use only an authorized
waste receiver for its disposal.
• If your waste brake fluid is non - hazardous, determine from your local solid waste collection
provider what should be done for its proper disposal.
• Do not mix brake fluid with spent motor oil.
• Do not pour brake fluid down drains or onto the ground.
• Recycle brake fluid (considered used oil) through a TNRCC- registered recycler.
• For more information on brake fluid recycling, refer to TNRCC document RG -257, Used Oil
Generators, Collection Centers, and Handlers.
OIL
• Never pour oil down the storm drains or on the ground.
• Clean up oil spills immediately.
• Drain oil filters completely — collect the drained oil for recycling.
• Use oil separators to remove oil and grit from runoff before it enters the storm sewer system.
• Regularly maintain oil separators to keep them functioning as intended.
• If your separator has oil- absorbent pads, replace them in the spring, in the fall, and at other
times, as needed. If your separator does not have oil- absorbent pads, consider installing
them. With pads you might be able to reduce the need to clean out the entire oil separator as
frequently.
• Recycle oil filters through a TNRCC — registered recycler. For more information on registered
recyclers, call the Used Oil and Used Oil Filter Recycling Program at (512) 239 -6695. Also
refer to TNRCC document RG -257, Used Oil Filter Generators, Collection Centers, and
Handlers.
19
PAINTS
• Use paints with high solids and low volatile organic compound (VOC) content.
• Use paints that are free of heavy metals (mercury, cadmium, chromium, lead, zinc, etc.) and
cyanide.
• Use water -based paints. Clean equipment and parts with water and detergent.
• Use a nonphenolic, nonacid stripper. Substitute dibasic esters (DBEs) for methylene chloride
strippers.
• Be sure that the proper liners are installed in paint pots.
• Use graduated sizes of sprayer cups specific to the job at hand.
• Use automatic paint mixer to minimize spills.
• Use high- eff iciency painting equipment, such as an HVLP spray gun.
• Use low air pressure and aim the spray gun perpendicular to the work piece to increase
accuracy.
• Use automatic paint gun washer to minimize paint cleaning wastes.
• Use a mechanical paint stripping system, such as plastic blast media, instead of solvents.
RECYCLING & DISPOSAL
Properly dispose of wastes (fluids and materials), and recycle when possible, to eliminate
illegal discharges. Reduce, reuse and recycle (R3) hazardous and non - hazardous wastes
when possible, to lower your disposal costs and the amount of waste going into our landfills.
Participate in waste exchange opportunities to decrease the waste you generate and save
money. Recycle what you must: oil and batteries. Recycle what you can: metal, water -based
paints, used tires, paper and cardboard, glass, aluminum and tin.
20
USEFUL REFERENCES
National Resource Defense Council, Report on Storm Water Strategies: Community
Responses to Runoff Pollution, Chapter 1.
http://www.nrdc.org/nrdcr)ro/storm/chap5.html
Pollution Prevention Information Clearinghouse (PPIC), USEPA, Quarterly List Pollution
Prevention Publications, Summer 1999.
http: / /www.epa.gov /or)ptintr /library/libppic.htm
The Southwest Pollution Prevention Information Center
Juan Maldonado
Phone: 915- 747 -6273
Fax: 915- 747 -5437
Email: jumaldon @ utep.edu
hftr):Hi)2.uter).edu/maribel/baseline2.html
The Texas Nonpoint Source Book: Pollution Prevention Controls Applicability Index Ratings
hftp://www.txnpsbook.or-q/BMPs/
21
CASE STUDIES
P2 Case Studies: APAC- Texas, Inc., Trott! & Thomson Division. TNRCC Office of Pollution
Prevention and Recycling.
By purchasing concrete cure in 250 - gallon reusable totes, (APAC) eliminated the handling,
storage, and most importantly the disposal of the 55- gallon steel drums.
P2 Case Studies: Dallas Area Rapid Transit. TNRCC Office of Pollution Prevention and Recycling.
DART fleet of buses, service vehicles, and other vehicles utilize large amounts of ethylene
glycol (antifreeze). In order to reduce the amount of coolant/'antifreeze purchased and used,
DART needed a solution to reuse this material.
P2 Case Studies: H.E. Butt Grocery Co. TNRCC Office of Pollution Prevention and Recycling.
With the installation of the Valvoline SYSTEM -ONE parts washer with distillation unit, HEB
fleet maintenance was able to totally eliminate the hazardous waste stream of parts washer
solvent.
Preventing Pollution In Our Cities and Counties: Cincinnati, Ohio. National Association of
County and City Health Officials, National Association of Counties, The National Pollution Prevention
Roundtable, Municipal Waste Management Association, and the United States Conference of Mayors.
The city is in the process of adopting a pollution prevention policy statement and
implementation for a plan for "in- house" pollution prevention activities.
Preventing Pollution In Our Cities and Counties: Dade County, Florida. National Association of
County and City Health Officials, National Association of Counties, The National Pollution Prevention
Roundtable, Municipal Waste Management Association, and the United States Conference of Mayors.
Any facilities, private or county, implementing pollution prevention, benefit by becoming better
educated, saving money, decreasing liability and dealing with fewer regulators.
Preventing Pollution In Our Cities and Counties: San Francisco, California. National
Association of County and City Health Officials, National Association of Counties, The National
Pollution Prevention Roundtable, Municipal Waste Management Association, and the United States
Conference of Mayors.
The city's program addresses hazardous wastes generated by city agencies, the private
sector, and households. The goal related to city departments is to turn them into models of
pollution prevention for the private sector.
Pollution Prevention in Vehicle/Equipment Maintenance. The Local Government Environmental
Assistance Network.
Pollution prevention (P2) opportunities abound in vehicle and equipment maintenance.
Purchasing Practices That Encourage Regulatory Compliance and Pollution Prevention. The
Local Government Environmental Assistance Network.
By incorporating environmental and health criteria into purchasing specifications, local
governments can avoid the use of potentially harmful chemicals, reduce the risk of accidents
and toxic releases, and more easily achieve regulatory compliance
22
APAC- Texas, Inc
TNRCC
Executive Office
Office of Pollution Prevention and Recycling
Pollution Prevention & Conservation
.. -
P2 Case Studies
Page 1 of 2
Address/Phone/Fax
PPC@tn cc.state.tx.us
APAC- Texas, Inc., Trotti & Thomson Division
1. GENERAL INFORMATION
Location
Beaumont
Number of Employees
150
Industry
Highway Heavy Construction
Waste Reduced
55- gallon steel drums
Process
Concrete Paving Operations
Contact Person
Roger Tutt, (409) 866 -1444
Information Current as of
January 1998
2. DESCRIPTION OF PROJECT
Help
Search
January 10, 1997
APAC- Texas, In., Trotti & Thomson Division, converted from 55- gallon steel drums to
reusable bulk containers for concrete curing compound. By purchasing concrete cure in
250 - gallon reusable totes, we were able to eliminate the handling, storage, and most
importantly the disposal of the 55- gallon steel drums.
3. INNOVATIVE APPLICATION OF TECHNOLOGY
N/A
4. ENVIRONMENTAL BENEFIT
Since the 55- gallon drums were not reusable and could not be recycled because they contained
a resin -based concrete cure, we were able to eliminate the disposal of approximately 100
drums per year into the local landfills. The disposal of the compound residue in the drums had
to be handled separately and placed in injection wells. Both these processes were eliminated.
5. COST SAVINGS/BENEFITS
The savings in disposal costs from the drums and the curing compound residue resulted in a
savings of approximately $6,000 per year.
http: / /p2. utep .edu /casestudies /Apac97.html 7/15/99
APAC- Texas, Inc
TNRCC disclaimer
Comments regarding Pollution Prevention Planning: PPC @tnrcc.state.tx.us
Technical questions regarding the TNRCC Web Server: webmast @tnrcc.state.tx.us
http://www.tnrcc.state.tx.us/exec/oppr/ppping/chevron295.html
Page 2 of 2
http: / /p2. utep .edu /casestudies /Apac97.html 7/15/99
Dallas Area Rapid Transit
TNRCC
r' w
Executive Office
Office of Pollution Prevention and Recycling
Pollution Prevention & Conservation
P2 Case Studies
Dallas Area Rapid Transit
1. GENERAL INFORMATION
Page 1 of 2
Address/Phone/Fax
PPC @ tnrcc.state.tx.us
Location
East Dallas Equipment Services
Number of Employees
84
Industry
Service, Transportation
Waste Reduced
Antifreeze
Process
Recycling
Contact Person
Joe Coker, (214)828 -6791
Information Current as of
January 1998
2. DESCRIPTION OF PROJECT
Helu
Search
January 10, 1997
Dallas Area Rapid Transits (DART) fleet of buses, service vehicles, and other vehicles utilize
large amounts of ethylene glycol (antifreeze). In order to reduce the amount of
coolant/antifreeze purchased and used, DART needed a solution to reuse this material.
3. INNOVATIVE APPLICATION OF TECHNOLOGY
An in -house antifreeze recycling machine has been introduced to all DART facilities to check
and reuse spent antifreeze. The spent material is deposited into a yellow drum, which is sent to
another part of the facility for testing. After all levels are checked, fresh additives are added to
replenish the antifreeze to a state of safe reuse.
4. ENVIRONMENTAL BENEFIT
DART has significantly reduced a serious waste stream common to this industry, antifreeze.
This reduction is beneficial to the environment as well as this facility.
5. COST SAVINGS/BENEFITS
The reduction of pure usage has allowed DART to excavate all of their underground tanks.
http: / /p2. utep .edu /casestudies/DART297.html 7/15/99
Dallas Area Rapid Transit
Page 2 of 2
These were 4,000 or 6,000 -gallon capacity tanks. The tanks are being either totally eliminated
or replaced with double lined above ground tanks or smaller capacity (1,000 gallon)
underground tanks. In the elimination situations DART is focusing on using so little antifreeze
that they can operate out of a few 55- gallon drums on site.
TNRCC disclaimer
Comments regarding Pollution Prevention Planning: PPC@tnrcc.state.tx.us
Technical questions regarding the TNRCC Web Server: webmast@tnrcc.state.tx.us
http://www.tnrcc.state.tx.us/exec/oppr/Ppping/chevron295.html
http: / /p2. utep .edu /casestudies/DART297.html 7/15/99
H
TNRCC
Executive Office
Office of Pollution Prevention and Recycling
Pollution Prevention & Conservation
P2 Case Studies
H.E. Butt Grocery Co.
1. GENERAL INFORMATION
Page 1 of 2
Address/Phone/Fax
PPC@tnrc state.tx.us
Location
San Antonio
Number of Employees
45,000
Industry
Food & Drug
Waste Reduced
Parts Washer Solvent
Process
Distillation
Contact Person
Tommy Johns, (210) 938 -5628
Information Current as of
May 20, 1998
2. DESCRIPTION OF THE PROJECT
Help
Search
January 10, 1997
With the installation of the Valvoline SYSTEM -ONE parts washer with distillation unit, HEB
fleet maintenance was able to totally eliminate the hazardous waste stream of parts washer
solvent. The system uses a high flash solvent ( >140 degrees Fahrenheit) that does not contain
any carcinogens or any listed material.
The process uses a 30- gallon system that separates contaminated solvent from clean solvent.
With only a four minute downtime, the operator is able to flush the five gallons of used
solvent into the vacuum distillation unit and begin the recycling process, while at the same
time replenish the five gallons of used solvent with clean solvent. The distillation process
takes about six hours; however, you are able to use the parts washer in only four minutes.
After the unit has completed the distillation of the solvent, the operator is able to dump the
still bottoms into the waste oil, which is then recycled.
Pure solvent is always readily available on demand without the need to wait for periodic
deliveries and hazardous waste disposal services.
3. INNOVATIVE APPLICATION OF TECHNOLOGY
The system eliminates waste recovery services and could avoid classification as a waste
generator. It also eliminates potential liabilities for improper handling, storage, and
transportation of waste material.
SYSTEM -ONE is a totally enclosed treatment that separates solvents from oil and other
http: / /p2. utep.edu /casestudies/HEB97.htm] 7/15/99
., .
H Page 2 of 2
impurities. The resultant residue meets the regulatory definition of used oil under 40 CFR
260.10 and may be managed as a used oil and is exempt from hazardous waste disposal
regulation. But remember, the responsibility for proper chemical management rests with the
user. The user must ensure that the solvent is never contaminated with a hazardous material or
waste.
4. ENVIRONMENTAL BENEFITS
This system will allow HEB to eliminate a large hazardous waste stream. The new solvent
does not exhibit any characteristics of hazardous waste therefore eliminating a hazardous
waste stream into the environment.
5. COST SAVINGS/BENEFIT
The system will save $49,000 in service and disposal costs over a period of 60 months. The
elimination of the hazardous waste stream will keep some of our sites Conditionally Exempt
Small Quantity Generator.
TNRCC disclaimer
Comments regarding Pollution Prevention Planning: PPC @tnrcc.state.tx.us
Technical questions regarding the TNRCC Web Server: webmast @tnrcc.state.tx.us
http://www.tnrcc.state.tx.us/exec/oppr/ppping/chevron295.html
http: / /p2. utep.edu /casestudies/HEB97.html 7/15/99
Cincinnati, Ohio
Summary
Cincinnati is aspiring to create a
model urban area pollution preven-
tion program through the creation
of a multifaceted strategy which
focuses on city government opera-
tions, business and industries and
outreach to the general public. This
is being done through pollution
prevention (P2) training, technical
assistance, and promotional efforts.
The city estimates that the poten-
tial savings are well over $2
million for 10 small to medium
sized industries that participated in
its initial P2 outreach program.
Program
Description
Impetus for Pollution
Prevention Activity
The program began in August
1992 as a result of city leaders rec-
ognizing the importance of
pollution prevention and identify-
ing opportunities for partnership
and assistance from U.S. EPA, University of Cincinnati,
American Institute for Pollution Prevention, Institute of
Advanced Manufacturing Sciences, and other local
resources. In addition, a U.S. EPA/City of Cincinnati
agreement provided for solid waste management and P2
assistance through the Intergovernmental Personnel Act
(IPA) which provided salary cost sharing for an expert
who assisted in the start-up of the city's Pollution Preven-
tion Incentives for States (PPIS) project and P2 program.
The initial goal of the program was to create a model
urban area pollution prevention strategy for three sectors:
local governments; business /industry; and the general
Jurisdiction:
Cincinnati. Ohio
Population:
City proper: 364,278
CMSA: 1,744,124
Type:
Urban, suburban
Contact:
J. Zruce Suits, Pollution Prevention
Program Manager, Office of
Environmental Management,
�ity�cf C�nCitiitrati; ,,. - .
Vwa Cpntenmal. Plaza, Suite 610,E
805 ?central Avenue, -
Cincinnati, Ohio 45202 -1947
Phone- 513/352 -6270
Overall Annual Budget of City:
Approx. $718 Million in FY95
Lead Agency Conducting
Pollution Prevention Work:
Office ,of Environmental Management
(Under the Office of the City Manager),
public. The long range goal was to
sustain local government P2 pro-
motion and implementation efforts
in all three sectors for community -
wide pollution prevention.
Strategy
The City of Cincinnati is
committed to promoting and
implementing P2 in its own opera-
tions as well as reaching out to
area business /industry and the gen-
eral public. This urban area
strategy is an attempt to provide a
model program for implementing
pollution prevention as the pre-
ferred method of environmental
protection across an entire commu-
nity. The city is in the process of
adopting a pollution prevention
policy statement and implementa-
tion plan for "in- house" pollution
prevention activities. All city
departments and divisions have
had P2 training and will be respon-
sible for implementing P2
practices on a daily basis. Base-
lines and goals are being
established along with measure-
ments for improvements and cost
savings. The city has also invited
other local and state governmental
agencies to participate in P2 training and promotional
activities. Some of these focus on P2 opportunities for air
and wastewater inspectors. The city has led the commu-
nity in adopting an "Environmental Preference"
purchasing ordinance for all city purchases. One particu-
larly noteworthy example of in -house initiatives has been
the conversion from lead, solvent -based highway line
striping paints to lead -free, waterborne paints. While
retraining employees and converting equipment has been
challenging, management and employee commitment is
beginning to produce P2 results.
Through the Institute of Advanced Manufacturing Sci-
Preventing Pollution in our Cities and Counties: A Compendium of Case Studies
ences (IAMS), the city is providing P2 training and tech-
nical assistance to small and medium -sized businesses. In
each business that is assisted, a pollution prevention team
usually consisting of employees, management, and a pol-
lution prevention expert is created. After the pollution
prevention team conducts an on -site assessment, the com-
pany is made aware of the types of waste, pollution, and
associated costs that have been identified. The team then
conducts a brainstorming session to make suggestions for
using alternative processes or materials that would create
less waste or use less toxic materials.
Resources Used
Staffing Resources
The P2 program manager in the Office of Environ-
mental Management (OEM) under the City Manager's
Office is the city's only full -time staff member dedicated
exclusively to P2. This person is responsible for ccordi-
nating all in -house government P2 activities (including
the PPIS grant). Other individuals in OEM's Solid Waste
Management and Employee Safety and Air Quality Sec-
tions also dedicate various portions of their work time to
the city's P2 efforts. However. OEM's role as P2 coordi-
nator relies on cooperation and assistance from all city
departments and divisions. Each department or division
director is responsible for implementation and documen-
tation of P2 efforts and improvements. Employees trained
in P2 comprise an interdepartmental coordinatin« com-
mittee. The committee serves as a pool from �Nhich P2
assistance teams are formed to perform P2 opportunity
and waste reduction assessments, and help in brainstorm-
ing and implementing improvements. It is important to
point out that the city's P2 efforts are being accomplished
without the creation of an additional layer of bureaucracy.
Instead, the program relies on existing personnel and
resources to implement a P2 "culture change" and waste
reduction effort throughout cite government operations.
Expenditures and Funding
(October 1992 - February 19951
Money is received through the U.S. EPA PPIS Match-
ing Grant which passes through the University of
Cincinnati, the City General Fund, Infrastructure Fund,
and other funds.
Written Materials and Technical Assistance
Sources Used
A variety of materials were used in the development of
the program including the following: EPA's Facility Pol-
lution Prevention Guide: Ohio EPA's Pollution Prevention
and Waste Minimization Planning Guidance Manual and
State of Ohio Pollution Prevention Strategy; material
from other local governments including Anchorage,
Alaska's Green Star Program materials; material from
other non -profit organizations including the Institute of
Advanced Manufacturing Sciences' hnplementing Pollu-
tion Prevention At Your Facility; and materials from the
National Pollution Prevention Roundtable and its member
organizations, The American Institute for Pollution Pre-
vention and many others.
Public or Private Sector Partners
The following organizations have contributed to the
success of Cincinnati's P2 program: University of Cincin-
nati: U.S. EPA; Office of Pollution Prevention, State of
Ohio: Institute of Advanced Manufacturing Sciences;
National Pollution Prevention Roundtable: An::rican
Institute for Pollution Prevention: Air and Waste Manage-
ment Association: Department for Environmental
Services. Hamilton COtlntv'. Ohio: Environmental Ser-
vices. State of Kentucky: Kentucky Partners:
Environmental Advisorti Council, City of Cincinnati;
Hamilton County Environmental Action Commission:
Greater Cincinnati Chamber of Commerce; Ohio Envi-
ronmental Council: The Cincinnati Zoo: P2 Peer Review
Advisory Committee (General Electric Co.. The Procter
R Gamble Co.. etc.): "Make Peace With Nature" syndi-
cated television program (courtesy of WKRC -TV
Cincinnati). Citicable Government Access television:
Liebel Flarsheim Co.. Amko Plastics. Inc.: and others.
Salaries and wages
S 112. )20
Fringes
531.47
i
outcome and
Travel
S4.000
Training
515.404
Accomplishments
Equipment /materials /contracted service
518.000
Workshops
Indirect overhead
51.66'
$24,070
Assessment of Effectiveness
Subcontracted P2 Assistance
5100.000
The city is still in the initial stages of implementation
Total
$307,206
of its urban area strategy. However, in the case of the out -
reach efforts to business and industry. there have been
some measurable successes in pollution preventionAwaste
reduction, either realiz °d or projected. Ten small to
medium -sized industries have been assisted with P2 train-
ing, opportunity assessments. and implementation
activities. Potential eliminations or reductions of pollution
and wastes were measured in millions of gallons and tons
per year. Potential cost savings were well over S2 million
annually, in materials alone. Most of the industries are
now in the process of implementing the identified P2
practices.
The city is still in the beginning stages of performing
its first departmental, or divisional, P2 waste reduction
opportunity assessments. Two "pilot " assessments have
just be completed: the City Printima Services and the
Municipal Garage. These high profile divisions were
selected because it is expected that methods and lessons
learned from their operations can be transferred to others.
both in and out of the city structure. Other city depart-
ments and divisions will soon follow using these two
divisions as models and utilizing the "cadre" of trained
P2 "cause champions" from their own departments and
from the coordinating committee pool in forming interde-
partmental P2 assistance teams. This approach will
facilitate transfer of information and identification of pos-
sible P2 opportunities in similar city operations.
P2 activities related to the third sector of the urban
area strategy —the general public —will probably be the
most difficult to measure in terms of effectiveness. How-
ever, with a goal of making P2 and waste reduction more
popular than recycling, future successes in terms of
reductions in pollution and wastes across the whole com-
munity, from all sources, are expected.
Community and Department Gains
Still in its early stages, the city's work is ongoing. One
example of early gains is that the OEM has eliminated
virtually all waste leaving its own office. Paper, the
largest part of the office's waste stream, is re -used before
it is recycled. All corrugated cardboard is either re -used
or recycled, as are packing materials, toner cartridges,
newspapers, magazines, metal, plastic, and aluminum.
The office is constantly looking for ways to improve and
is convinced improvements are possible. The example
OEM sets will help other city operations in their efforts.
The example set by city government will help the private
sector, the general public, and other institutions with their
Iforts.
Lessons Learned
i the process of establishing goals for P2 reductions
and eliminations for city Loyernment operations, it may
be prudent to ward against measuring all departments or
divisions against each other by an arbitrary starting point.
In other words, if the goal is to reduce pollution and
waste by 25 percent oyer a two -year period, make sure
entities Let credit for what they did prior to the starting
point, so that they aec not penalized for their good work
prior to the baseline measuring point. Cincinnati is pay-
ing close attention to this because employee, division,
and departmental competition and recognition activities
are planned for the near future. As much as possible,
there should be a level playing field.
Another piece of advice would be to not give up. P2 is
a way of life, an ongoing, neverending process of
improvement. The process of implementing a change in
waste management culture like P2 is difficult. The
"we've always- done -it- that -way" argument can be con-
vincing, as is the staternent, "It can't be done."
Fortunately, there are now too many businesses, indus-
tries, governments, and, most importantly, individuals
who can attest that there are better, safer, cleaner, and
more responsible ways of doing things.
Pollution Prevention Materials Available
From Jurisdiction
Available in September 1995: Videotape copies of the
"Make Peace With Nature" television program special
series on P2 (produced by WKRC -TV Cincinnati) —a
series of interviews with representatives from business,
industry, government (federal, state and local), and non-
profit organizations (including the National Pollution
Prevention Roundtable), all agreeing on one thing: P2
pays I
Available in September 1995: Copies of videotape on
Cincinnati's experience with changing over from solvent -
based, leaded highway line striping paints to water borne,
no -lead paints. This video and its companion report may
help others avoid some of the problems and delays
Cincinnati has encountered.
Available in September 1995: Final report (and possi-
ble video) on the PPIS grant project "Urban Area
Pollution Prevention Strategy," which will list and discuss
the City of Cincinnati's project and ongoing model pro-
gram, including successes and failures, boosts and
barriers, problems, and solutions.
Preventing Pollution in our Cities and Counties: A Compendium of Case Studies
JACIA'l,.�, �AI LLI�I.V�=
San Francisco,
California
Summary
The City and County of San
Francisco employs an active and
aggressive pollution prevention
program focused on reducing the
amount of hazardous waste that is
generated as well as decreasing
the amount of pollutants that
enters the city's sekyer system. As
a result of its efforts, the city has
realized decreases in its waste
totals, the amount of heavy metal
mass discharged, and has noticed
changes in consumer awareness
and behavior.
Program
Description
Impetus for Pollution
Prevention Activity
HWMP's pollution prevention
activities started in 1988 in
response to the passage of a state
law in 1986 (AB 2648, Tanner)
which authorized counties to
develop county hazardous waste
management plans for the reduc-
tion and management of
hazardous waste to the year 2000.
During the development of these
plans, counties were continually
urged to focus on waste reduction
to reduce the need for treatment
and disposal facilities. Since San
Francisco was a county that
essentially exported all of its
waste, it felt this pressure from
Jurisdiction:
San Francisco, California
Population:
750,000
Type:
Urban
Contact:
Aiex Dong, Acting Hazardous Waste
Program Manager
Office of the Chief Administrative
-Officer
Hazardous Waste Management
Program ,,(HWMP)
1`145'Uthiket,Street, Suite 401
SanTrancisco,'CA 94103
Phone:, 415!695 --7339
Fax:.,-415/695-7377
Steve Medbery, Chief
Department of Public Works
Bureau of Environmental Regulation &
Maiiagernent' (BERM)
38011' =`3rd' Street, Suite 600
San Francisco, CA 94124
Phone: 4151695 -7310
Fax-,415/695-7377
Overall Annual Budget of
Jurisdiction:
$2.9 billion (1995 -1996)
lead Agency- Conducting
Pollution'Prevention' Work:
The Office of the Chief Administrative
Officer's Hazardous Wasted ,
Management Program {HWMP)
Department of Public Work's Bureau of
Environmental Regulation :&
Management (BERN/1).
neighboring counties as well.
The initial goals of the HWMP
�yere to target specific small busi-
nesses that had a lot of waste
reduction potential in an effort to
minimize illegal disposal and to
help achieve the year 2000 goal
of 10 - 40 percent waste reduc-
tion. In San Francisco. unlike
other parts of the country, small
businesses or small quantity gen-
erators, generate most of the
hazardous waste — approxi-
mately 55 percent. To encourage
small businesses to pursue waste
reduction, the plan also sought to
make city departments models of
waste minimization for the pri-
vate sector. Finally, there was an
initial major goal of educating all
users of the city's Household
Hazardous Waste Collection
Facility on safer alternatives.
The creation of BERM's Water
Pollution Prevention Program
(WPPP) in 1990 was a result of
criteria outlined in the city's
"Best Management Practices
Implementation Plan" (October
1990) which was required by the
city's Oceanside National Pollu-
tant Discharge Elimination
System (NPDES) permit require-
ments. The purpose of the WPPP
was to decrease the identified
toxic pollutants that entered the
combined sewer system which
eventually was discharged into
the San Francisco Bay or the
Pacific Ocean. The WPPP was
charged with qualifying and
quantifying the city's pollutants
of concern, identifying sources of
Preventing Pollution in our Cities and Counties: A Compendium of Case Studies
the pollutants. developing and implementing source
reduction /pollution prevention strategies, and initiating
evaluation methodologie, to determine the effectiNene >,
of the program.
Strategy
HWMP's pollution hrcv ention actin itic� arc proac-
tive, comprehensive, and multi- media. The city';
program addresses hazardous wastes generated by cite
agencies, the private sector. and households.
The goal related to city departments is to turn them
into models of pollution prevention for the private scc-
tor. All pollution prevention opportunities are identified
or encouraged via the following: 1) review of existing
generators and waste disposal patterns: 2) on -site
assessment done in -house or by outside contractors:
and 3) development of a city employee recognition pro-
gram. Both technical assistance and some financial
assistance are offered to the city agencies. Active tech-
nical assistance include on -site assessments, waste
classification (sampling and analysis, if required), and
waste exchange. Also, publications on safer alternatives
and a quantitative methodology — much simpler than
the Life Cycle Assessment process — have been devel-
oped to identify safer products. This methodology has
been peer reviewed and has been recently published in
one of ASTM's Standard Technical Publications.
Finally, financial assistance has been provided to city
agencies to purchase waste minimization equipment,
such as a waste paint thinner recycling still.
On the private sector side, the initial focus was small
businesses, but now attention is turning to the larger
businesses. For city agencies, technical assistance and
some financial assistance, in the form of five percent
matching grants, are available. Using a very proactive
approach, staff and their contractors identify, prioritize
(based on waste reduction potential), and approach
businesses to provide technical assistance in the form
of on -site technical assistance and workshops. Three
novel projects have been conducted in the last several
years. One project looked at the possibility of technol-
ogy transfer between large -to -small quantity generators.
A recently finished project looked at quantifying waste
minimization achieved by selected groups of businesses
and the various factors that motivated them, particularly
the impact the city had in this regard. A third project,
done several years ago, involved the development and
dissemination of a self -help checklist to help property
owners minimize environmental contamination from
leaking underground tanks.
To keep the business community informed about
potentialk u,cful waste ^iinimization technologies and
rC,1ulation. a newsletter is published and disseminated
tw ice a v car. Fach issue of the newsletter features a
hu,ines, that i, doing something in pollution preven-
tion.
Finally. the cite has heen running a pilot collection
program for conditionally exempt small quantity gener-
ators (CFSQG,,). This program also disseminates waste
minimization information to the CESQGs and compiles
information on their pollution prevention activities that
are eventually disseminated to similar businesses.
In the area of household hazardous waste, city resi-
dents have been inundated with public information
cai,tpaigns and publications promoting proper manage-
ment. usin17 safer products. buvinR only what is needed,
and recycling,. For those who want to act rid of their
household hazardous waste, the city has provided a per-
manent household hazardous waste collection facility
which has been another significant educational tool in
pollution prevention. The city is trying to measure
household hazardous waste reduction by surveying
users of the facility on how their buying habits have
chanced.
WPPP's P2 activities target business, industry, and
residential sectors. WPPP develops educational materi-
als for the general public and technical assistance
materials for individuals, specific business, and indus-
try. WPPP also conducts steering committees,
workshops, presentations and other public participatory
projects.
Resources Used
Staffing Resources
The above mentioned lead agencies have staff
devoted to P2 work in the following manner:
First, in the HWMP, there are five staff devoted to
P2 work. The Hazardous Waste Program manager
works on P2 approximately 75 percent of the time,
including the area of household hazardous waste.
Two assistant program managers are fully budgeted
for P2 work to help city departments and the private
sectors. Additionally, there are two graduate student
interns who provide support to the assistant program
managers.
Finally, staff resources are frequently augmented by
outside contractors for specific projects.
WPPP has two full -time staff. Staff are dedicated to
5 ra -C --o,. Califoi
rnia
public education, source identification. ;and source :oij
trol strategies.
Expenditures and Funding Sources
Exclusive of salaries, the folio%v in« h,i\ e been burl
geted/spent for P2 work for fiscal year 199-1 -1995
(fiscal year ends June 30th )
HWMP's Budget
In coordination with other San Francisco
Bay Area counties development of a
Green Business Recognition Program
Green Ribbon Panel Awards to recognize
exemplary environmentally conscientious
businesses
Further development of the Hazardous
Material, Resource Center, which �yill
be open to the public in the future
Informational booklets and brochures
Computer Data Base Service to obtain
information identifying safer products
Small Business Waste Reduction Grants
Public outreach campaigns
�','ritten Materials and Technical Assistance
Sources urces Used
The Cit' :111d Countv of San Francisco uses a variety
Ot document,, including EPA's P2 facilities management
"LlIdes, state materials, material from other non -profit
�,r«anizations. and material from other local govern-
ments which is col1� ,,„d from all Bay Area and
California agencies for each others use.
Public or Private Sector Partners
The Printing Industry of Northern California. San
S6.376 Francisco Dental Society. California Dental Society.
American Dental Association and Hospital and metal
finishing associations have been partners.
S7.�,()O
Outcome and
57.335
Accomplishments
S50,000
52,000
525,000
520.000
Support for waste classification and help city
departments implement waste reduction
$0,000
Total
$138,211
Note: The above does not include a couple of projects
continued over from the previous fiscal year.
WPPP's Budget
Public education
Cooling towers $178,000
Small businesses, e.g.,screen printers, $76,000
jewelers, and automotive services
Total $79,000
$330,000
HWMP is funded by the impound account -- the
Qarbage monies. Very infrequently this is supple -
»>r:nted by small state grants.
WPPP is funded by the sewer service charge.
j Assessment of Effectiveness
The city has done very well in meeting and pursuing
its goals. especially those related to the private sector
and household hazardous waste.
The city has used various techniques, manifest data,
and surveys over the last few years to assess progress in
waste minimization. The manifest data appears to show
that the city has done a better job in waste reduction for
the period 1989 to 1992 than perhaps seven of the eight
other counties in the San Francisco Bay Area, taking
into account changes in the number of generators and
employment data. Some Bay Area counties have had
totals similar or slightly higher for the period, whereas,
the city has shown an approximately 25 percent
decrease in its waste totals. This achievement is
matched by only one other San Francisco Bay Area
county. Since the inception of the P2 program, surveys
have been done as a matter of course to assess the
effectiveness of projects. Finally, a recent study's pre-
liminary results show that almost all the facilities
demonstrating waste reduction practice at least one
method of waste minimization and the most common
techniques are better management practices and house-
keeping. Fifty percent of the facilities received
information from HWMP and 21 percent have
expressed interest in participating in a city- sponsored
waste minimization assessment. The next phase of the
survey is to verify waste minimization claims by con-
ducting on -site waste assessments.
Preventing Pollution in our Cities and Counties: s
A Compendium of Case Studies
i
San Francisco, California'
In the area of household hazal'doll, «acre. ,tu \ e\
show that 75 percent of the u,er, of the city's house-
hold hazardous waste collection f<<cilit\ have heen
buying less toxic or safer products. To verify this. the
city has evaluated the volume of waste hrouLht in by
participant,. These hay e slio%v n ,ignifieant decrease,
for the last several years. For example. each participant
brought in 9.4 gallons in 1955 ( the ear of inception
when there were 50 participants per week) verso, 7.0
gallons in 1993 twhen there ��ere _'25 participants per
week) and 40 percent of the users were new.
Over the past 15 years. the quality of the influent to
the city, water pollution control plant has improved.
Specifically. from 1975 through 1990, the total heapv
metal mass loadinLT into the SF«VPCP
(influent) decreased 91 percent. Alost of thi, reduction
can he attributed to the city's aggressive pretreatment
program. However. it appears that the WPPP has
played a significant role in reducing the silver levels in
the influent from photo finishers and printers when
they were added to the list of rep =Mated ,ilver dischar�__-
ers. A second method that `v'4'PPP uses to measure the
effectiveness of its program is bi- annual phone surreys
of city residents, which began in 1992. The second sur-
vey, in 1994, showed that, in general, residents were
using toxic products.at a lower rate and that they
appear to be taking a greater personal responsibility in
reducing water pollution.
Community and Department Gains
The HWMP has, through its pollution prevention
efforts, helped city departments and businesses save
money and reduce exposures to toxics. In return, it has
received national recognition, such as the 1992 Award
for Best Local Government Reduction Program in the
Nation presented by the HAZMACON Conference.
WPPP's efforts are reducing the levels of toxic pol-
lutants discharged to sewer systems which helps the
city to meet NPDES limits. Efforts also assist busi-
nesses in complying with wastewater discharge
permits. Finally, efforts provide residents and small
businesses with information on proper disposal outlets
and product alternatives.
Lessons Learned
There are two basic approaches to a waste minimiza-
tion program, passive and active. Passive approaches
rely on such tools as newsletters. Active approaches
involve soliciting participation on a one -to -one basis
.md prov Min_ 011 -,11e consultations. Many waste mini -
mization nroLIram, .u-e passive. San Francisco's
program has element, of hoth, but is more active than
passive. The passi% -e approach is less expensive, but
San Frailcl,CO has found the active approach more
�ffecti�e. San Fr'fflcisco believes that a model waste
minimization program must contain elements of both.
The city found that personalized solicitations such as
telephone calls were extremely effective in getting busi-
nesses to attend workshops and allow waste
assessments of their facilities. Doing workshops prior
to the waste assessments is another way -- the most
etfectiNe ��av found to date -- to engender cooperation
rrom husine,,e,.
The city found that field te,tinL, educational and
technical pieces -- rev ic\k by members of the target
audienee -- was eery effective in producing readable
any usable materials.
The grant program for small businesses has been
successful. The city found in implementing the grant
program that the paperwork that businesses needed to
fill out to apply and receive the grant was sometimes
daunting. In fact. one business decided against receiv-
ing the grant because of the paperwork. As a result, the
city streamlined the bureaucracy.
San Francisco has found that in the development and
implementation of a waste minimization program, it is
important to continually solicit the input and comments
of businesses. San Francisco has accomplished this
through focus meetings with key representatives of the
target businesses at the developmental stage and
through follow -up questionnaires and telephone sur-
veys.
The city discovered that a waste minimization pro-
gram is more favorably received when it operates in
conjunction with a program that addresses waste that
would still be generated. It seems businesses are more
receptive to waste minimization programs when they
know there will be a place where they can afford to dis-
pose of the waste they will continue to generate.
Another observation is that success or participation
might have been greater in some of the above programs
if they were done in such a way that the businesses did
not feel that their participation could lead to enforce-
ment in other areas.
The success of the waste minimization program for
city departments, depends a great deal on top manage-
ment's endorsement and the development of collegial
relationships with counterparts in the city agencies.
Otherwise, turf invasion might become a concern. One
key to developing a collegial working relationship is to
Preventing Pollution in our Cities and Counties: . A Compendium of Case Studies
work on projects jointly and to recognize the ronn-ibu-
tions of the participating department through a jointly
authored report and a recognition program. A hi« hin-
drance is the bureaucratic nature of « overnment. sshich
seems so often to have instilled the tear of liabilit% in
government personnel. paralvzing them from attempt-
ing something nest'.
Overall, however. esdecialls in cases where one has
control through the chain of command. it appears that
is easier to try out new products or processes in a gyov-
ernment setting. This is perhaps due to the fact that
government is not profit oriented, making it a more
conducive environment for experimentation.
It appears that government and bic businesses are
more likely to explore new technologies. Small bUSI-
nesses with limited funds. are more risk adserse and. in
some cases, must be induced by grants to rry "off -the-
shelf' technologies. Also, social psychological research
studies done in the early 1980's may have relevance in
encouraging small businesses to implement waste
reduction activities. These studies showed that rational
economic models (REMS) often failed to change the
behavior of small groups or individuals, especially
when benefits are marginal or hard to detect in terms of
energy conservation. In these cases, it seems that REMS
that are presented using social psychological tools
make a significant difference in changing behavior. An
underlying theme is that whatever approach is used
should be user- friendly and showcase peers who are
already successfully using the techniques or technolo-
(2ies. The latter is of paramount importance in terms of
encouraging the use of new techniques or technologies.
Another obvious recommendation is program elements
should be affordable to the targeted businesses.
Pollution Prevention Materials Available
From Jurisdiction
HWMP's Publications and Materials
On the Safe Side Newsletter, biannually.
automotive Radiator Repair Shops Fact Sheet, 1995
LiOting Manufacturing Facilities Fact Sheet, 1995
Printed Circuit Board Manufacturing Facilities Fact
Sheet, 1995
Reprographics Facilities Fact Sheet, 1995
Silversmithing and Electroplating Facilities Fact Sheet,
1995
lallmv Manufacturing Facilities Fact Sheet, 1995
Quick Checklist for Auto Body Repair Shops, 1994
Qrri, , : hecK' /i_si ror.4utorrrotive Repair Sltops. 1994
Quic, Checklist for Paintirr,; Contractors, 1994
Quirk Checklist for Printers. 1994
Snurlr husiness /-la,.ardou.s ltuste Reduction Technology
Transfer' Oppor lunitie s and Public Assistance Needs
in San Francisco - Lessons from the Lithographic
Prirttin� an(l Paintin,,, Industries,
August 1994
Cite Safe Fast Facts #1 - Industrial Solvents. 1994
Cite Safe Fast Facts #2 - Adhesives, 1994
Y'oru- Guide to Less Toy is Shopping, 1994
Waste Reduction Assistwice for Small Quantity
Generators. 1993
Service Station Her: ardoers ttaste Reduction and
.Llcurcr(ement Checklist. 1991
V4'PPP's Publications and Materials
Uale r ltarriors, newsletter
When Something goes Down the Drain..., general
public brochure
Get to the Root of the Problem, homeowners brochure
Help Paint the Town Green, pollution prevention tips
for painting contractors
The Green Wrench Guide, pollution prevention tips for
auto repair & body shops
R,v of a Health• Environment, pollution prevention tips
for hospitals and medical office buildings
Estuarviu'ise, brochure for citizens
Public Education Plan, document
Clean Image, pollution prevention tips for photopro-
cessing and printing operations
Note: Both the HWMP and the WPPP produce a vari-
ety of bill inserts, bus transit signs, point -of- purchase
posters, and door hangers.
Preventing Pollution in our Cities and Counties: . A Compendium of Case Studies
Dade County,
Florida
Summary
Dade County is comprised of a
relatively small urban area, with a
sprawling suburban community
and an outlying rural area in the
.outhcm region of the county.
County Department of
Env ironmental Resources Man -
<«emeilt (DERM) has provided
local assistance for the multitude
of large, medium, and small busi-
nesses and industries in need of
assistance since it became appar-
ent in 1992 that enforcement
alone was not adequate to protect
South Florida's unique environ-
ment effectively.
Program
Description
Impetus for Pollution
Prevention Activity
Although some pollution pre-
vention (P2) activities were initiated beforehand, Dade
County's pollution prevention program officially began
in October 1992 with funding from the Florida Depart-
ment of Environmental Protection (DEP) through
Florida EPA. The duration of the grant is three years
(ending date December, 1995), however DERM will
continue to fund the program after the grant expires.
The US Enviromental Protection Agency's Pollution
Prevention Incentive for t:.;, States (PPIS) Grant was
the primary impetus because it provided initial funding
for the program, as well as an opportunity for the State
(FDEP) and Dade County DERM to work coopera-
tively on implementing pollution prevention at the local
Jurisdiction:
Dade County, Florida
Population:
Over two million
Type:
Urban. Suburban
Contact: .
Nichole `Hefty," 1'rograrri Manager
Dade,Co. Dept., of Environmental
Resource s:lVl anagement (DERM)
3!
33.5, n,d.,A.ve,. Suite 1200
Miami Focitln =�3i30 =1540
Phone '�31i�>372 -6825 '
Fax:: 305/372 -6760
Overall Annual Budget of
County:
$2 billion
Lead A9'ency'Conducting'`P2
Work.
Department of Environmental
Resources-(DERM)
level. One of the most important
state and local factors providing
impetus for environmental regu-
lation and initiative is the fact
that Southeast Florida's only
source of drinking water is the
Biscayne Aquifer, ranging from
three to ten feet below the sur-
face of the ground in Dade
County. Therefore, it is impera-
tive that all measures are taken to
protect this aquifer from contami-
nation.
DERM has traditionally been
an enforcement - oriented agency,
until it became apparent that
enforcement alone was not ade-
quate to effectively protect South
Florida's unique environment.
This progam was established to
provide local assistance to busi-
nesses and industries in need of
assistance. Further -more, the size
and population of Dade County
alone dictate that it be a leader in
pollution prevention and set an
example for the rest of the state.
The initial program goals were
as follows:
• train DERM and other county staff;
• provide on -site technical assistance to county
departments and local industry and help them
implement pollution prevention measures;
• provide /host educational workshops /technology
transfer for local industry, government agencies,
and P2 partners:
• produce and distribute P2 /waste minimization edu-
cational material for local industry & county
departments; and
• develop partnerships and educational modules with
local educational institutions (all levels).
Preventing Pollution in our Cities and Counties: A Compendium of C atP Sn i�fPc
The program focuses on the follcm in-,:
• solid waste mana«ement:
• purchasing:
• POTW:
• consumer education:
• fleet maintenance:
• stormwater run -off:
• technical assistance to businesses:
• air pollution issues.
• facilities /buildings:
• energy conservation,
• small quantity hazardous waste.
• all inclusive, multi -media (primary focus): and
• county departments.
Strategy
This program strives to implement pollution preven-
tion at the local level by: 1 ) providing training to
in -house staff as well as to staff of all other count\,
departments. 2) sponsoring and !-_)sting multiple annual
workshops, 3) producing and distributing educational
material (including a quarterly newsletter with a mate-
rials exchange). 4) providing on -site technical
assistance to county departments and local industry,
and 5) integrating pollution prevention into enforce-
ment consent agreements.
In -house pollution prevention measures include stan-
dard office waste minimization practices such as
double -sided copies, reuse of single -sided paper for
printing of draft copies, and posting or circulation of
memos (instead of copies for each employee).
An example of a noteworthy activity is the Solvent
Alternatives Exposition, held in Miami in November
1993. This exposition brought government and indus-
try experts together with local and regional industry for
a full -day of workshops on waste minimization, pollu-
tion prevention, and solvent alternatives. It included a
full exhibit floor where participants could further
research the alternatives presented in the sessions and
speak to representatives of companies which could pro-
vide these alternatives. In addition to standard
table -top displays, some vendors set up actual operating
equipment. This enabled participants to bring in parts
or other items that required cleaning and actually see
first -hand the viability of a particular cleaning alterna-
tive or type of equipment. There were more than 300
participants in this exposition and program staff still
continues to get positive feedback on the event. The
second annual Solvent Alternatives Exposition was held
on March 7 -8, 1995 in Miami and was also a great suc-
cess. This year's exposition targeted solvent
alternative, and pollution prevention for the printing
:nd paintir)2 industric,. a, ��ell a, cleaning applications
for all t%pe. 0t indu,n�.
Resources Used
Staffing Resources
A half -time program manager is responsible for
administering the PPIS Grant and managing the P2 pro-
gram and staff. (including speaking engagements,
publicity. workshop organization, networking, training
of county staff. technical assistance to local industrv.
and production of newsletter). The program is also
,tatted b\ a full-time engineer and a part -time clerk.
Tkyo administrative services staff devote 20 percent of
their time. One computer services staff member works
half time for the P) program. In addition 13 staff
members from various DERM divisions also support
.he project.
Expenditures and Funding Sources
PPIS Grant - 5300,000 over three years
Montenay Agreement - 575,000 ($65,000 for program
manager and S 10,000 for part -time Clerk)
Joint Grant with DERM Air Section - 538,000
2 Staff from Administrative Services reassigned to
assist P2 Program part -time (listed above).
Written Materials and Technical Assistance
Sources Used
The written materials and technical assistance
sources most commonly used are as follows:
• EPA documents- P2 Guides, i.e. "Facility P2
Guide"
• state materials- P2 Programs
• material from other local governments'
P2 Programs
• material from universities University of Texas.,
Mississippi State
• material from other non -profit organizations -
Inform, EDF
• other sources /contacts (Waste Reduction Resource
Center) WRRC, Solvents Alternatives Guide
(SAGE)
The program keeps a large library of documents and
information for assistance to industry and county
IPreventing Pollution in our Cities and Counties: 0 A Compendium of Case Studies
departments making it difficult to name specific docu-
ments. The EPA, the WRRC, and other P2 Programs
have been the most helpful.
Public or Private Sector Partners
The following organizations have played partnership
roles in the P2 program:
Industry Environmental Association (IEA), Greater
Miami Chamber of Commerce, Automotive Services
Association (ASA), FL Dept. of Env. Protection
(FDEP), Dade Co. Departments, Broward Co. Dept. of
Nat. Resources Protection (DNRP), EPA Region IV,
American Business Women's Association (ABWA),
Miami -Dade Community College (MDCC), S. Fla.
Assoc. of Env. Professionals (SFAEP).
Outcomes and
Accomplishments
Assessment of Effectiveness
Overall, the P2 program has been eery successful in
meeting its goals. In addition to training several count
departments and initiating P2 measures at various Dade
County facilities, it has assisted several local industrial
facilities. During the two- and -a- half -year span of the
program. it has hosted or participated in more than 1
local and regional educational workshops addressing
pollution prevention. The success of the workshops is
measured bs the attendance numbers as vyell as
responses to questionnaires. The newsletter has
received positive feedback with many requests for peo-
ple to be included on the mailing list (currently over
1.000 ).
Program staff would like to provide more assistance
to both local industry and count� departments. How-
ever due to the small number of staff' (3 full time). it
has been more effective to concentrate efforts towards
education (workshops and training) to reach the great-
est number of facilities and individuals. The county
also hopes that more staff will be assigned to the pro-
gram within the next year. which a otild :rllo\v more
resources to be devoted to on -site technical assistance.
Community and Department Gains
Even though the program is only t��o- and- a -hah-
years old, Dade County has benefited in many v,ays.
Through the efforts of the pollution prevention pro-
gram, DERM has gained a much better public image,
particularly in the industrial community. DERM has
historically been an enforcement - oriented agency and
now the industrial community is beginning to see that
DERM can and will extend a helping hand. Although
it is hard to document, it is also anticipated that by edu-
cating and assisting the regulated com- munity, the
number of enforcement actions and new or repeat
clean -ups (remediation) will be reduced. Furthermore,
initiating pollution prevention at county facilities sends
an important message to the community. This sets an
example for local industry to follow and shows the
entire community that the county government is dedi-
cated to protecting the county's valuable resources and
environment. Any facilities, private or county, imple-
menting pollution prevention, benefit by becoming
better educated, saving money, decreasing liability and
dealing with fewer regulators (DERM enforcement).
In addition, their success stories are published in the P2
newsletter, providing good public relations. The com-
munity as a whole benefits from better eL:ucation and
increased environmental responsiblity from industry.
Lessons Learned
Technical assistance is difficult with small staff. The
program has been unable to conduct the number of on-
site technical assistance audits originally anticipated
and it is difficult to properly follow through with those
facilities assisted. It has been determined that the pro -
oram would more effectively benefit the community by
concentrating efforts on education (workshops, train-
ing. newsletter. etc.). The program has also obtained
assistance \N ith on -site technical audits from Florida
DEP's Retired Engineers VA'aste Reduction Assistance
Program (REWRAP).
The bureaucratic system is a general barrier Bur-
densome procedural requirements and delays present
many barriers. For example. it is often difficult to pro-
duce educational workshops in a timely and efficient
manner. It is imperative that program staff plan well in
advance. The program also established a Pollution Pre-
vention Trust Fund from which it will finance
workshops. This mill alloy staff to bypass the cumber-
some and time- consuming county bid process.
DERM'.s repwation. Due to DERM's his -
tor< Lind reputation of strict enforcement. local industry
is skeptical of the 1:12 program's offer of technical assis-
tance. afraid this may be a coy means by which
regulators can infiltrate their facilities and are hesitant
to invite DERM into their facilities. This is being over-
come by having the state's retired engineers help with
Preventing Pollution in our Cities and Counties: A Compendium of Case Studies
on -site audits (local facilities are less afraid of the
state) and by working closely with local trade associa
tions (i.e.. ASA. IEA. etc.). The trade association, are
an extremely important ally because thev introduce the
program and its benefits to their memhers and promo[e
the validity and value of the P2 programs assisruHce
and workshops. The success of the workshops has also
been important in demonstrating to the community that
DERM is really willing to provide assistance and that
this assistance is valuable. Furthermore. those facilities
that have received technical assistance from the pro-
gram are publicizing its good work.
It is difficult to o,ercone inertia. The difficulty of
enticing people to change is well documented and Dade
County's program has encountered that internally.
within the department. as well as externally. Those
who are accustomed to being regulators are hesitant to
give up the ticket book, and "Notice of Violations" and
offer P2 solutions instead (in enforcement settlements).
Similarly, field inspectors who are accustomed to look-
ing for violations and issuing notices are hesitant to
offer "low- tech" P2 tips in the field. A persistent edu-
cation campaign and encouragement, as well as
involvement in the P2 program and decision - making
process (for enforcement settlements) is helping to
overcome this barrier. It has also been difficult to
implement the P2 ethic throughout the department for a
number of reasons. This is being overcome by involv-
ing all sections. 'allowi(, them to initiate their own P2
easures, anti encourag
m ing other sections to do the
say »e (rather than hay in2' �tll P2 tips and encouragement
collie only from the P2 Program). This requires 'a
CO(Terati\e etl,ort which. in itself', is sometimes diffi-
cult to oh[aln Ill suCh an organization.
Pollution Prevention Materials Available
from Jurisdiction
I Pollution Prevention Quarterly (Newsletter)
New Best Management Practices and P2 Tips booklets
lrnlrlementin Pollution Prel,ention at the Local Level
Guidebook (currently being developed, will be com-
pleted by October. 1995 )
Additional Comments
Considering that this program has only been in exis-
tence for tv\o and a half vears. has a staff of three and
operate, on a budget of S 100.000 per year, staff
believes the program has made substantial accomplish -
ments. Dade County's program has developed a
reputation throughout Region IV as one of the leading
pollution prevention programs. The program has set a
prime example of how successful pollution prevention
efforts can be implemented at the local level. The
county hopes that, with the assistance of this guide-
book, other local govermrtents and organizations will
follow its lead.
eventing Pollution in our Cities and Counties: OMW A Cnl- 71C)Pnrliin„ of Cam Studies
P2 -*Pollution Prevention in Vehicle/Equipment Maintenance
http://www.igean.org/htrnl/p2-8.cftn
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Pollution Prevention in
Vehicle/Equipment Maintenance
Introduction
Pollution prevention (P2) opportunities abound in vehicle and equipment
maintenance. Usually three factors contribute to the level of success of a P2 plan.
The first factor involves auditing current procedures, researching P2
opportunities, and committing to make appropriate and beneficial changes. This
step requires researching alternative products and funding equipment purchases.
The second factor is funding. Generally present funding can be re- appropriated
in a phased plan to purchase new equipment, products and/or contract services.
The third factor deals with the regulatory requirements and contract services
available based on the facility's location. Some facilities base their decisions for
a P2 plan on the regulatory requirements found in the Resource Conservation and
Recovery Act (RCRA), Occupational Safety & Health Administration (OSHA)
laws and/or stricter local regulations. P2 technology with this approach will
enhance the safety of workers, improve regulatory compliance, and may lower
operating cost of a facility. There are many options for P2 depending on the
waste stream's characteristics and regulatory requirements. Some of the best
ideas for P2 can come from the mechanics who perform the task everyday, but
changing old habits is the key to P2 success. The single most important thing to
remember is that P2 can play an important role in any plan as long as appropriate
research and planning is performed. The following separated waste streams offer
suggestions for evaluation to determine if these P2 opportunities exist in your
facility.
Typical Wastes Generated
• Cleaning solvents.
• Anti - freeze /coolant.
• Used/soiled shop rags.
• Unrecovered freon from a/c.
• Oil/lubricants.
• Scrap metal.
Parts Cleaning Systems
There are many different types of parts cleaning systems. Some utilize a pump to
circulate cleaning solvent/solutions that clean parts. These machines can be
managed by the facility or contracted to a service that maintains the system and
hauls away any generated waste. The type of system and the solvent/solution
(organic based, aqueous, citrus based, etc.) used in the system will determine
regulatory management requirements and P2 opportunities. Some systems have a
distiller to clean the solvent and a reservoir tank to hold the waste that is
"cooked" out, while others utilize filters to extract impurities. Protecting the
integrity of the cleaning solvent/solution in order to extend its life and reduce
disposal quantities is P2. For example, by managing your own system that
utilizes filters, you can change the filters based on the system's use before they
reach a regulated threshold and not because of a pre -set contracted service. Also,
there are aqueous, semi - aqueous, and citrus -based systems that offer unique
opportunities for P2. With any of these types of systems, it is important not to
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introduce any non - compatible solvents /solutions into them that would cause them
to become regulated hazardous waste.
[► •YTiT • •I • rIAMITromwn
• Utilizes non - chlorinated solvents in the system.
• High flash point solvent of 143 degrees or higher.
• Can meet all regulatory requirements regarding disposal of filters. >143
• Closing the lid when the system is not being used to reduce evaporation.
• OSHA safety requirements for use are minimal.
Some factors for aqueous solution systems:
• The system cleans to the standard required for the part to function
properly.
• There will be minimal regulatory restrictions if disposal of the solution is
required.
• A balance can be maintained for the bioremediation in the system to work
properly.
Key Tips:
Maintain the solution/solvent integrity to extend its life and increase frequency of
filter replacement to reduce disposal costs of solvent/solution. Let the part sit in
the wash basin and drip dry to reduce solvent "drag out" loss. Choosing aqueous
systems may reduce regulatory requirements all together.
Pressurized/Aerosol Cleaners
Never use chlorinated solvents /solutions in any application to clean parts. Avoid
using any aerosol cleaning products that are not RCRA approved. The use of
these types of solvents /solutions can cross contaminate fluids and make them
regulated under RCRA and increase OSHA requirements. Solvent/solutions
purchased in bulk and applied with self - pressurizing applicators will reduce the
use of the product and waste containers. Pre- cleaning with a putty knife and wire
brush and utilizing recyclable shop rags will also reduce disposal cost and excess
use of solvents /solutions. Verify compatibility of the solvent/solution with the
parts washer's solvent/solution. Aqueous solutions may be the best option when
utilized properly. There are pre - cleaning solvents /solutions that can affect the
parts washing tank if, after use, further cleaning of a part is required in that
system. Eliminate overuse and set standards on the amount of cleaning required
for the particular part to function properly.
• • • • • FolanyorTWU71 -
• Use non - chlorinated solvents.
• Choose a solvent/solution compatible with the parts washer.
• Verify solvent/solution content with RCRA/OSHA regulations.
• Does the manufacturer /supplier offer system product support and/or
training?
Key Tips:
Utilizing a scraping device and/or wire brush, recyclable shop towels, and a
non - regulated RCRA solvent/solution will reduce usage and hazardous waste
regulatory requirements. Low VOCs and the reduction of potentially toxic vapors
will be less harmful to the employee.
Anti- freeze/Coolant
Using manufactured specified anti - freeze /coolant is required to maintain
warranties and extend the life of the vehicle /equipment. There are some ways to
recycle anti - freeze /coolant to manufacture specifications and reuse on -site.
Verify the vehicle /equipment warranty will be honored if this re -used
anti - freeze /coolant is utilized. One method to recondition used
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anti - freeze /coolant is to utilize a mobile service to perform on -site recycling at
your facility. Verify that the service is licensed and has a neutral third party
laboratory's test results to prove the system works and they guarantee the
system's product. Another approach is to purchase your own on -site recycling
machine. This allows you to fully manage the systems use and the quality of the
product it produces. Either one of these will reduce new product purchases,
RCRA disposal costs, and insure a readily available product.
Some factors to look for in choosing the best method for the facility:
• Verify warranty coverage of the vehicle /equipment for the system/service
chosen.
• Verify disposal approval for filters generated from recycling system.
• See if bulk containers for used/recycled anti - freeze are available and
proper storage can be achieved.
Key Tip:
Whatever method is chosen, make sure testing and warranties of the system's
product is backed and the manufacturer of the vehicle /equipment allows for the
use of the reconditioned anti - freeze /coolant.
Shop Rags
Do not use disposable shop rags. Contract with a service to provide reusable rags
for the facility as needed. Provide mechanics with a certain amount to perform
the job. Require them to bring back and exchange used rags for new rags. Verify
the service provider has an approved method and facility for recycling the rags.
The only exception to utilizing a service is if the facility's non - regulated waste is
disposed at a Waste -to- Energy plant that can incinerate waste rags. Remember to
never use chlorinated solvents regardless of the recycling/disposal method.
Some factors to look for in selecting a service:
• A regulatory approved method for the facility where the rags will be
recycled.
• Will set a pick -up schedule for the used rags as required by your facility.
• Offers different rag selection based on the use for the facility.
Key Tip:
Use as few rags as possible and always utilize a service to recycle them at an
approved facility.
Air Conditioning
There are several manufacturers that have different machines that will recover
freon from a system for off -site recycling. Other machines recover and recycle
the freon and then place the recycled freon back into the repaired unit. These
types of machines reduce new freon purchases and disposal cost associated with
the management requirements of the waste stream. If repair of this type of
equipment is performed off -site, verify their practice for handling generated
waste.
Some factors to look for in selecting a machine:
• It is regulatory approved and registered.
• Backed by third party test results verifying efficiency.
• Has factory warranty and supplier training.
Lubricating Oils
There are several types of lubricating oils in the various types of
vehicles /equipment in use today. Changing these oils should be performed as
determined by the use and not specific timed dates. If the vehicle /equipment is
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underutilized and /or is only needed for a specific task, changing the oils by a
timed date is a waste of resources. Synthetic oils generally have a longer span of
time for use before a change is required. When choosing the correct lubricant,
verify warranty approval and track the miles/hours of use of the product in the
vehicle /equipment. Check various options of disposal to see if refining of the
waste oils is available over fuel blending for incineration. Keep non - compatible
oils separate from one another to reduce possible cross contamination and
increased disposal cost.
Metal Recycling
Most parts replaced are made of metal. Some metal parts must be exchanged for
the new part when purchased. However, there are many that can be recycled
thereby saving the facility from disposal cost. Lead tire weights, broken engine
brackets, nuts and bolts, and body parts are just a few that have value for
recycling. Set up places to store the recyclable metal, preferably out of the
weather, and contract with a scrap dealer to pick -up what is recycled at the
facility on an as needed basis. Some scrap dealers will supply the container to the
facility for the storage of the metal to be recycled. The scrap dealer may require
separation of the different metal types.
Conclusion
Pollution prevention (P2) will have a positive effect on procedures /processes and
regulated waste generated at the facility when the P2 concept is initiated. When
product use is reduced and/or eliminated, the reduction of manufacturing,
transporting, and handling are all affected. This allows the need for energy and
raw material reductions to occur. Although the facility may not benefit entirely
from this occurrence, the entire scope of pollution prevention for the industry
does. Changing procedures and incorporating new technology to reduce or
eliminate waste is true pollution prevention and must be encouraged from top
management to every employee. The major key to incorporate a successful P2
plan is to utilize current funds and available resources to implement the changes
required in the plan. Inventory control, product research, operational procedures,
and regulatory compliance requirements all must be evaluated before
implementation occurs. Evaluate and document current product uses and
procedures to verify the extent of the P2 plan's success at the facility.
Success Story
The purpose of this case study was to evaluate and eliminate violations and the
potential to violate the Resource Conservation and Recovery Act (RCRA) at Lee
County's Fleet Management Facility, to reduce associated liabilities regarding the
Facility's employees' health and safety, to implement and utilize Best
Management Practices (BMP's), Pollution Prevention (P2) technologies and
Preferable Purchasing Techniques (PPT) where possible and to perform research
and institute Recycling Procedural Requirements (RPR) where profitable.
The Fleet Management Facility maintains over 1600 pieces of equipment from
lawn mowers to heavy equipment utilized by various departments in Lee County.
Several violations of RCRA were discovered in 1992 and Lee County was
required by the Board of County Commissioners to fix the situation so violations
did not occur again. A corrective plan was the first task, and later another
operations plan was written to include Pollution Prevention (P2), Best
Management Practices (BMP's), and Reduce, Reuse, and Recycle (R3). The later
plan initiated a three -year phased process that covered"product substitution
and/or elimination, equipment/chemical purchasing requirements, and employee
training.
Eauioment Specifications/Models Purchased to Promote P2. BMP's and R3:
Parts Washer: Zep Dyna Clean Parts Washing System - A three staged filter
system which utilizes Zep Dyna 143 °6 Cleaner Degreaser. Utilizing this system
allowed for the total elimination of hazardous waste that was being generated
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and then shipped off -site for disposal.
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Anti -freeze Recycler: FPPF Gly Clean Anti -freeze Recycling System Model ARS
100. Used to filter impurities from used anti - freeze before chemically balanced
to manufacturer specifications. This closed loop approach is the only way to
insure compliance is achieved and product integrity. As long as filters are
changed appropriately, they do not accumulate regulated heavy metal amounts.
Also, performing on -site recycling of the anti -freeze saved money required for
new product purchase, testing to determine if it was a hazardous waste and
transportation/disposal cost.
Air Conditioning Reclaimed/Recycler: Refrigerant Technology Inc. Model #
RRC -751 and RRC770- R134A. Copeland Inc. Model # PC -1. This machine cut
the cost of freon purchases by 82 %, with zero waste to dispose.
Self - Pressurizing Solvent Sprayer: Zep Model B Pressure Sprayer. Utilize Zep
Brake Wash Product Number 0505. In conjunction with recyclable rag service,
no regulated hazardous waste. Also, changing to manual pressurizing dispensers
eliminated use of chlorinated solvents.
Cost Savings Estimate:
The cost for hazardous waste disposal was reduced 100% for savings of $16,800
per year for an average year's cost. This includes solvent disposal contracts,
anti -freeze disposal, and freon disposal. Recycling of fluids such as anti - freeze,
used oil, parts cleaning solvent, and freon also reduced the facility's liability and
saved in new product purchases. For more information contact Dale Nottingham
(see below).
Additional References:
Local, State, and National Vehicle Trade Associations
National Pollution Prevention Roundtable
State Pollution Prevention Roundtables
National Association of Counties
EPA Website
For more information. contact:
Dale L. Nottingham - Lee County Small Quantity Generator Program, 1500
Monroe Street, Fort Myers, FL 33901, Phone: (941) 479 -8126, e-mail:
nottindl@bocc.co.lee.fl.us.
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.+.'�
I ack to P2 Table of Contents I
Purchasing Practices That Encourage
Regulatory Compliance and Pollution
Prevention
Introduction
Local governments use numerous products to perform public services. Product
manufacturing (including raw material extraction), transportation, use, and disposal
can generate byproducts that stress local and global environmental resources and pose
health threats to product users and the public. By incorporating environmental and
health criteria into purchasing specifications, local governments can avoid the use of
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potentially harmful chemicals, reduce the risk of accidents and toxic releases, and
more easily achieve regulatory compliance. Localities are also discovering they can
Go! I'
save money by reducing the amount of hazardous materials they handle and by
purchasing energy efficient equipment.
Presidential Executive Order 13101 (which strengthens Executive Order 12873)
"Greening the Government Through Waste Prevention, Recycling, and Federal
Acquisition," has directed federal agencies to increase their demand for recycled
content products and other environmentally preferable products and services. Many
local and state governments have voluntarily adopted policies that support the
Executive Order and have increased their procurement of recycled products and
products that are less hazardous, non - toxic, energy efficient, and that generate less
waste.
Typical Products Purchased by Local Governments and Environmentally -
Preferable Product Alternatives
The composition of wastes and the types of emissions generated by local government
is directly affected by the products they purchase. Choosing
environmentally - preferable alternatives to products that are considered hazardous, or
that contribute to wastes covered under environmental regulations, is a preventative
strategy available to any agency involved in product requisition. Please refer to the
accompanying local government operations in this manual for specific wastes
generated and pollution prevention opportunities.
(This is a sample of products purchased by local governments and includes
environmentally preferred alternatives to consider. This does not constitute an
endorsement of any particular products. All products should be researched and
tested.)
(Department/Operation Products Environmentally - Preferred
Purchased ]Alternatives
Construction Site Fill/Base Containing
Fill/Base Material Recycled Materials
(stone, dirt, etc.) (recycled concrete, glass,
li or asphalt)
uilding Materials Recycled Content
Building Materials
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Electrical
Equipment
Energy- Efficient
Equipment and Building
Adhesives
Design (low- mercury
fluorescent lights; energy
Petroleum -Based
efficient HVAC; etc.)
Solvents and
Cleaners
Vegetable -Based
Adhesives
Petroleum -Based
Paints
Vegetable /Citrus -Based
Solvents
Water -Based Paints
Vector/Pest
Chemical
Integrated Pest
Management
Pesticides and
Management (mechanical,
Herbicides
physical, and biological
pest control techniques;
least- hazardous chemical
;options)
Public Safety
Fire Response and:,
Ozone -Safe Fire
Suppression
Extinguishers
Mercury Batteries !
Mercury-Free and
Rechargeable Batteries
Mercury
Thermometers
Mercury-Free
Thermometers
Lead Bullets
I
Ceramic Bullets (for firing,
j
range use only)
Solid Waste
Vehicle Fuel
Alternative Fuels (natural
Management
(gasoline, diesel
gas, propane, solar
fuel)
generated electricity, etc.)
Recycling Bins
Recycled Content
and Residential
Recycling Bins and Trash
Trash Cans
Cans
Wastewater
Chlorine,
Ultraviolet Osmosis
Collection and
Hypochlorite
Treatment
Vegetable -Based
Petroleum -Based
Lubricants
Lubricants
Vegetable /Citrus -Based
Petroleum -Based '
Solvents; Aqueous -Based
Solvents
Parts Washers
Vehicle/Equipment
Petroleum -Based
Aqueous -Based Cleaners;
Maintenance
and Chlorinated
Microbial Agents;
Solvents (parts
Vegetable /Citrus -Based
washers, brake
Solvents; Aerosol -free
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ve Recycled Automotive
Fluids (re- refined motor
oil and recycled propylene
glycol antifreeze)
Tires; Tires with
Printing Petroleum -Based fi SoyNegetable -Based
Inks Inks; Water - Washable Ink
Systems
Perchloroethylene;!
Petroleum Vegetable Ester Solvents;
Distillates Terpene -Based Solvents
(blanket washes)
Administration JElectronic Office Energy- Efficient Office
Office Furniture (Refurbish Used Furniture
aper Supplies; Post - Consumer Recycled
aper Use Content, Chlorine -Free
Paper; Double -Sided
oner Cartridges Copying; Reuse of Scrap
lRemanufactured Toner
Cartridges
Top Pollution Prevention Opportunities
1. Pass a purchasing policy that promotes the integration of environmental and
health criteria in all product specifications.
2. Form an interdepartmental committee to investigate environmental purchasing
opportunities.
3. Educate entire staff about health effects associated with chemicals commonly
found in the products they use or are exposed to, and provide information on
alternatives. Prompt users to choose environmentally preferable products.
4. Involve product end -users throughout the decision making process, request
that vendors perform product demonstrations for staff, and compare products.
5. Choose one department/operation at a time to incorporate environmentally
preferable products. Review final product specifications with product user or
operation supervisor to ensure that their needs are satisfied.
6. Review all purchases and product Material Safety Data Sheets for potential
environmental and, health impacts associated with products being purchased.
7. Avoid purchasing products that are potentially harmful to the user, public, or
environment, e.g. contain known or suspected carcinogens and other toxic
ingredients.
8. Prevent the generation of hazardous wastes in operations by eliminating
products that contain hazardous ingredients.
9. Participate in cooperative purchasing ventures with other jurisdictions, your
state, and vendors to increase availability of environmentally preferable
products and reduce internal costs associated with the formal bid process.
10. When researching environmental purchasing, utilize resources and expertise
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available from vendors, manufacturers, government agencies, non - profit and
other organizations.
11. Consider environmental and health impacts associated with a product's life
cycle prior to drafting bid specifications ( "product life cycle" includes raw
material extraction or development, product manufacturing, transportation to
market, product use, and disposal).
12. Implement waste reduction activities (e.g., implement lease agreements that
require vendors to take responsibility for products as they become obsolete;
require prospective bidders to avoid excess paper and packaging in their bid
and proposal submittals such as avoiding plastic covers and dividers, using
both sides of paper, and use post- consumer recycled content paper; specify
copiers and printers with double -sided printing capabilities; etc.)
13. Begin an energy conservation program and invest in energy - efficient
equipment and building design (specify EPA "Energy Star" certified
equipment and require equipment installers to activate efficiency features
upon product installation).
Success Story
The City of Santa Monica, California, transformed its purchasing practices to
promote environmentally - friendly products without compromising performance
standards or budgetary requirements. As a result, Santa Monica has reduced its
annual use of chemicals considered to be hazardous or toxic by 3,200 pounds and has
proven the City's commitment to provide a safe and healthy environment for its
employees and the public. Other accomplishments include:
• Replaced cleaning products with less toxic or nontoxic alternatives in 15 or 17
product categories, reducing spending on custodial products by approximately
5 percent;
• Reduced pesticide use by developing an effective integrated pest management
system covering all City facilities, saving 30 percent in pest management
costs;
• Purchased re- refined motor oil for all vehicles maintained by Fleet
Maintenance Division which costs up to 25 percent less than virgin motor oil
and, uses less- toxic, water -based brake cleaners and parts washers;
• Powered 20 percent of its 585 vehicle fleet with less - polluting alternative
fuels including compressed natural gas, electricity, and propane; and
• Purchased a wide range of recycled products including office paper, recycled
paint, trash can liners, and retread tires.
For more information about Santa Monica's environmental purchasing efforts,
including specifications for Integrated Pest Management and custodial products,
contact Deborah Raphael of the Environmental Programs Division at (310) 458 -2255.
To receive a copy of the Santa Monica Environmental Purchasing Case Study,
contact the U.S. EPA Pollution Prevention Clearinghouse at (202) 260 -1023 or
E -mail: P in c @epamail.epa.gov.
Additional Resources
National Association of Counties (NACo) Environmental Purchasing Project, 440
First Street, NW, Washington, DC 20001; phone: (202) 393 -6226,
(www naco org/programs /environ/purchase cfm).
Environmentally Preferable Purchasing Listserve ( EPPNET). Established and
maintained by the Northeast Recycling Council (802) 254 -3636. To subscribe to
EPPNET, send an e-mail message to (lyris @aladdin.webrover.com) with
SUBSCRIBE EPPNET <FIRST NAME> <LAST NAME> on the subject line or in
the body of the message.
U.S. EPA Environmentally Preferable Purchasing Program, U.S. EPA (7409), 401 M
Street, SW, Washington, DC 20460 ( htip: / /www.epa.gov /opntintEL=).
U.S. EPA and DOE Energy Star Program, U.S. EPA (6202J), 401 M Street, SW,
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Washington, DC 20460 (888) 782 -7937,
(httl2://www.el2a.gov/al2,12dstar/buildin2s,htmi).
Office Green Buying Guide and Choose Green Reports: Green Seal, 1400 16th
Street, NW, Suite 300, Washington, DC 20036 -2215; phone: (202) 588 -8400,
(www.greenseal org).
Scientific Certification Systems, 1939 Harrison Street, Suite 400, Oakland, CA,
94612; phone: (510) 832 -1415, (www.scsl corn/).
Toxic Turnaround - A Guide to Reducing Pollution for Local Governments,
Environmental Health Coalition, 1717 Kettner Blvd., Suite 100, San Diego, CA;
phone: (619) 235 -0281, (www.environmentalhealth or ).
Sustainable Building Technical Manual - Green Building Design, Construction, and
Operations, Public Technology, Inc. (PTI), the U.S. Green Building Council
( USGBC), U.S. DOE, and U.S. EPA; printed copies available for purchase from PTI
at (301) 490 -2188, and from USGBC at USGBC -SF, 90 New Montgomery Street,
Suite 1001, San Francisco, CA 94105.
Environmental Purchasing Model Resolutions from Local Governments, National
Association of Counties, 440 First Street, NW, Washington, DC, 20001; phone: (202)
393 -6226, ( www. naco. org[�rograms /envirorn/gurchase cfm).
"Pollution Prevention Questionnaire for Municipal Departments" and "Procurement
Recommendations Applicable to Multiple City Departments and Agencies,"
Environmental Defense Fund, 1875 Connecticut Ave., NW, Suite 1016, Washington,
DC 20009; phone (202) 387 -3500; contact Lois Epstein (Lois Epstein @edf org).
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