Introduction
MassHighway has developed an Environmental Management System (EMS) to
assist the Department in conducting facility activities in a manner
that is consistent with environmental requirements and protective of
the environment. This Facility Environmental Handbook is a key component
of the EMS and serves as a reference tool for facility personnel in
maintaining environmental compliance at MassHighway’s facilities.
It provides basic information on how to conduct facility activities
in an environmentally sensitive manner and in keeping with applicable
environmental laws, regulations,
and policies.
MassHighway’s
Commitment To Compliance
MassHighway is committed to maintaining environmental compliance in
all phases of its operations and in all places where it conducts business.
The Facility Environmental Handbook provides for the integration of
environmental stewardship into our everyday activities by furnishing
the necessary guidance to ensure operations are carried out in an environmentally
responsible manner with assigned roles and responsibilities.
Why Must Masshighway Maintain Compliance?
Many routine activities that are conducted at MassHighway Facilities and discussed in this handbook such as vehicle maintenance, vehicle washing, storage of sand and salt are subject to environmental regulations. It is the responsibility of all MassHighway facility personnel to conduct operations in accordance with these laws and regulations.
How Can I Maintain Environmental Compliance At My Facility?
Maintaining environmental compliance can be achieved through these four simple tasks:
|
Keep it neat |
This is the easiest and most important element of environmental compliance. Keep your work areas swept up, put tools and equipment back in their place, and put materials and wastes in their designated areas. Ensure that a proper amount of time and personnel are allocated to continue good housekeeping at the facility. |
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Inspect it |
For example, hazardous waste storage areas must be inspected once per week. Your District HazMat Coordinator (DHC) or District designee will also do a thorough inspection of your facility on a regular basis. In addition, you should periodically inspect your facility for environmental compliance issues. |
| Label it |
Hazardous waste, hazardous material, and solid waste containers must be labeled with their contents. Certain materials may require special labels, if they are hazardous. If you see one of these containers without a label, it is your responsibility to label it. Examples of labels are found on page 1-4 of this handbook. |
| Report it |
When in doubt, call your CSIII, DHC, or District Maintenance Engineer. They are your resource and can provide the information you need to maintain environmental compliance at your facility. Your DHC can provide labels, give instructions on what to do in case of a spill, or arrange for a contractor to remove wastes. The DHC is your guide in maintaining environmental compliance. |
General Environmental
Roles & Responsibilities
In order to maintain environmental compliance at MassHighway facilities,
each facility employee and certain district District and Boston Headquarter’s
employees must play an active role. This includes being aware of the
environmental conditions at each facility, understanding which facility
activities may result in an environmental impact, understanding and
following Standard Operating Procedures (SOPs), and establishing an
open line of communication. A description of the environmental roles
and responsibilities of key MassHighway personnel is presented in this
section.
Facility Personnel
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• |
Maintain facilities in a neat and orderly fashion as described in this handbook. |
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• |
Adhere to standard operating procedures. |
| • |
Notify the facility foreman in the event of a spill or other environmental condition. |
Facility Foreman
|
• |
Notify the appropriate contact person within the District or Boston in the event of a spill or other environmental condition. |
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• |
Maintain certain environmental records. |
| • |
Monitor certain environmental conditions. |
| • | Allocate resources to ensure good housekeeping practices. |
District Hazardous Materials Coordinator
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• |
Serve as the liaison between facility personnel, the District Maintenance Engineer, and the Environmental Section in Boston Headquarters. |
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• |
Ensure the completion of regular environmental inspections at each facility. |
| • |
Arrange for certain waste disposals. |
| • | Notify the appropriate person that other housekeeping or corrective actions are necessary. |
| • | Maintain hazardous waste documentation. |
Maintenance Engineer and Operations Engineer (District and Boston)
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• |
Maintain facility structures and equipment to ensure environmental compliance. |
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• |
Obtain and ensure compliance with applicable permits, environmental regulations and MassHighway Standard Operating Procedures for structures and activities at facilities. |
| • |
Ensure that time is allocated to facility personnel to carry out activities associated with environmental compliance. |
| • | Ensure that corrective actions identified during regular facility inspections and audits are addressed within the required time frame. |
District Environmental Engineer
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• |
Coordinate wetland resource area related submittals either directly with the regulatory authorities or with the Environmental Section. |
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• |
Determine the applicability of wetland resource-related regulations, such as the Massachusetts Environmental Policy Act, and the Wetlands Protection Act for district projects. |
| • |
Determine when activities at a facility may have the potential to impact wetlands. |
Safety Inspectors
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• |
Provide Right-to-Know training. |
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• |
Supply Material Safety Data Sheets (MSDSs) and safety equipment. |
| • |
Conduct regular facility safety inspections. |
| • | Coordinate and respond to spills that may be discovered along roadways or at facilities. |
District Asbestos Coordinators
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• |
Arranges Annual Asbestos Surveys and Renovation/Demolition Surveys. |
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• |
Coordinates asbestos removal actions. |
| • |
Maintains records of filings, surveys, and abatement reports. |
Stock Room Manager
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Supply MSDSs with bulk deliveries of hazardous materials to facilities. |
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Return empty drums to the supplier within a month of receipt. |
Emergency Response Coordinator
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The Emergency Response Coordinator is the Environmental Division’s designee responsible for overall coordination of spill response at MassHighway facilities. |
These roles and responsibilities and additional environmental compliance tools are provided in the following documents.
Standard Operating Procedures
Appendix A
SOPs relating to facility activities are provided in Appendix A of this handbook. Although most of the information contained in these SOPs is presented in the first part of the handbook, the SOPs are the primary guidance documents for the Department.
It is important that MassHighway personnel read and understand these SOPs, and in particular understand their responsibilities as outlined in the SOPs.
Emergency Response Spill Plan (Facility Spill Plan)
Appendix B
The Emergency Response Spill Plan outlines specific procedures for handling all types of spills of oil or hazardous materials (OHM) that may occur at facilities.
MassHighway Environmental Management System Manual (EMS Manual)
The EMS Manual documents the components of MassHighway’s EMS. Copies of the manual may be obtained on MassHighway’s Intranet and at the District and Boston Offices.
Hazardous Waste
This section provides information on hazardous wasteand guidance for
the proper management of hazardous waste including identification, accumulation,
labeling, inspections, transport, and shipping hazardous wastes for
proper offsite disposal. This section also provides information on spill
prevention and response.
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• |
Any hazardous substance that has been discarded, spilled, or is no longer usable and/or out of specification. |
Examples include:
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• |
waste oil |
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• |
waste transmission fluid |
| • |
saturated absorbent |
| • | waste kerosene/diesel fuel |
| • | waste aerosol containers not empty or out of date |
| • | waste gasoline |
| • | waste paint (other than roadway) |
| • | waste solvent |
| • | broken fluorescent bulbs (used to clean asphalt-covered tools) |
What Do You Do With A Container
Of Hazardous Waste?
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Make sure the container/drum is in good condition (not rusted or damaged). |
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• |
Label it with a hazardous waste label. Place the label where it can be seen and clearly mark the contents (see page 1–4 for label examples). |
| • | Keep the container closed. |
| • | Store containers inside on spill containment pallets. If pallets are not available, store containers on a surface that is free of cracks and away from floor drains. Any containers stored outside must be protected from the weather. |
| • | Place the containers in the designated hazardous waste storage area. |
NOTE: Cracked automotive batteries must be disposed of as hazardous waste. Intact used batteries from MassHighway vehicles should be returned to the stockroom. All other batteries must be properly stored for recycling.
Where Do You
Store Hazardous Waste?
Hazardous waste must be stored in a designated Hazardous
Waste Accumulation Area. The storage area in each facility must:
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• |
Be located indoors on a surface free of cracks, away from floor drains |
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Have clearly marked boundaries |
| • | Be marked with a HAZARDOUS WASTE sign (all capital letters, at least one inch high) |
| • | Be neat |
| • | Have adequate aisle space between drums to allow for inspections of containers |
NOTE:
Only hazardous waste can be stored in the hazardous waste accumulation
area. Do not store equipment (other than spill response supplies) or
usable materials in the accumulation area.
If your facility is not equipped
with a hazardous waste accumulation area, any hazardous waste must be
self-transported the same day to a designated facility.
Hazardous Waste Accumulation Area —
The boundaries are clearly marked and the drums are labeled and closed.
If your facility does not have enough pallets, store full drums on an
impervious surface and active drums on the pallet (as shown above).
What Is A Satellite
Accumulation Area?
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• |
A place to temporarily store hazardous waste at the point of generation. |
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• |
Accumulation of up to 55 gallons is allowed. |
| • | Only one container can be used for each type of waste. |
| • | The garage foreman is responsible for managing the activity producing the waste (ex. changing oil) and, must manage the satellite accumulation area. |
| • | The container must be labeled with the words “Hazardous Waste,” the contents, and hazard. |
| • | Waste must be moved to the main accumulation area within 3 days after the container is full. |
| • | Satellite accumulation areas must be inspected weekly. |
Satellite
Accumulation — Only a few facilities operate satellite accumulation
areas. Turn to the Facility Profile in the front of this Handbook to
see if this section applies to your facility. Contact your DHC if you
are interested in setting one up.
How Do You Fill
Out A Hazardous Waste Label?
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• |
Fill in the name of the waste (waste oil, waste paint, etc.). | ||||||||
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Fill in the hazard type.
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| • | Fill in the date when accumulation began only if your facility is a Small Quantity Generator (SQG) of hazardous waste. (Refer to the facility profile in the front of this handbook for the status of your facility). |
NOTE: Any container used for temporary storage or transporting of hazardous waste must be properly labeled.
Hazardous Waste Labels — Either the red or yellow label can be used for hazardous waste. The name of the waste and the hazard must be filled in on the label. For an SQG, also fill in the date accumulation began.
Temporary labels such as tape can be used if these labels are not readily available.
What Are The
Differences Between A Very Small Quantity Generator (VSQG) And A Small
Quantity Generator (SQG) Of Hazardous Waste?
MassHighway facilities have been registered as either a VSQG or an SQG.
If you do not know if your facility is a VSQG or an SQG, ask the DHC
or refer to the facility profile in the front of this Handbook.
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VSQG
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SQG
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Dual status (e.g., VSQG of
hazardous waste and SQG of waste oil)
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NOTE: If your facility is close to the its accumulation limit, call the DHC.
Accumulation limit for a vsqg
— three 55-gallon drums
Accumulation limit for an sqg — ten 55-gallon drums
What Types Of
Inspections Are Required? 
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Weekly Hazardous
Waste Inspections
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Regular Facility Inspections
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How Do You Get Waste Oil
Removed From Your Facility?
The DHC monitors waste oil generation each month, but keep in touch
with your DHC if you have accumulated more than usual.
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If your facility is a VSQG:
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If your facility is an
SQG:
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How Do You Get All Other Hazardous
Waste Removed
From Your Facility?
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Regardless of your generator status, contact the DHC to coordinate the removal of all other hazardous waste. |
What Is Required For Self-Transport?
| 1. | A maximum of 55 gallons of hazardous waste can be transported at a time in any size container. |
| 2. | Contact receiving depot facility to confirm that the waste being sent to them will not cause them to exceed their accumulation limits. |
| 3. | Make sure the container is closed, labeled as Hazardous Waste, and secured to the truck. |
| 4. | Bring a shovel and absorbent. |
| 5. | Bring a copy of the VSQG or SQG Generator Registration. |
| 6. | Bring the Two-part Self-transport Receipt. |
| 7. | In the case of a spill: call the Radio Room to initiate the emergency call down procures and for further instruction. |
Note for Receiving Facility: Before agreeing to accept wastes from a VSQG, confirm that the waste being delivered will not exceed the allowable accumulation limit for waste storage.
NOTE:
You do not need a special driver’s license to self-transport 55
gallons or less of hazardous waste.
What Do You Do If You Have
A Small Spill At Your Facility?
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• |
A small spill of oil is less than 10 gallons and is easily controlled and contained. | ||
| • | Use the absorbent
Spill Kit or contain it as best you can. DO NOT RISK YOUR SAFETY. |
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| • | Use the Emergency Response Plan (Facility Spill Plan). | ||
| • | Use the Spill Prevention Control and Countermeasure Plan (SPCC Plan) (Refer to the Facility Profile to determine whether an SPCC Plan is applicable to your facility). | ||
| • | Call
the facility’s Primary Emergency Coordinator.
|
Note: Know the location and contents
of the above items before an emergency occurs.
Spill
Response — The Spill Kit is meant for cleanup of minor or
controllable spills. If you cannot contain the spill, use the Call Down
Sheet.
NOTE: The Call Down Sheet is a list
of Emergency contacts that should be posted near the telephone at all
MassHighway facilities.
What Spills
Need To Be Reported?
Large Spills (typically 10 gallons or more) do always require reporting
to the DME.
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• |
A large spill is a spill to surface water, drains, unpaved areas, or a large quantity of material that cannot be easily contained by personnel and equipment in the immediate area. |
Small Spills do notmay require reporting to the DME, depending on the circumstances of the spill. Refer to the Spill Plan in Appendix B for instances where small spills (categorized as minor/controllable) need to be reported.
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• |
A small spill (typically less than 10 gallons) is a spill that can be and therefore is quickly contained and cleaned up by personnel and equipment in the immediate area, and there is little chance of the spill entering a drain, surface water, or an unpaved area. |
NOTE: For spill reporting, reference
the Emergency Response Plan (Facility Spill Plan) in
Appendix B.
What Do You
Do With The Used Clean-Up Materials?
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• |
If any amount of oil or solvent can drip from the clean-up materials when squeezed or rung out, they are considered saturated and must be disposed of as hazardous waste (put in a container and label with a hazardous waste label). |
| • | If no oil or solvent drips from the clean-up materials, they can be disposed of as solid waste and can be placed in the dumpster. |
Note: To properly contain and clean-up a minor spill of oil, use the designated absorbent materials such as MARCAL all purpose granular absorbents distributed by the stockroom; and or spill pads and socks supplied by the HazMat Coordinator. Sand or soil should only be used to contain spills in an emergency, when absorbent material is not available.
Where Else Can I Find Information On Hazardous Waste?
For the specifics on handling, storing, and disposing of hazardous waste, refer to the following MassHighway Standard Operating Procedures contained in Appendix A:
| 1. | Hazardous Waste Management Standard Operating Procedure |
| 2. | Handling and Disposal of Used Oil, Used Diesel and Used Gasoline Filters Standard Operating Procedure |
| 3. | Decommissioned Equipment Standard Operating Procedure |
| 4. | Handling and Cleaning of Asphalt Coated Hand Tools Standard Operating Procedure |
| 5. | Maintenance of Wastewater Holding Tanks and Proper Disposal of Accumulated Wastewater Standard Operating Procedure |
Universal Waste
This section provides information on managing Universal Waste, including
identification, storing, labeling, and proper offsite disposal..
What Is Universal
Waste?
Universal wastes are wastes that the EPA and/or the State DEP have determined
need special management. Universal wastes that may be found at a MassHighway
Facility include:
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Batteries:
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Pesticides
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Mercury
Containing Devices iIn Good Condition
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How Do You Temporarily
Store Universal Wastes?
Take precautions to ensure universal waste items remain in good condition
and unbroken while it is being stored. If breakage occurs, the universal
waste becomes a hazardous waste. See Chapter 1 of this handbook
for information on managing hazardous waste.
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For Universal Waste Batteries:
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For
Universal Waste Mercury-Containing Devices (fluorescent bulbs and
thermostats):
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For Universal Waste Pesticides:
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What Do You Do If You Have A Small Spill Involving Universal Waste At Your Facility?
Do not attempt to clean-up spilled mercury from a broken thermostat. Mercury is easily absorbed through the skin causing damage to the central nervous system. Mercury vapors (as with a broken fluorescent bulb) can be inhaled causing damage to the lungs. Spilled battery acid can cause burns to the skin without special clean-up equipment. Use the Call Down Sheet to report these types of spills and await instructions.
Use the absorbent Spill Kit to contain the spill as best you can.
DO NOT RISK YOUR SAFETY.
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• |
Use the Emergency Response Plan (Facility Spill Plan). |
| • | Call the Facility’s Primary Emergency Coordinator. |
| • | Use the Call Down Sheet and keep calling until you reach someone who can respond. |
How Do You Remove Universal Waste From Your Facility?
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• |
Universal Waste can be stored for up to one year. |
| • | Contact your DHC to arrange for Universal Waste disposal. |
Where Can I Find More Information On Universal Waste?
For the specifics on handling, storing, and disposing of Universal Waste refer to the following MassHighway Standard Operating Procedures contained in Appendix A:
| 1. | Handling and Disposal of Universal Waste Standard Operating Procedure |
Hazardous Materials
This section provides information on Hazardous Materials that are typically used at MassHighway Facilities, including information on identification, storing, labeling, Material Safety Data Sheets (MSDS), and disposal of old materials.
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Solid, liquid, gaseous substances, and product containers that are potentially harmful to human health and the environment | ||||||||||||||||||||||||
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Some
common hazardous materials typically found at your facility:
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This is an example of a hazardous material storage area
How Do You Store Hazardous Materials?
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Label all hazardous materials. | ||||||
| • | Store in an authorized area — preferably in contained, indoor areas (away from drains). | ||||||
| • | Store hazardous materials in a neat an organized manner. Centralize your hazardous material storage location for safety and convenience. | ||||||
| • | Outdoor salt piles must be labeled, bermed and covered when not in use. | ||||||
| • | Outdoor salt-charged sand piles must be lableled, bermed and covered when not in use. | ||||||
| • | Keep all hazardous material containers closed when not being used. | ||||||
| • | Store flammable materials inside a flammables storage cabinet. | ||||||
| • | Keep compressed gas cylinders:
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| • | When not in use, separate
oxygen and acetylene cylinders at least 20 feet apart or by a non-combustible
barrier at least 5 feet in height with a fire resistance rating
of at least one-half hour. |
Storage Sheds are used to store
bulk quantities of hazardous
materials at facilities.
Hazardous Materials Storage
Outdoor Storage — Keep sand and
salt piles in closed sheds whenever possible.
Container Storage — Label containers
with the contents and keep closed when not in use. For safety and convenience,
keep containers in centralized locations.
What Labeling
Is Required For Hazardous Materials?
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• |
All hazardous material containers must be labeled with the contents. Labeling can be done using a grease pen or duct tape and a permanent marker. | ||||
| • | All containers used for temporary storage or transporting hazardous materials must be labeled with the contents. | ||||
| • | National Fire Protection
Association (NFPA) labels are required for all hazardous materials
stored in containers of greater than 5 gallons and provide the following
information:
|
NFPA
Label — The NFPA label is the diamond-shaped, four-colored emblem
in the middle. The ratings of each hazard class range from 0 to 4 (4
being the most hazardous).
What Is A Material
Safety Data Sheet (MSDS)?
|
• |
An information source for all products containing hazardous ingredients |
| • | Furnished by the manufacturer |
| • | Provides information about the hazards of the material |
| • | Provides instructions on how to respond to an emergency situation |
NOTE: You should become familiar with the format of an MSDS so you can quickly find the information you need in the event of an emergency.
What Information Is Provided On
An MSDS?
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• |
Section 3 — hazards identification |
| • | Section 4 — first aid measures |
| • | Section 5 — fire fighting measures (lists NFPA ratings) |
| • | Section 6 — accidental release measures |
| • | Section 7 — handling and storage |
| • | Section 8 — exposure controls/personal protection |
Where Can You Find MSDSs ?
|
• |
Each facility has an information center (MSDS station) that consists of MSDS data sheets for every product that contains a hazardous material at the facility. |
| • | MSDSs are generally filed either alphabetically by product name, or if preferred, by category (e.g., paints, cleaners, fuels). |
| • | The MSDSs must remain at the designated MSDS station for easy accessibility. |
NOTE: If there is no MSDS for a particular material, call the DHC or Safety Inspector.
MSDS
Station — An MSDS will be provided by the stockroom
when a new product is delivered to a facility. It must be filed in the
MSDS binder.
How do you manage hazardous materials
that are no longer usable?
If you want to dispose of hazardous materials that are no longer used,
have expired, or are out-of-specification, refer to procedures for managing
hazardous wastes found in Section 1 and follow the quick instruction
below:
|
• |
Call the DHC or DME. |
| • | Store these materials in the Hazardous Waste Accumulation Area until they are removed from the facility (make sure they are labeled). |
NOTE: Never dispose of hazardous
materials in the trash or dumpster. Never hide hazardous materials.
Removal
— Generally, hazardous
materials must be disposed of as hazardous waste.
What Do You Do If You Have A Spill At Your Facility?
What Spills
Need To Be Reported?
click
here
What Do You Do With The Used Clean-Up
Materials?
click
here
Spill Response — The Spill Kit is meant for cleanup of minor or controllable spills of petroleum products such as oils, gasoline and/or diesel fuel. If you cannot contain the spill, use the Call Down Sheet.
NOTE: The Call Down Sheet is a list
of Emergency contacts that should be posted near the telephone at all
MassHighway facilities.
Where Can I Find More Information
On Managing
Hazardous Materials?
For more information on handling, storing, and disposing of hazardous materials refer to the following MassHighway Standard Operating Procedures contained in Appendix A.
| 1. | Hazardous Materials Management Standard Operating Procedure |
| 2. | Material Safety Data Sheet Management Standard Operating Procedure |
| 3. | Handling and Storage of Sand and Deicing Chemicals Standard Operating Procedure |
| 4. | Handling, Storage, and Disposal of Compressed Gas Cylinders |
Hazardous Materials
— Sand and salt are considered hazardous materials and must be
handled and stored in accordance with MassHighway Standard Operating
Procedures.
Asbestos Containing
Materials
This section provides information on Asbestos Containing Materials.
What Materials
May Contain Asbestos?
Asbestos containing materials (ACM) are materials that contain 1% by
weight of asbestos. ACMs that may be found at a MassHighway facility
include:
|
• |
Plaster |
| • | Floor tile and mastics: |
| • | Insulation |
| • | Roof tiles/shingles |
| • | Other building materials |
Floor tile and mastic may contain
asbestos. Surveys are conducted annually to evaluate the condition
of ACM at all MassHighway facilities.
How Do I Know If ACMs Are Present At My Facility?
MassHighway conducts an annual survey of all facilities for the presence and condition of building materials that may contain asbestos. In addition, an Operation and Maintenance Program was developed to assist in managing ACM identified at the facilities.
Note:
The locations of known ACM and potential ACM are posted at each
facility.
Generally, material in good condition will not release asbestos fibers. THERE IS NO DANGER unless fibers are released into the air and inhaled into the lungs. Therefore, so long as the ACM is in good condition and left undisturbed, it poses no harm.
What Is The Notification Procedure
For Renovation Or
Demolition Activities?
Prior to any renovation or demolition, facility personnel and/or the District Asbestos Coordinator request a renovation/ demolition asbestos survey. The District Asbestos Coordinator will coordinate the conduct of a survey and any asbestos removal or material repair that may be required.
A BWP AQ 06 form shall be sent to the MADEP by the District Asbestos Coordinator 10 days prior to any demolition/renovation activity. If asbestos abatement is necessary, an ANF-001 form must be filled out by the abatement contractor and sent to the MADEP at least 10 days prior to beginning the project. The ANF form shall be filled out by the abatement contractor.
What If I Discover That ACM Has Been Damaged?
Contact your District Asbestos Coordinator who will coordinate the removal and or repair of the ACM.
Where Can I Find More Information On Asbestos?
For more information on asbestos containing materials refer to the MassHighway Asbestos Operations and Maintenance Program Guide available from your District Asbestos Coordinator and the following Standard Operating Procedure contained in Appendix A:
| 1. | Management of Asbestos Containing
Materials at MHD Facilities Standard Operating Procedure |
Solid Waste
This section provides information on Solid Waste Management at MassHighway Facilities including information on types of solid waste, accumulation areas, prohibition on open burning of wood waste, and managing empty containers. Note that accumulation of solid wastes at MassHighway facilities is for internal use only. Contractors, other state agencies, and the general public are not permitted to dispose of their solid waste at MassHighway facilities. NOTE: Solid waste can be temporarily stored in contained areas as long as it does not create a public nuisance.
What Is Solid
Waste?
Solid wastes are uselessunusable, unwanted, or discarded solid, liquid,
or contained gaseous material which has come into the possession of
MassHighway through Highway Operations (Union Areas) such as roadside
pick-ups, street sweeping and catch basin cleaning.
Solid Waste
Types And Storage Requirements
| Category | Waste Types |
Temporary Storage Requirements |
| ABC | asphalt grindings, bricks, concrete | segregate and store in designated accumulation area |
| C&D | wood, building materials | segregate and store in designated accumulation area |
| Wood Waste | trees, stumps, wood chips, branches | segregate and store in designated accumulation area |
| Tires | used tires | segregate and store in designated accumulation area |
| Appliances / White Goods |
refrigerators, water heaters, washers, dryers | segregate and store in designated accumulation area |
| Street Sweeping Debris | collections from street sweeping operations | when possible, berm and temporarily store on pavement |
| Metal | scrap metal | segregate and store in designated accumulation area |
| Treated Timbers | wood treated with a preservative (i.e., creosote pressure treated lumber) | segregate and store in designated accumulation area |
| Trash | litter, garbage | dumpster |
| Catch Basin Sediment |
sand, silt, leaf and trash material removed during catch basin / drainage structure cleaning and maintenance | segregate and store in designated accumulation area |
| Televisions/ Computer Monitors |
electronic equipment containing cathode ray tubes | segregate and store indoors (avoid breakage) |
What Is A Designated Accumulation Area?
|
• |
It is used to segregate and store solid waste. |
| • | The area should be labeled and have clearly marked boundaries. |
| • | Areas can be separated with jersey barriers or guardrails. |
| • | Each accumulation area must contain only one type of solid waste. |
| • | Accumulation areas serve to keep solid wastes consolidated, to avoid similar types of waste from being scattered throughout the facility. |
| • | Consult with your Area Supervisor, DME, or DHC for emergency storage instructions if an accumulation area is not available at your location. |
Solid Waste Accumulation Area — Label and segregate all
solid waste.
How Do You Remove Solid Waste From Your Facility?
|
• |
Removals are coordinated by the DME, who will coordinate with the DHC. |
| • | You may have to transfer some wastes to a designated storage facility in your district for proper storage and removal. |
| • | Refer to your facility plan in Appendix B for the categories that your facility is designated to accumulate. |
Designated Solid Waste Accumulation Area — Solid waste White
Goods must be segregated and stored in designated areasrecycled.
Is Burning an Approved Option for Disposal of Wood Waste at MassHighway Facilities?
No. Burning of any wood waste is
strictly prohibited at MassHighway Facilities. Whenever practical,
brush and forestry debris should be chipped and recycled.
What Do You Do With
An Empty Oil Or Chemical Drum That Was Provided By The District Stockroom?
NOTE: A container is considered empty if there
is no more than 1 inch (2.5 centimeters) of residue. Use as much of
the material as possible and transfer the remainder into a suitable
container
|
• |
Label it “empty.”. |
| • | Keep it protected from the elements — If at all possible, do n’ot store keep itempty drums outdoors. If outdoor storage is necessary due to space constraints, place drums on their side and stack safely in a manner that prevents drums from rolling or interfering with facility operations. |
| • | Empty drums must be returned to the District Stockroom or vendor. |
| • | Empty metal drums or other empty metal containers found during roadway cleaning activities should be crushed and placed in the scrap metal pile. |
Storage
— Properly label and store empty drums.
What Do You Do With An Empty Compressed Gas Cylinder?
|
• |
Refer to the Standard Operating Procedure. |
| • | Label it “empty.” |
| • | Call the distributor to pick up cylinder – do not self-transport. |
| • | Gas grill propane containers found during roadway cleaning activities should be stored outside at designated facilities for eventual offsite disposal. Contact your DHC to arrange disposal. |
Where Can I Find More Information On Solid Waste?
For more information on handling, storing, and disposing of solid waste refer to the following MassHighway Standard Operating Procedures contained in Appendix A:
| 1. | Temporary Storage of Solid Waste at MassHighway Facilities Standard Operating Procedure |
| 2. | Handling and Disposal of Empty Oil/Chemical Drums Standard Operating Procedure |
| 3. | Handling, Storage, and Disposal of Compressed Gas Cylinders Standard Operating Procedure |
| 4. | Prohibition on Open Burning of Wood Waste at MassHighway Facilities Standard Operating Procedure |
Roadside Issues
This section provides information and guidance on how to manage debris that must be removed from the roadside, including information on management of animal carcasses, unknown materials, and medical waste.
How Do You Handle
Animal Carcasses Found On The Roadway?
|
• |
MassHighway is authorized by the Division of Fisheries and Wildlife (DFW) to retrieve and transport animals killed by collision with motor vehicles or otherwise found dead on or adjacent to a public way. |
| • | To minimize contact, disposable gloves and shovels must be used to handle the carcass. |
| • | If transport is warranted, as required by the Division of Fish and Wildlife, place the carcass in a plastic bag or wrap it in plastic. |
| • | Avoid contact with body fluids. |
| • | Hands must be washed after handling the carcass. |
| • |
Any equipment that comes in contact with the carcass must be washed after use. |
How Do You Dispose Of Animal Carcasses
Found On The Roadway?
|
• |
MassHighway must handle animal carcasses in accordance with the permit issued by the State Division of Fish and Wildlife and in accordance with Massachusetts General Law for retrieval and transport of dead animals. MassHighway personnel must also follow standard operating procedures for Disposal of Animal Carcasses. | ||
| • | Animal carcasses retrieved by MassHighway personnel may either be buried on state property within the state Highway layout/Rights of Way and preferably within the vicinity of carcass discovery, or incinerated if a local incinerator is available. A list of licensed incinerators is available from the DEP at 617-292-5578. | ||
| • | A record of roadside pickup of animal carcasses must be maintained by the designated District Maintenance personnel. | ||
| • | If possible, identification tags of pets should be retained. | ||
| • | Special conditions apply
to certain animal carcasses:
|
What is a Roadside
Unknown?
All unidentifiable wastes encountered on the roadside are considered
“unknown” until attempts to identify the waste or threat associated
with the waste have been conducted by a hazardous waste contractor.
All medical waste is to be considered infectious.
What is Medical Waste?
Medical Waste is any material of a biological nature such as:
|
• |
Blood |
| • | Body Fluids |
| • | Sharps |
| • | Body Parts |
| • | Red Bag Waste |
What Do You Do With Medical Waste
Or Unknowns Found
On The Roadside?
|
• |
All efforts will be made by MassHighway personnel on scene to identify the owner and/or the handler/responsible party for the waste (ambulance company, hospital, waste hauler). |
| • | Call the District Radio Room to report the finding and request that notification be made to the Safety office. |
| • | The Safety Inspector will examine the waste and coordinate disposal with the DHC. If the waste cannot be identified by a visual inspection, or the inspector deems the material unsafe, the DHC or Safety Inspector will coordinate the removal of the material by a waste removal contractor. |
Where Can I Find More Information On Roadside Issues?
For more information on responding to roadside wastes, refer to the following MassHighway Standard Operating Procedure contained in Appendix A:
| 1. | Disposal Of Animal Carcasses Standard Operating Procedure |
| 2. | Roadside Unknown Waste Handling Standard Operating Procedure |
Tanks
This section provides information on aboveground and underground storage tanks and describes the basic operating systems for storage tanks and tank inspection requirements.
What Types Of
Tanks Are Maintained At Facilities?
Aboveground and Underground tanks present at your facility are shown
on the Facility Plan at the front of this Handbook. Materials typically
stored in tanks at MassHighway facilities include:
|
• |
Fuel
|
||||||||||
| • | De-icing Materials
|
How Are Underground
Storage Tanks For Gasoline And Diesel Fuel Monitored For Leaks?
Underground gasoline and diesel tanks are equipped with electronic leak
detection systems. These systems are monitored by the District Storekeeper
or other District/Operations representative.
What Is Stage
I Equipment?
Gasoline USTs are equipped with Stage I Vapor
Recovery Equipment designed to prevent gasoline vapors from escaping
into the air while tanks are being filled. The equipment consists of
an access port equipped with:
|
• |
Spill containment bucket |
| • | Valve and an access port with vapor break or: |
| • | Coaxial fill tube |
What Is Stage II Equipment?
Gasoline dispensers are equipped with Stage II
Vapor Recovery equipment to reduce gasoline vapors from escaping
during pumping. Gasoline dispensing nozzles are equipped with:
|
• |
Vapor recovery boot |
| • | Delivery/Recovery Hose: (designed to dispense fuel through an inner hose and, recover vapors through an outer hose and back to the UST) |
| • | Breakaway valve |
What Types Of Inspections Are Required?
|
• |
Weekly
Aboveground Storage Tank Inspections
|
||||||||||
| • | Weekly Stage I and II Vapor
Equipment inspections
|
||||||||||
| • | All underground storage tanks
must have daily electronic inventory checks that will be monitored
by the District Storekeeper or other District/Operations representative.
|
|
• |
Weekly Stage I and II inspection forms |
What Fuel Dispensing Procedures Must I Follow?
|
• |
Turn off engine. |
| • | Do not smoke. |
| • | Fill carefully to avoid spillage and to keep the vapor recovery system engaged. |
| • | Do not top off. |
| • | Apply absorbent material if spillage occurs. |
When Is Emergency Action Required?
|
• |
If an alarm on the tank is activated use the Emergency Call Down Sheet. |
| • | If alarm activates after hours notify the radio room immediately and await instructions. |
Where Can I Find More Information On Tanks?
For more information on tank issues refer to the following MassHighway Standard Operating Procedures contained in Appendix A:
|
1. |
Fuel Dispensing at MassHighway Facilities Standard Operating Procedure |
| 2. | Inspection and Repair of Stage I and Stage II Recovery Systems associated with Underground Storage Tanks Standard Operating Procedure |
| 3. | Site specific SPCC Plans that may have been prepared for facilities storing 1,320 gallons or more combined oil products in aboveground storage tanks, electrical transformers, or drums |
Water Quality
This section provides information on how MassHighway manages wastewater
and stormwater at facilities including information on the types of wastewater,
discharge options, oil/water separators, holding tanks, septic systems,
floor drains, preventative measures for stormwater runoff, and vehicle
washing.
What Are The Different Types Of Wastewater Generated At Masshighway Facilities?
|
• |
Sanitary wastewater-generated from restrooms |
| • | Stormwater -generated from precipitation, including snow melt |
| • | Industrial wastewater- generated by vehicle washing and traffic paint equipment cleaning |
What Are The Requirements For The
Discharge Of Wastewater At Masshighway Facilities?
Sanitary wastewater from bathrooms is discharged
to either:
|
• |
public sanitary sewer system |
| • | or an onsite septic system |
Industrial wastewater from vehicle washing is discharged to:
|
• |
an oil water separator and then to either a holding tank or to a sanitary sewer system |
Industrial wastewater can be discharged to the sewer only if the local sewer provider has approved this discharge (your DHC can provide guidance on whether there are permit conditions and/or wastewater discharge restrictions that apply to your facility).
Stormwater is discharged to either:
|
• |
to a stormwater catchbasin or as sheet flow runoff |
Refer to the Facility Profile at the front of this Handbook to determine the types of water discharges at your facility. Facility Plans show the locations of wastewater structures at your facility.
What Inspections
Are Required For Oil/Water Separators?
|
• |
Self-test the alarm system on a weekly basis, if so equipped. |
| • | Report any malfunctions to your supervisor. |
| • | Notify the DHC if a “High Oil” or Pump Out Oil” condition is found. |
| • | Specific OWS permits may dictate other inspection requirements, such as maintaining a log, or collecting effluent samples. |
What Inspections Are Required
For Holding Tanks?
|
• |
The tank must be gauged
on a regular basis at a minimum (underground tanks must be gauged weekly). |
| • | Notify the DHC or the District
Structures Maintenance Engineer when the holding tank is 75% full. |
| • | Report any malfunctions to your supervisor, including surface water entering the tank. |
What Are The Other Requirements
For Holding Tanks?
|
• |
Label tank as Non-Hazardous Industrial Wastewater. |
| • | Keep tank closed when not in use. |
Example
Holding Tank alarms
and access manholes are shown here.
What Are The
Management Requirements For A Septic System?
No material other than domestic sanitary wastewater and sewage may be
discharged to a septic system.
|
• |
Record water meter readings on a quarterly basis. |
| • | Report quarterly water usage to your DHC. |
| • | Notify your supervisor of any system malfunctions. |
| • | Your supervisor will arrange to have the system inspected. |
Signs of a malfunctioning system include:
|
• |
sewage back-ups |
| • | sewage surfacing in drains/and or leach fields |
| • | slow draining toilets |
| • | strong sewage odors |
| • | excessive green growth over the leach field |
What Can Affect
Water Quality?
|
• |
Leaking equipment |
| • | Outside storage of hazardous materials that are not protected from rain water |
| • | Improper handling and disposal of vehicle wash water |
| • | A spill to a floor drain or stormwater catchbasin |
| • | A spill to pavement that ends up in a storm drain |
| • | A spill to the ground |
Note: Storm drains receiving impacted water from facility operations can be visually identified by presence of heavy silt loads or oil sheens.
Floor Drains — Indoor
spills
must be contained before they reach
the floor drains.
What Preventive Measures Can You Take To Preserve Water Quality?
|
• |
Inspect vehicles and equipment for leaks. |
| • | Store decommissioned vehicles or equipment on paved surfaces, and immediately have leaks repaired; otherwise, drain fluid reservoirs. |
| • | Protect outdoor hazardous materials storage from rain water. |
| • | Protect floor and storm drains from spills. |
| • | Dispose of wastes properly — do not pour them down the drain. |
Outdoor
Storage — Protect outdoor material storage from precipitation.
What Are The Requirements For Storm Water Catchbasins?
|
• |
Avoid rinsing equipment, vehicles or stockpiling of sand near stormwater catch basins. |
| • | Inspect stormwater catch basins after each snow and ice season and, whenever possible, before the spring rain season. |
| • | Stormwater catch basins found to contain accumulated sediments exceeding 50% of the capacity of the sump shall be cleaned. |
| • | Report damaged Stormwater catch basins to your supervisor. |
| • | Your supervisor will arrange for needed repairs. |
What Do You Do If A Spill
Threatens The Water Quality?
click
here
What Does Vehicle
Washing Include?
|
• |
Washing with heated water |
| • | Power washing/Pressure washing (no soap, no heat) |
| • | Any type of physical agitation (e.g., use of sponge, brush) |
| • | Steam cleaning |
| • | Washing using soap or detergent |
Where Can You Wash Vehicles And
Equipment?
|
• |
All vehicle and equipment washing must be conducted at a designated facility. |
| • | Refer to the Facility Profile at the front of this Handbook to determine if your facility is a designated washing facility. |
Vehicle washing —Washing must take place indoors at designated facilities.
NOTE: Contractors are not permitted to wash or rinse their vehicles at MassHighway facilities.
What Is A Designated Vehicle Washing
Facility?
|
• |
A facility equipped with floor drains connected to either the municipal sewer (with the appropriate permit) or a wash water recycling system. |
| or | |
| • | A facility equipped with an approved holding tank. |
NOTE: Refer to the Facility Profile
at the front of this Handbook to determine if your facility is designated
for vehicle washing.
Vehicle Washing — This facility
is designated for vehicle washing because the floor drains are connected
to a wash water recycling system.
What Do You Do If Your Facility
Is Not Designated For
Vehicle Washing?
Take your vehicle to the closest designated facility within your District
and refer to the Vehicle Washing Standard Operating Procedure.
Where Can You Rinse Vehicles And Equipment?
|
• |
Vehicles can be rinsed outdoors. |
| • | Vehicles or equipment used for transfer/storage of petroleum-based products can only be rinsed/washed at a designated vehicle washing facility. |
Where Can I Find More Information On Water Quality?
For the specifics on management of water quality issues, refer to the following MassHighway Standard Operating Procedures contained in Appendix A:
| 1. | Outdoor Operations/Maintenance Equipment Storage Standard Operating Procedure |
| 2. | Decommissioned Equipment Standard Operating Procedure |
| 3. | Inspection and Maintenance of Stormwater Catch Basins Standard Operating Procedure |
| 4. | Vehicle Washing at MassHighway Facilities Standard Operating Procedure |
| 5. | Inspection and Maintenance of Oil/Water Separators (OWS) Standard Operating Procedure |
|
6. |
Maintenance of Wastewater Holding Tanks and Proper Disposal of Accumulated Wastewater Standard Operating Procedure |
| 7. | Maintenance of Subsurface Sewage Disposal Systems Standard Operating Procedure |
| 8. | Maintenance of Flow Meters for Sewage Disposal Systems Standard Operating Procedure |
Wetlands
This section provides information on wetlands and how they are protected at MassHighway Facilities.
|
• |
Areas of standing water (ponds, pools) or flowing water (streams) |
| • | Areas where soil is wet long enough during the growing season to support a wetland plant community (bogs, meadows, shrub or wooded swamps) |
| • | Areas of seasonal flooding or flow including: intermittent streams and manmade drainage ditches |
NOTE: For facilities that have wetland areas, they are marked on the facility plans. The facility plan is located in the front of this Handbook.
Wetlands — Wetlands are valuable because they provide habitats for plant and animal species, flood control, and water quality enhancement.
Examples Of Wetlands
Wetlands — Wetlands are present on many MassHighway facilities.
Wetlands — Manmade drainage systems or ditches are designated as wetlands because of the presence of water and the types of vegetation that grow within them.
|
• |
An area extending 100 feet beyond the boundary of a wetland |
| • | A Buffer Zone can be determined by measuring off a horizontal distance of 100 feet beyond the wetland boundary. |
NOTE: Where applicable, Buffer Zones are marked on the facility plans.
Buffer Zone — The purpose of the Buffer Zone is to provide additional protection for the wetlands.
|
• |
An area extending 200 feet
beyond the mean annual high water line of a perennial river or stream. |
| • | For designated urban areas only: the Riverfront Area is reduced to 25 feet. |
NOTE: For facilities that have riverfront areas, they are marked on the facility plans. The facility plan is located in the front of this Handbook.
Riverfront Areas — The purpose
of the Riverfront Area is to protect plant and animal species and to
provide flood and erosion control.
What Work Can
You Do In A Wetland/Riverfront Area?
|
• |
Nothing without a permit |
| • | You need a permit to do any work in a wetland such as removing, filling, dredging, or altering. |
| • | Do not store anything within a wetland/riverfront area. |
| • | Other maintenance activities that could impact a wetland/riverfront include vegetation removal and grading. |
| • | Do not discharge any wastewater to a wetland or riverfront area. |
NOTE: Do not fill ANY land including wetlands and buffer zones with street sweepings or yard waste.
What Work Can You Do In A Buffer
Zone Or Riverfront Area?
|
• |
Stay out of the buffer zone, if possible. | ||||||||||||
| • | Work proposed within a buffer zone must not impact or alter adjacent wetland resource areas. | ||||||||||||
| • | If you have to store equipment,
useable materials, or solid waste in a buffer zone:
|
||||||||||||
| • | Check with the District Environmental Engineer to determine if proposed activity beyond those mentioned above will require a permit. |
Where Can I Find More Information On Wetlands?
For more information on wetlands issues refer to the following MassHighway Standard Operating Procedure contained in Appendix A:
|
1. |
Protection of Wetland Resource Areas Standard Operating Procedure |
Record Keeping
This section summarizes record keeping requirements for environmental management at MassHighway facilities. For more information on what records need to be maintained by your facility, refer to the preceding sections of this handbook.
What Documentation Needs
To Be Maintained?
|
• |
Weekly Hazardous Waste Inspection Checklist, if applicable |
| • | Weekly Stage I and II Vapor Recovery Equipment Inspections, if applicable |
| • | MSDSs |
| • | Self-transport receipts for VSQGs that self-transport their wastes |
| • | Tank permits (Fire Department permits) which must be posted |
| • | Call Down List (Make sure the list is accurate and up-to-date) |
| • | Generator registration number (VSQG, SQG) |
| • | Asbestos Containing Material postings |
| • | Renovation/demolition Asbestos Survey Request Forms |
| • | ermits of a routine nature such as drainage ditch cleaning |
| • | Oil/water separator, holding tank, or septic tank pump-out or maintenance records |
| • | Construction & Installation records for Industrial Wastewater Holding Tanks and operator records for shipments of wastewater |
Where Are These
Records Kept, And For How Long?
|
• |
Weekly Hazardous Waste Inspection Checklist – sent to DHC weekly |
| • | Stage I and II Vapor Recovery
Equipment Forms – sent to Structures Maintenance Personnel weekly |
| • | MSDSs – maintained at the facility at all times |
| • | Self-transport receipts – one part goes to the receiving facility during shipment and the other part is maintained at the facility that transported the waste |
| • | Tank permits – posted at the facility in a conspicuous location |
| • | Call Down List – posted at the facility in a conspicuous location near a phone |
| • | Generator registration number – maintained at the facility at all times |
| • | Asbestos Containing Material postings - maintained at the facility at all times |
| • | Renovation/demolition Asbestos Surveys – maintained by District Asbestos Coordinator |
| • | Oil/water separator, holding tank, and septic tank pump-out and maintenance records - maintained by the District Structures and Facilities Engineer |
| • | Construction & Installation
records for Industrial Wastewater Holding Tanks and operator records for shipments of wastewater – maintained by the District Structures and Facilities Engineer |
Inspections
Facility personnel should expect inspections to occur on a regular basis.
These inspections may be announced or unannounced.
What Inspections
Should You Expect?
|
• |
EPA inspections |
| • | DEP inspections |
| • | MassHighway Self Audits |
| • | MassHighway Regular Inspections |
What Will The Inspector Want To
Look At?
|
• |
Hazardous waste accumulation areas |
| • | Hazardous material storage areas |
| • | Solid waste accumulation areas |
| • | Tank monitoring records and permits |
| • | Hazardous waste self-transport receipts |
| • | Spill Plan/Facility Handbook Sign-off Sheet |
What Can You Do To Be Prepared
For An Inspection?
|
• |
Always maintain files and documents in a neat and orderly manner. |
| • | Post permits and emergency response contacts in a central location. |
| • | Implement Good Housekeeping Practices – On a Continuous Basis! |
| • | Keep materials and waste labeled. |
| • | Complete regular inspections. |
| • | Familiarize yourself with the facility foreman, other District personnel, and all the topics in this handbook that relate to your particular facility. Review the information presented on the facility plan. |
What Will The Inspector Be Interested
In?
|
• |
How you are storing hazardous waste |
| • | How you are storing hazardous materials |
| • | How you are storing solid waste |
| • | Whether you are aware of sensitive receptors at the facility, such as wetlands |
| • | Whether you are familiar with the Facility Spill Plan and know whom to contact in the event of a spill |
| • | Whether the facility appears organized and neat |
What Should You Do When A DEP Or EPA Inspector Arrives
At The Facility?
|
• |
Be polite | ||||||||
| • | Things to politely ask the
Inspector:
|
Whom Should You Contact When A DEP Or EPA Inspector Arrives?
MassHighway
has delegated responsibility for facility environmental compliance to
facility foremen, District, and Boston staff. For this reason, you should
contact the following individuals if an inspector arrives at the facility.
|
• |
Your Immediate Supervisor |
| • | Your DME |
| • | Your DHC |
How Should You Conduct Yourself During The Inspection?
| • | Be honest.
|
||||||||||
| • | Be observant.
|
||||||||||
| • | Be responsive.
|
What Should Be Done At The Conclusion Of The Inspection?
|
• |
Request a copy of the Inspector’s notes and field report. |
| • | Provide the Inspector’s notes and your notes to the DME or DHC. |
Standard operating Procedure (SOP) LIST:
| ENV-01-02-1-000 |
Materials Safety Data Sheet Management |
| ENV-01-03-1-000 | Hazardous Waste Management |
| ENV-01-04-1-000 | Handling and Disposal of Used Oil, Used Diesel and Used Gasoline Filters |
| ENV-01-05-1-000 | Used Vehicle Battery Disposal |
| ENV-01-06-1-000 | Handling, Storage, and Disposal of Compressed Gas Cylinders |
| ENV-01-07-1-000 | Handling and Disposal of Universal Waste |
| ENV-01-08-1-000 | Handling and Storage of Sand and Deicing Chemicals |
| ENV-01-09-1-000 | Handling and Cleaning of Asphalt Coated Hand Tools |
| ENV-01-10-1-000 | Disposal of Animal Carcasses |
| ENV-01-11-1-000 | Hazardous Materials Management |
| ENV-01-12-1-000 | Temporary Storage of Solid Waste at Facilities |
| ENV-01-13-1-000 |
Handling and Disposal of Empty Oil/Chemical Drums |
| ENV-01-14-1-000 | Fuel Dispensing |
| ENV-01-15-1-000 | Protection of Wetland Resource Areas |
| ENV-01-16-1-000 | Groundwater Monitoring Well Maintenance |
| ENV-01-17-1-000 | Maintenance of Subsurface Sewage Disposal Systems |
| ENV-01-18-1-000 | Maintenance of Wastewater Holding Tanks and Proper Disposal of Accumulated Wastewater |
| ENV-01-19-1-000 | Inspection and Maintenance of Stormwater Catchbasins |
| ENV-01-20-1-000 | Outdoor Operation/Maintenance Equipment Storage |
| ENV-01-21-1-000 | Decommissioned Equipment |
| ENV-01-22-1-000 | Vehicle Washing |
| ENV-01-23-1-000 | Flow Meters |
| ENV-01-24-1-000 | Street Sweepings |
| ENV-01-25-1-000 | Interim Roadside Unknown Waste Handling |
| ENV-01-26-1-000 | Prohibition on Open Burning of Wood Waste |
| ENV-01-27-1-000 | Inspection and Maintenance of Oil/Water Separators |
| ENV-01-28-1-000 | Inspection and Repair of Stage I and
II Recovery Systems associated with USTs |
| ENV-01-29-1-000 | Management of Asbestos Containing Materials |