Document 13043457

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FACILITY ENVIRONMENTAL
HANDBOOK
HAZARDOUS WASTE | UNIVERSAL WASTE | HAZARDOUS MATERIALS | ASBESTOS CONTAINING MATERIALS | SOLID WASTE
ROADSIDE ISSUES | TANKS | WATER QUALITY | WETLANDS | RECORD KEEPING | INSPECTIONS
Table of Contents
Introduction.................................................................................................................................................... i
1.0 Hazardous Waste ............................................................................................................................. 1
2.0 Universal Waste ............................................................................................................................... 7
3.0 Hazardous Materials ........................................................................................................................ 9
4.0 Asbestos Containing Materials ...................................................................................................... 13
5.0 Solid Waste .................................................................................................................................... 15
6.0 Roadside Issues.............................................................................................................................. 18
7.0 Tanks.............................................................................................................................................. 20
8.0 Water Quality................................................................................................................................. 23
9.0 Wetlands ........................................................................................................................................ 27
10.0 Record Keeping ............................................................................................................................. 30
11.0 Inspections ..................................................................................................................................... 31
List of Appendices
Appendix A
Standard Operating Procedures
Appendix B
Emergency Response Spill Plan (Facility Spill Plan)
Appendix C
Storage Tank Monitoring and Management Addendum
MassDOT Facility Environmental Handbook
Introduction
The Massachusetts Department of Transportation (MassDOT) - Highway Division has developed
an Environmental Management System (EMS) to provide the framework for conducting facility
activities in a manner that is consistent with environmental requirements and protective of the
environment. MassDOT facilities include maintenance, snow or ice depots, drawbridges, and
jurisdictional highways. This Facility Environmental Handbook (Handbook) is a key component
of the EMS and serves as a reference tool for facility personnel in maintaining environmental
compliance at MassDOT’s facilities and while conducting routine roadway maintenance
activities. It provides basic information on how to conduct facility and roadway maintenance
activities in an environmentally sensitive manner that is consistent with applicable environmental
laws, regulations, and MassDOT policies.
MassDOT’s Commitment to the Environment
The MassDOT Highway Division is committed to being a responsible steward of the
environment. Massachusetts state transportation agencies are fulfilling their mission to provide
efficient, safe, clean, and cost-effective transportation systems and services for the
Commonwealth. Our actions can have a broad and visible impact on the communities we serve.
Therefore, we must remain accountable for our actions and exercise good judgment to benefit all
of our stakeholders—our customers, our employees, and the public.
MassDOT Highway Division has taken a leadership role in supporting MassDOT’s overall
environmental commitment by developing a formal Environmental Management System. The
EMS ensures continual compliance with all environmental requirements that apply to its facility
operations. Routine maintenance activities conducted at our transportation maintenance facilities
require employing sound controls, tools, and practices to avoid and otherwise minimize impacts
to the environment. The EMS regulates these activities to mitigate environmental risks
associated with this process. All MassDOT employees and contractors are expected to conduct
their job responsibilities in accordance with the EMS and its supporting programs.
Although this EMS is specific to MassDOT Highway Division, each division should consider
using the framework of this EMS as a model to establish formal programs and procedures that
promote sustainable practices within their own division. Developing an EMS, following the
established procedures, and continuously improving the program will result in increased
efficiency, better community relations, and a safer and cleaner environment.
Why must MassDOT maintain compliance?
Many routine activities that are conducted at MassDOT facilities and discussed in this document
such as vehicle maintenance, vehicle washing, and storage of sand and salt are subject to
environmental regulations. It is the responsibility of all MassDOT facility personnel to conduct
operations in accordance with applicable laws, regulations, and MassDOT Standard Operating
Procedures.
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MassDOT Facility Environmental Handbook
How can I maintain environmental compliance at my facility?
Maintaining environmental compliance can be achieved through these four simple rules:
Keep it neat
This is the easiest and often the most important element of environmental
compliance. Keep your work areas swept up; store tools and equipment
back in their place; and place 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.
Inspect it
Your District Environmental Compliance Coordinator (ECC) 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. For example, hazardous waste storage
areas must be inspected once per week.
Label it
Hazardous waste and hazardous material containers must be labeled with
their contents. Certain materials may require special labels if they are
hazardous. If you identify a container without a label, it is your
responsibility to label it.
Report it
When in doubt, contact your Supervisor, District ECC, or District
Maintenance Engineer (DME). They are your resource and can provide
the information that you need to maintain environmental compliance at
your facility. Your District ECC can provide labels, give instructions on
what to do in case of a spill, or arrange for a contractor to remove wastes.
The District ECC is your guide for maintaining environmental
compliance.
Report it
Label it
Inspect it
Keep it
Neat
General Environmental roles & responsibilities
In order to maintain environmental compliance at MassDOT facilities, every facility employee
and designated District and Boston Headquarters’ employees must play an active role. This
includes maintaining awareness 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. The
following is a description of the environmental roles and responsibilities of MassDOT personnel:
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MassDOT Facility Environmental Handbook
Facility Personnel
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Maintain facilities in a neat and orderly fashion as described in this Handbook.
Adhere to MassDOT SOPs.
Notify the facility supervisor in the event of a spill or other environmental condition.
Facility Supervisor
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Notify the appropriate contact person within the District or Boston in the event of a spill
or other environmental condition.
Maintain certain environmental records.
Monitor certain environmental conditions.
Allocate resources to ensure good housekeeping practices.
District Environmental Management Systems Compliance Coordinator (ECC)
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Serve as the liaison between facility personnel, the District Maintenance Engineer, and
the Environmental Section in Boston Headquarters.
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.
Obtain and ensure compliance with applicable permits, environmental regulations, and
MassDOT SOPs for structures and activities.
Ensure that time is allocated for facility personnel to implement 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 facility wetland resource area-related submittals either directly with the
regulatory authorities or with the Environmental Section.
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 or roadway maintenance activities may have the
potential to impact wetlands.
Safety Inspectors
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Provide initial Right-to-Know training.
Supply safety equipment.
Conduct regular facility safety inspections.
Coordinate and respond to spills that may be discovered along roadways or occur at
facilities.
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MassDOT Facility Environmental Handbook
District Asbestos Coordinators
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Arranges Annual Asbestos Surveys and Renovation/Demolition Surveys.
Coordinates asbestos removal actions.
Maintains records of filings, surveys, and abatement reports.
Stock Room Manager
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Supply bulk deliveries of hazardous materials to facilities.
Coordinates the return of empty drums to the supplier.
Emergency Response Coordinator
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The Emergency Response Coordinator is the district designee that is responsible for
overall coordination of spill response at MassDOT facilities.
References
Further description of roles and responsibilities and additional environmental compliance tools
are provided in the following documents.
Standard Operating Procedures (SOPs) Appendix A
The SOPs are the primary guidance and enforcement documents for the MassDOT. SOPs
relating to facility activities are provided in Appendix A of this Handbook. Most of the
information contained within these SOPs is presented in the Handbook sections. All district
supervisory personnel must be familiar with the SOP’s.
It is important that MassDOT 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 spills of oil or
hazardous materials (OHM), hazardous wastes, and universal wastes that may occur at facilities.
Storage Tank Monitoring and Management Addendum Appendix C
The Storage Tank Monitoring and Management Addendum is provided in Appendix C of this
handbook and includes additional information regarding the management of storage tanks at
MassDOT facilities.
MassDOT Environmental Management System Manual (EMS Manual)
The EMS Manual documents the components of MassDOT’s EMS. Copies of the manual may
be obtained on MassDOT’s Intranet and at the District and Boston Offices.
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MassDOT Facility Environmental Handbook
1.0 Hazardous Waste
MassDOT is committed to minimizing hazardous waste generation and is actively evaluating
means and methods to reduce or eliminate the generation of hazardous wastes. This section
provides information and 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.
SOP References (see Appendix A)
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SOP 03 Hazardous Waste Management
SOP 05 Used Vehicle Batteries
What is hazardous waste?
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
waste transmission fluid
saturated absorbent
waste kerosene/diesel fuel (often
used to clean asphalt-covered tools)
cracked/leaking car batteries
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waste aerosol containers (expired and/or
no longer usable)
waste paint waste solvent broken fluorescent bulbs
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).
Label it with a hazardous waste label. Place the label where it can be seen and clearly mark
the contents.
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 with adequate secondary containment.
Place the containers in the designated hazardous waste storage area.
Separate drums of incompatible waste by berms, dikes, or similar structures.
Note: Cracked automotive batteries must be disposed of as hazardous waste. Intact used
batteries from MassDOT 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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MassDOT Facility Environmental Handbook
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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,
hazardous waste must be selftransported 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 secondary containment pallets, store
full drums on an impervious surface and active drums on the secondary containment 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.
A container of up to 55 gallons is allowed.
Only one container can be used for each type of waste.
The facility is responsible for managing the activity producing the waste (ex. changing oil)
and the associated satellite accumulation area.
The container must be labeled with the words “Hazardous Waste,” the contents, and hazard.
Waste must be moved to the centralized hazardous waste storage area within 3 calendar days
after the container is full.
Satellite accumulation areas must be inspected weekly.
Satellite Accumulation. Only a few facilities operate satellite accumulation areas. Contact
your ECC if you are interested in establishing one.
What are the differences between a very small quantity generator (VSQG), a small
quantity generator (SQG), and a large quantity generator (LQG) of hazardous
waste?
Two factors determine the facilities generator status: the rate at which a facility generates
hazardous waste and the amount of hazardous waste that is stored. Most MassDOT, Highway
Division facilities have been registered as either a VSQG or a SQG. If you do not know if your
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facility is a VSQG or a SQG, ask the ECC. The same numerical thresholds apply to waste oil as
hazardous waste, and a site can be a VSQG, SQG, or LQG of hazardous waste and/or a VSQG,
SQG, or LQG of waste oil. Your facility may be registered for a separate generator status for
each.
VSQG
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Can only store a maximum of 2,200 pounds, or approximately 270 gallons, or five 55-gallon
drums, of hazardous waste or waste oil (no limit on storage time) until all five drums are full.
Can generate a maximum of 220 pounds, or approximately 27 gallons, of hazardous waste or
waste oil per month.
SQG
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Can only store a maximum of 13,200 pounds, or approximately 1,620 gallons or twenty-eight
55-gallon drums, of hazardous waste or waste oil (MassDOT limits storage to 10 drums)
Can generate a maximum of 2,200 pounds, or approximately 270 gallons, of hazardous waste
or waste oil per month.
Hazardous waste can only be stored for a maximum of 180 calendar days from the date the
container has been added to the centralized hazardous waste storage area.
LQG
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There is no maximum storage or generation amount of hazardous waste or waste oil.
Hazardous waste can only be stored for a maximum of 90 calendar days from the date the
container has been added to the centralized hazardous waste storage area.
LQG of hazardous waste have contingency plan requirements, personnel training, and
biennial reporting. However, LQG of waste oil do not have these requirements.
Note: If your facility is close to its accumulation limit, call the ECC.
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.).
Fill in the hazard type.
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Toxic - Poisonous Examples: waste oil, paint, and kerosene Ignitable - Easily catches fire
Examples: gasoline and paint thinner
Corrosive - Easily corrodes materials or human tissue Example: battery acid
Reactive - Violent change may result in heat or explosion when they come into contact
with other materials.
Examples: chlorine bleach, certain peroxides, and ammonia.
For Small Quantity Generators (SQGs), fill in the date when the first 55-gallon drum is full
and/or moved to the centralized hazardous waste storage area. For a SQG, hazardous waste must
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be shipped off-site within 180 calendar days of this date. Only enter a date on the hazardous
waste label if your facility is a SQG of hazardous waste (a date is not required for VSQG
facilities). Your ECC can provide your generator status and assist with management of
hazardous waste.
Hazardous Waste Labels. Any container used for temporary storage or transporting of
hazardous waste must be properly labeled. 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 (i.e. the date the container is full and moved to the
centralized hazardous waste storage area). Temporary labels such as tape can be used if these
labels are not readily available. Temporary labels must include state “Hazardous Waste” as well
as the name and the hazard(s) associated with the waste.
What types of inspections are required?
Weekly Hazardous Waste Inspections:
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Conducted by designated facility personnel.
Fill out the Weekly Inspection Form.
Keep the form on file for review by the ECC.
Correct any problems that can be handled immediately.
Regular Facility Inspections:
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Conducted by the ECC or District representative.
Facility staff may be asked to correct identified issues.
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MassDOT Facility Environmental Handbook
How do you get waste oil removed from your facility?
The ECC monitors waste oil generation each inspection, but contact your ECC if you are
accumulating more waste than usual.
If your facility is a VSQG:
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The waste oil may be self-transported (see self-transport requirements below), or
The ECC, DME, or facility supervisor will coordinate regularly scheduled waste oil pick-ups
If your facility is a SQG or LQG:
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The ECC, DME, or facility supervisor will coordinate regularly scheduled waste oil pick-ups.
How do you get all other hazardous waste (not waste oil) removed from your
facility?
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Regardless of your generator status, contact the ECC to coordinate the removal of all other
hazardous waste.
What is required for self-transport of waste oil?
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A maximum of 55 gallons of waste oil can be transported at a time in any size container.
Contact receiving facility to confirm that the waste being sent to them will not result in
exceeding their accumulation limits.
Make sure that the container is closed, labeled as Hazardous Waste, and secured to the truck.
Bring a shovel and absorbent.
Bring a copy of the VSQG Generator Registration number.
Bring the Two-part Self-transport Receipt (SOP 03).
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.
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MassDOT Facility Environmental Handbook
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.
Refer to the Emergency Response Spill Plan (Appendix B and SOP 03).
Use the Spill Prevention Control and Countermeasure Plan (SPCC Plan) if applicable.
Call the facility’s Primary Emergency Coordinator.
Use the Call Down Sheet and keep calling until you reach someone who can respond.
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 MassDOT facilities.
What spills need to be reported?
Large Spills (typically 10 gallons or more) always require reporting
to your supervisor and the ECC.
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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.
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A small spill (typically less than 10 gallons) is a spill that may be 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.
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, the materials 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 when squeezed or rung out, the
materials 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 granular absorbents (clay pellets) distributed by the stockroom and/or spill pads
and socks supplied by the ECC. Sand or soil should only be used to contain spills in an
emergency, when sufficient absorbent material is not available.
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MassDOT Facility Environmental Handbook
2.0 Universal Waste
This section provides information on managing Universal Waste, including identification,
storing, labeling, and proper offsite disposal.
SOP References (see Appendix A)
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SOP 05 Used Vehicle Batteries
SOP 07 Universal Wastes
What is Universal Waste?
Universal wastes are wastes that EPA and/or the MassDEP have determined need special
management. Universal wastes that may be found at a MassDOT facilities include:
Batteries
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Rechargeable batteries containing nickel cadmium (NiCd), nickel metal hydride (NiMH)
lithium ion batteries, and button batteries containing mercury
Mercury-containing batteries that have been banned from domestic sale.
Used consumer products containing rechargeable batteries that can not be easily removed.
Pesticides
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Pesticides that are no longer allowed by regulation or have been recalled and are not intended
for use by MassDOT.
Mercury Containing Devices in Good Condition
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Thermostats
Switches
Thermometers
Fluorescent light bulbs
High Intensity Discharge (HID) lights
How do you temporarily store universal wastes?
Take precautions to ensure that universal waste items, such as fluorescent bulbs and
thermometers, remain in good condition and unbroken while it is being stored. If breakage
occurs, the universal waste must be considered a hazardous waste. See Section 1.0 of this
handbook for information on managing hazardous waste.
For Universal Waste Batteries
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Store batteries indoors, in a container suitable for containing leaks.
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MassDOT Facility Environmental Handbook
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Label as “Universal Waste – Batteries” and the start date for accumulation. For universal
wastes, the accumulation start date is the date that the first battery is placed into the
container.
For lithium batteries, tape the leads on the battery to prevent a fire hazard.
For Universal Waste Mercury-Containing Devices (fluorescent bulbs and thermostats)
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Store devices indoors in a container suitable for containing possible breakage.
Label container with “Universal Waste – Mercury Containing Lamps” and the start date for
accumulation. For universal wastes, the accumulation start date is the date that the first lamp
is put into the container.
Label all other universal waste mercury-containing devices with “Universal Waste-Mercury
Containing Devices” and the start date for accumulation.
For Universal Waste Pesticides
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Place the original container in a secondary closed container suitable for containing possible
leakage.
Label the secondary container as “Universal Waste – Pesticide” and the start date for
accumulation. For universal wastes, the accumulation start date is the date that the first
pesticide container is placed into the secondary container.
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 and can result in impairment of 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.
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Use the absorbent Spill Kit to contain the spill as best you can.
DO NOT RISK YOUR SAFETY.
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 ECC to arrange for Universal Waste disposal.
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MassDOT Facility Environmental Handbook
3.0 Hazardous Materials
This section provides information on Hazardous Materials that are typically used at MassDOT
Facilities, including information on identification, storing, labeling, Material Safety Data Sheets
(MSDS), and disposal of old materials.
SOP References (see Appendix A)
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SOP 02 MSDS Management
SOP 06 Handling of Compressed Gas Cylinders
SOP 08 Handling of Sand and Deicing Chemicals
SOP 11 Hazardous Materials Management
What are hazardous materials?
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Solid, liquid, gaseous substances and product containers that are potentially harmful to
human health and the environment.
Some common hazardous materials typically found at your facility:
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gasoline
diesel fuel
motor oil
lubricants
heating oil
propane
paints
sand (silica)
paint thinners
aerosol spray
degreasing solvents
How do you store hazardous materials?
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Label all hazardous materials.
Store in an authorized area.
Store hazardous materials in a neat and organized manner. Where possible, centralize your
hazardous material storage location for safety and convenience.
Outdoor salt piles and salt charged sand piles must be labeled, bermed, and covered when not
in use.
Outdoor sand piles must be labeled and bermed.
Keep all hazardous material containers closed when not being used.
Store flammable materials inside a flammables storage cabinet.
Keep compressed gas cylinder labeled, capped and stored in a secured cylinder storage rack
or similar device.
When not in use, separate oxygen and acetylene cylinders by 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 onehalf hour.
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MassDOT Facility Environmental Handbook
Hazardous materials storage
Storage Sheds are used to store
bulk quantities of hazardous
materials at facilities.
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 of 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:
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Identifies the hazards of the material using four hazard classes — Health, Fire, Reactivity, Specific.
If a container greater than 5-gallons does not have an NFPA label, call your ECC or look
in section 5 on the MSDS for the NFPA hazard ratings of the material and place the
completed NFPA label on the container.
Provides 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.
What is a Material Safety Data Sheet (MSDS)?
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?
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Most facilities have 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 be easy accessible to all employees. MSDSs are also available online.
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 or in an electronic
file.
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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 outof-specification, refer to procedures for managing hazardous wastes found in Section 1.0 and
follow the quick instruction below:
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Call the ECC or DME.
Store these materials in the Hazardous Waste Accumulation Area until they are removed
from the facility (make sure that these materials are labeled).
Note: Never dispose of hazardous materials in the trash or dumpster. Never hide hazardous
materials.
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.
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Label it “empty.”
Keep it protected from the elements — If at all possible, do not store empty 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.
What do you do with the used clean-up materials?
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. Refer
to Section 1.0 of this handbook for more information on spill response.
Note: The Call Down Sheet is a list of Emergency contacts that should be posted near the
telephone at all MassDOT facilities.
12 MassDOT Facility Environmental Handbook
4.0 Asbestos Containing Materials
This section provides information on Asbestos Containing Materials.
SOP References (see Appendix A)
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SOP 29 Management of Asbestos Containing Materials
What materials may contain asbestos?
Asbestos Containing Materials (ACM) are materials that contain at least one percent by weight
of asbestos. ACMs that may be found at a MassDOT facility include:
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Plaster
Floor tile and mastics
Insulation
Roof tiles/shingles
Other building materials
Floor tile and
mastic may
contain asbestos.
How do I know if ACMs are present at my facility?
MassDOT conducts an annual survey of 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.
13 MassDOT Facility Environmental Handbook
Note: The locations of known
ACM and potential ACM are
identified in the District Asbestos
Survey report.
Generally, ACM 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, as 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 survey and any asbestos removal or material repair that may be required.
A BWP AQ 06 form shall be sent to the MassDEP 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 MassDEP at least 10 days
prior to beginning the project.
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 you may contact the ECC or refer to the
MassDOT Asbestos Operations and Maintenance Program Guide.
14 MassDOT Facility Environmental Handbook
5.0 Solid Waste
This section provides information on Solid Waste Management at MassDOT 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 MassDOT
facilities is for internal use only. Contractors, other state agencies, and the general public are not
permitted to dispose of their solid waste at MassDOT facilities.
SOP References (see Appendix A)
SOP 12 Solid Waste Management
SOP 32 Contractor Use of Facilities
What is solid waste?
Solid wastes are unusable, unwanted, or discarded solid, liquid, or contained gaseous material
which has come into the possession of MassDOT through Highway Operations such as roadside
pick-ups, roadside maintenance, street sweeping and catch basin cleaning. Facility trash is also a
solid waste.
Solid waste types and storage requirements
Category
Asphalt, Brick, and
Concrete (ABC)
Construction &
Demolition (C&D)
Wood Waste
Tires
Appliances / White
Goods
Street Sweeping Debris
Metal
Treated Timbers
Trash
Catch Basin Sediment
Televisions/Computer
Monitors
Waste Types
asphalt grindings, bricks,
concrete
lumber, building materials,
plastics, sweeper brooms, bed
liners
trees, stumps, wood chips,
branches
used whole tires (with or
without rims)
refrigerators, water heaters,
washers, dryers
collections from street
sweeping operations
scrap metal, scrap electronics
not including cathode ray tubes
(TV’s computer monitors)
wood treated with a
preservative (i.e., creosote
pressure treated lumber)
litter, garbage, bagged roadway
trash
sand, silt, leaf and trash
material removed during catch
basin / drainage structure
cleaning and maintenance
electronic equipment containing
cathode ray tubes
15 Temporary Storage Requirements
segregate and store in designated
accumulation area
segregate and store in designated
accumulation area
segregate and store in designated
accumulation area
segregate and store in designated
accumulation area
segregate and store in designated
accumulation area
when possible, berm and temporarily store
on pavement (see Policy BWP-94-092
within SOP 12)
segregate and store in designated
accumulation area
segregate and store in designated
accumulation area
dumpster
segregate and store in designated
accumulation area
segregate and store to avoid breakage
MassDOT Facility Environmental Handbook
What is a designated accumulation area?
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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.
ƒ Each accumulation area must contain only one type of solid waste.
ƒ Accumulation areas serve to keep solid wastes consolidated, to avoid similar types of
waste from being scattered throughout the facility.
ƒ Consult with your Supervisor, DME, or ECC for emergency storage instructions if an
accumulation area is not available at your location.
Designated Solid Waste
Accumulation Area. Solid waste
must be segregated and stored in
designated areas.
How do you remove solid waste from your facility?
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Removals are coordinated by the DME, or designated District Personnel, who will coordinate
with the ECC.
It may be necessary to transfer some wastes to a designated storage facility in your district
for proper storage and removal.
Refer to your Facility Plan for the categories that your facility is designated to accumulate.
Is Burning an Approved Option for Disposal of Wood Waste at MassDOT
Facilities?
No. Burning of any wood waste is strictly prohibited at MassDOT Facilities. Whenever
practical, brush and forestry debris should be chipped and recycled.
What do you do with an empty drum or container that was found during roadway
cleaning activities?
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Empty metal drums or other empty metal containers should be crushed and placed in the
scrap metal pile.
Empty plastic drums or plastic containers should be crushed and placed in the construction
and demolition debris pile.
What do you do with an empty compressed gas cylinder?
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Refer to the Standard Operating Procedure.
Label it “empty.”
16 MassDOT Facility Environmental Handbook
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Call the distributor to pick up cylinder – do not self-transport gas cylinders of any type
without securing them from movement.
Gas grill type propane containers found during roadway cleaning activities should be stored
outside at designated facilities for eventual offsite disposal. Contact your ECC to arrange
disposal of all gas cylinders not provided by MassDOT vendors.
What do you do with street sweepings?
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Refer to the Standard Operating Procedure and MassDEP Policy #MWP-94-092.
Street sweepings can only be temporarily stockpiled at designated facilities.
Do not store within the 100-foot Buffer Zone of a Wetland or 200-foot Riverfront Area.
17 MassDOT Facility Environmental Handbook
6.0
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.
SOP References (see Appendix A)
SOP 10 Disposal of Animal Carcasses
SOP 25 Roadside Unknown Waste Handling
SOP 33 Beaver Dam Control
How do you handle animal carcasses found on the roadway?
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MassDOT 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?
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MassDOT 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.
Animal carcasses retrieved by MassDOT personnel may be buried on state property within
the state Highway layout/Rights of Way, preferably within the vicinity of carcass discovery
Animal carcasses may be placed in such a way to allow for natural decomposition as long as
the location will not draw scavenger animals into the roadway, produce a public nuisance, or
a public health hazard
Animal carcasses maybe incinerated if a local incinerator is available. A list of licensed
incinerators is available from the MassDEP 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 and the owner contacted for possible
retrieval.
Special condition: Deer carcasses may be kept by the driver that struck the animal. Within
24 hours, the death must be reported to the DFW at 1-800-632-8075.
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.
18 MassDOT Facility Environmental Handbook
What is Medical Waste?
Medical Waste is any material of a biological nature such as:
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Blood
Body Fluids
Sharps
Body Parts
Red Bag Waste
What do you do with medical waste or unknowns found on the roadside?
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All efforts will be made by MassDOT 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 MassDOT Safety office.
The Safety Inspector will examine the waste and coordinate disposal with the ECC if
necessary. If the waste cannot be identified by a visual inspection, or the inspector deems the
material unsafe, the ECC or Safety Inspector will coordinate the removal of the material by a
waste removal contractor.
What do you do when a beaver dam is resulting in flooding of a MassDOT facility,
roadway or other threat to public health or safety?
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Contact the DEE to arrange for an emergency permit from the local Board of Health to
remove or by-pass a dam from beaver or muskrat-related activity that could present a threat
to public health and safety.
What do you do when insufficient drainage is resulting in flooding of a MassDOT
facility or threat to public health or safety?
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Identify the cause of the flooding event and assess mitigation.
Contact the DME and DEE as soon as possible.
Should mitigation of the flooded area require pumping, the recovered water should first be
pumped to downstream stormwater management structures.
If no downstream stormwater structures are available, approvals from applicable authorities
will likely be required for discharge to surface water or private land (i.e. MassDEP, local
Conservation Commission, private landowners, etc.)
19 MassDOT Facility Environmental Handbook
7.0 Tanks
This section provides information on aboveground and underground storage tanks and describes
the basic operating systems for storage tanks and tank inspection requirements.
SOP References (see Appendix A)
SOP 28 Inspection/Repair of Stage I/II VRS
What types of tanks are maintained at facilities?
Aboveground and underground tanks present at your facility are shown on the Facility. Materials
typically stored in tanks at MassDOT facilities include:
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Fuel
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Gasoline
Diesel
Kerosene
Heating Oil
Liquid Propane
De-icing Materials
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Calcium Chloride Solution
Magnesium Chloride solution
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 designated District personnel.
20 MassDOT Facility Environmental Handbook
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:
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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:
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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?
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Aboveground Storage Tank Inspections
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Conducted by facility personnel
Visual inspection for leaks or corrosion
Monitor how much is in the tank
Report needed repairs to the District Maintenance Engineer or their designee
Weekly Stage I and II Vapor Equipment inspections
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Conducted by designated facility personnel
Ensure equipment is functioning properly
Fill out weekly inspection form
Report needed repairs to the District Maintenance Engineer or their designee
21 MassDOT Facility Environmental Handbook
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All underground storage tanks must have daily electronic inventory checks that will be
monitored by the District and/or District Maintenance Engineer or their designee. If the
electronic monitoring system (Veeder Root or similar) is inoperable, designated facility
personnel may be required to:
ƒ Conduct daily manual inventory stick test;
ƒ Conduct daily manual water level test;
ƒ Submit records to the District Maintenance Engineer or their designee.
What Types Of Records Do You Need To Keep?
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Weekly Stage I and II inspection forms
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Daily electronic or manual underground tank inventory records
Where can I find more information on storage tank issues?
For more information on tanks refer to Appendix C, Storage Tank Monitoring and Management
Addendum, and training materials for Inventory Control for Underground Storage Tanks
22 MassDOT Facility Environmental Handbook
8.0
Water Quality
This section provides information on how MassDOT 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. Further information on wastewater and stormwater management
can be found in the facility’s wastewater permit, and the Stormwater Pollution Prevention Plan
(SWPPP) Manual.
SOP References (see Appendix A)
SOP 16 Groundwater Monitoring Well Maintenance
SOP 17 Maintenance of Subsurface Sewage Systems
SOP 18 Maintenance of Waste Water Holding Tanks
SOP 19 Maintenance of Catchbasins
SOP 20 Outdoor Equipment Storage and Management
SOP 22 Vehicle Washing
SOP 27 Maintenance of Oil/Water Separators
What are the different types of wastewater generated at MassDOT facilities?
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Sanitary wastewater generated from restrooms.
Stormwater generated from precipitation, including snow melt.
Industrial wastewater generated by vehicle rinsing and washing.
What are the requirements for the discharge of wastewater at MassDOT
Facilities?
Sanitary wastewater from bathrooms is discharged to either:
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Public sanitary sewer system.
An onsite septic system or septic holding tank.
Industrial wastewater from vehicle washing is discharged into floor drains and to:
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A holding tank, or
An oil water separator (OWS) 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 ECC can provide guidance on whether there are permit conditions
and/or wastewater discharge restrictions that apply to your facility).
Stormwater is discharged to either:
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To a stormwater catchbasin or as sheet flow runoff.
Refer to Facility Plans for wastewater structures at your facility.
23 MassDOT Facility Environmental Handbook
What inspections are required for oil/water separators?
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Self-test the alarm system on a regular basis, if so equipped.
Report any malfunctions (floordrain backups) to your supervisor.
If the OWS is equipped with an alarm, notify the ECC if a “High Oil” or Pump Out Oil”
condition is found.
Specific OWS permits may dictate other inspection requirements.
What inspections are required for holding tanks?
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The tank must be gauged on a regular basis (some holding tanks must be gauged weekly,
check the permit requirement or MassDEP guidance).
Notify the ECC or the District Maintenance Engineer or their designee when the holding tank
is 75% full.
Report any malfunctions to your supervisor or the ECC.
What are the other requirements for holding tanks?
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Label tank as “Sanitary Wastewater” or “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.
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Notify your supervisor of any system malfunctions.
Your DME or their designee will arrange to have the system inspected.
Signs of a malfunctioning system include:
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sewage back-ups
sewage surfacing in drains/and or leach fields
slow draining toilets
24 MassDOT Facility Environmental Handbook
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strong sewage odors
excessive green growth over the leach field
What can affect water quality?
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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?
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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.
What are the requirements for storm water catchbasins?
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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?
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Immediately contain the spill, if possible.
Refer to the Emergency Response Spill Plan (Appendix B).
25 MassDOT Facility Environmental Handbook
What does vehicle washing include?
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Power washing/Pressure washing (no soap, no heat).
Any type of physical agitation (e.g., use of sponge, brush).
Steam cleaning or rinsing with heated water.
Washing using soap or detergent.
Where can you wash vehicles and equipment?
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All vehicle and equipment washing must be conducted at a designated facility.
Refer to the Facility Plan at the front of this Handbook to determine if your facility is a
designated washing facility.
Vehicle washing must be conducted indoors at designated facilities.
Note: Contractors are not permitted to wash or rinse their vehicles at MassDOT facilities.
What is a designated vehicle washing facility?
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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 Plan or ask your ECC to determine if your facility is designated for
vehicle washing.
What do you do if your facility is not designated for vehicle washing?
Take your vehicle to the closest designated facility within your District.
Where can you rinse vehicles and equipment?
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Vehicles can be rinsed outdoors.
Vehicles or equipment used for hauling cold patch asphalt or hot asphalt 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 Stormwater Pollution
Prevention Plan (SWPPP) and Manual.
26 MassDOT Facility Environmental Handbook
9.0 Wetlands
This section provides information on wetlands and how they are protected at MassDOT
Facilities.
SOP References (see Appendix A)
SOP 15 Wetland Resource Protection
What are wetlands?
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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 may include
manmade drainage ditches and detention ponds.
Facilities adjacent to an Area of Critical Environmental Concern (ACEC) must be
maintained more vigorously, even in upland areas, with special consideration regarding
drainage outlets.
Examples of wetlands
Wetlands are present on many MassDOT facilities.
Wetlands. Wetlands are
designated as wetlands because of
the presence of water, soils and the
types of vegetation that grow
within them.
What is a buffer zone?
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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.
The purpose of the Buffer Zone is to provide additional protection for the wetlands.
27 MassDOT Facility Environmental Handbook
Buffer Zone. The Buffer
Zone is 100 feet from a
wetland boundary.
What is a riverfront area?
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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.
The Riverfront Area is considered a RESOURCE AREA. There is no buffer zone associated
with the Riverfront Area. The first 100ft. adjacent to the waterway is the Inner Riparian Zone
and NO work or material storage should take place here. The outer 100ft. is the Outer
Riparian Zone and, although still a resource area, non-erodible materials may be stored there
if necessary
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?
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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.
28 MassDOT Facility Environmental Handbook
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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?
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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:
ƒ Store in the outer limits of the buffer zone (as far away from the wetlands as possible).
ƒ Consolidate and store neatly.
ƒ Make sure sand piles are bermed and salt piles are bermed and covered.
ƒ Make sure sand and salt sheds are closed when not in use.
ƒ You can perform normal maintenance activities, but keep it neat.
ƒ Transfer equipment to another facility, if possible.
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 Stormwater Pollution Prevention Plan
(SWPPP) and Manual.
29 MassDOT Facility Environmental Handbook
10.0 Record Keeping
This section summarizes record keeping requirements for environmental management at
MassDOT facilities. For more information on what records need to be maintained by your
facility, refer to the preceding sections of this handbook.
What facility documentation needs to be maintained?
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Weekly Hazardous Waste Inspection Checklist, if applicable (onsite)
Weekly Stage I and II Vapor Recovery Equipment Inspections, if applicable (onsite)
MSDSs (onsite, otherwise accessible i.e. online)
Self-transport receipts for VSQGs that self-transport their wastes
Hazardous waste manifests for LQG, SQGs and VSQGs (that do not self-transport all waste)
Tank permits (Fire Department permits) which must be posted
Underground Storage Tank Fuel Inventory records
Call Down List (Make sure the list is accurate and up-to-date)
Generator registration number (VSQG, SQG, LQG)
Asbestos Containing Material postings
Renovation/demolition Asbestos Survey Request Forms
Active Wetland Permits
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
Training records for Environmental Awareness, SPCC training, and SWPPP training.
Where are these records kept, and for how long?
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Weekly Hazardous Waste Inspection Checklist – on file at facility or sent to ECC weekly
Weekly Stage I and II Vapor Recovery Equipment Inspection Forms – on file at facility or
sent to designated district personnel
Underground Storage Tank Fuel Inventory Records – District Maintenance Engineers office
for one year
MSDSs – maintained at the facility or easily accessible at all times
Hazardous waste shipping manifests – maintained at the district headquarters or at the facility
Hazardous waste 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 and in electronic file at
District Headquarters
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 and/or the ECC.
Construction & Installation records for Industrial Wastewater Holding Tanks and operator
records for shipments of wastewater – maintained by the District Structures and Facilities
Engineer or the ECC.
Training records – maintained at the district headquarters
30 MassDOT Facility Environmental Handbook
11.0 Inspections
Facility personnel should expect inspections to occur on a regular basis. These inspections may
be announced or unannounced.
What inspections should you expect?
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EPA inspections
MassDEP inspections
MassDOT Self Audits
MassDOT Regular Inspections
What will the inspector want to look at?
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Hazardous waste accumulation areas
Hazardous material storage areas
Solid waste accumulation areas
Tank monitoring records and permits
Hazardous waste self-transport receipts or manifests
What can you do to be prepared for an inspection?
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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, other District personnel, and all the topics in this
handbook that relate to your particular facility. Review the information presented on the
facility plan.
Discuss potential environmental compliance issues with the ECC
What will the inspector be interested in?
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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 MassDEP or EPA inspector arrives at the facility?
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Be polite
Things to politely ask the Inspector:
ƒ The Inspector’s name
ƒ What agency they represent
ƒ What they would like to see as part of the inspection
ƒ What files or records they will need to see as part of the inspection
31 MassDOT Facility Environmental Handbook
Whom should you contact when a MassDEP or EPA inspector arrives?
MassDOT 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.
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Your Immediate Supervisor
Your DME
Your ECC
How should you conduct yourself during the inspection?
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Be honest.
ƒ Provide brief, but honest answers. Do not mislead the Inspector
ƒ If you do not know the answer to a question, say so. Do not guess or give your opinion.
ƒ Present files and information upon request.
Be observant.
ƒ Take notes during the inspection.
ƒ Document comments made by the Inspector.
ƒ Always stay with the Inspector during the inspection.
ƒ Request a post-inspection discussion with the Inspector.
ƒ Provide a summary of the inspection to your supervisor.
Be responsive.
ƒ Address simple issues raised by the Inspector, such as labeling and general housekeeping.
ƒ Present files, permits, and manuals requested by the Inspector
ƒ Do not offer any information without being asked
What should be done at the conclusion of the inspection?
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Request a copy of the Inspector’s notes and field report.
Provide the Inspector’s notes and your notes to the DME or ECC.
32 Appendix A
Standard Operating Procedures
STANDARD OPERATING PROCEDURES (SOP) INDEX:
SOP 01 Environmental Compliance SOPS
SOP 02 Materials Safety Data Sheet Management
SOP 03 Hazardous Waste Management
SOP 05 Used Vehicle Battery Disposal
SOP 06 Handling, Storage and Disposal of Compressed Gas Cylinders
SOP 07 Universal Waste Management
SOP 08 Management of Sand and Deicing Chemicals
SOP 10 Disposal of Animal Carcasses
SOP 11 Hazardous Materials Management
SOP 12 Temporary Storage of Solid Waste
SOP 15 Wetland Resource Protection
SOP 16 Groundwater Monitoring Well Maintenance
SOP 17 Maintenance of Subsurface Sewage Disposal Systems
SOP 18 Maintenance of Wastewater Holding Tanks
SOP 19 Inspection and Maintenance of Stormwater Catch Basins
SOP 20 Outdoor Operation/Maintenance Equipment Storage
SOP 22 Vehicle Washing
SOP 25 Roadside Unknown Waste Handling
SOP 27 Inspection and Maintenance of Oil/Water Separators
SOP 28 Inspection and Repair of Stage I and Stage II Recovery Systems
SOP 29 Management of Asbestos Containing Materials
SOP 31 Performing Facility Environmental Compliance Inspections
SOP 32 Contractors’ Use of Facilities
SOP 33 Beaver Dam Control
ENV-01-01-1-000
ENV-01-02-1-000
ENV-01-03-1-000
ENV-01-05-1-000
ENV-01-06-1-000
ENV-01-07-1-000
ENV-01-08-1-000
ENV-01-10-1-000
ENV-01-11-1-000
ENV-01-12-1-000
ENV-01-15-1-000
ENV-01-16-1-000
ENV-01-17-1-000
ENV-01-18-1-000
ENV-01-19-1-000
ENV-01-20-1-000
ENV-01-22-1-000
ENV-01-25-1-000
ENV-01-27-1-000
ENV-01-28-1-000
ENV-01-29-1-000
ENV-01-31-1-000
ENV-01-32-1-000
ENV-01-33-1-000
Appendix B
Emergency Response Spill Plan (Facility Spill Plan)
Appendix B. Emergency Response Spill Plan (Generic) Table of Contents 1. Emergency Coordinator
2. Emergency Contact List
3. Available Spill Equipment and Resources
3.1 Description of Emergency Resources at MassDOT Facilities
3.2 Site-Specific Emergency Equipment List 4. Emergency Prevention Systems
4.1 Prevention of Fire, Explosion, or Chemical Reaction
4.2 Hazardous Material/Hazardous Waste Loading/Unloading Safety Procedures 4.3 Storm Water Pollution Prevention and Drainage Controls 4.4 Power Outage or Equipment failure
4.5 Protection of the Public and the Environment during Emergencies
4.6 Personnel Exposure Protection 5.0 Emergency Evacuation Procedures
Background
This Emergency Response Spill Plan has been prepared to address potential spills of
hazardous waste or hazardous materials at MassDOT facilities. It is based upon the RCRA
Hazardous Waste Generator Emergency Response Plan that is presented within SOP 03
(Hazardous Waste Management at MassDOT Facilities) but has been revised to address
possible spills related to hazardous materials storage and usage.
1. Emergency Coordinator
Each MassDOT facility which generates or accumulates hazardous wastes and/or stores
or uses hazardous materials that could be released to the environment shall at all times
have an Emergency Coordinator either on the facility premises, or, to the extent the
facility's operations make this option appropriate, on call and available to respond to an
emergency by reaching the facility within one hour. The Emergency Coordinator shall
have the responsibility for coordinating all emergency response measures. This
Emergency Coordinator shall be thoroughly familiar with all aspects of the facility's
contingency plan, all operations and activities at the facility, the location and
characteristics of waste/materials handled, the location of all records within the facility,
and the facility layout. The Emergency Coordinator shall have access to all areas of the
facility. In addition, this individual shall have the authority utilize available resources to
carry out the contingency plan.
The Emergency Coordinator for MassDOT facilities shall be the District Maintenance
Engineer (DME) for the district in which the facility is located. If the DME is
unavailable, the alternates listed on the Emergency Call Down Sheet by order of ranking
shall serve as the Emergency Coordinator.
2. Emergency Contact List
In the event of a hazardous waste/hazardous materials emergency, personnel shall contact
the Emergency Coordinator immediately, or, in the case of fire, explosion, or other lifethreatening emergency, as soon as possible after notifying local fire, police, ambulance
and/or other Emergency “First-Responder” groups.
Notifying personnel should continue calling each person on the Emergency Call Down
Sheet until the Emergency Coordinator or an alternate is contacted. Report to the
Emergency Coordinator the location and nature of the incident, type and estimated
volume of materials involved, environmental impacts, and the identity of any other
emergency services contacted. Follow the instructions of the Emergency Coordinator,
and report back any new developments on a frequent basis.
3. Available Spill Equipment and Resources
3.1 Description of Emergency Resources at MassDOT Facilities
MassDOT facilities which generate/accumulate hazardous wastes and/or store/use
hazardous materials have spill kits on premises, in close proximity to but outside
the respective accumulation/storage areas. The spill kits typically contain an
assortment of absorbent booms and pads, plastic bags, personal protective
clothing (tyvek suits, gloves) for use in containing a small spill of hazardous
waste material. Supplies of granular absorbents, drain blocker pads, neoprene
rubber dikes, brooms, shovels, waste accumulation drums, and other spill
containment and cleanup equipment are also available at each facility, or can
otherwise be mobilized from a nearby facility.
3.2 Site-Specific Emergency Equipment
Emergency/spill response equipment that is available to facility personnel may be
used in the event of a minor hazardous waste/hazardous materials emergency
incident to contain/control spills. Major spill events warrant outside assistance
(fire department, spill response contractor, etc).
4. Emergency Prevention Systems
4.1 Prevention of Fire, Explosion, or Chemical Reaction
MassDOT maintenance facilities typically may generate and accumulate virgin or
waste lubricating and hydraulic oils, diesel fuel, gasoline, and paint related
materials, all of which are combustible or flammable. Hazardous wastes are
accumulated either inside the facility maintenance garage on spill containment
pallets (generally at VSQG facilities) in a designated location and separate from
other materials, or in an outdoor fire-rated hazardous waste shed with secondary
containment and ventilation. Hazardous materials are stored in designated areas
including flammable cabinets, designated hazardous materials drum storage areas
and aboveground/underground tanks.
To mitigate the potential for fire or explosion, MassDOT personnel must keep all
waste and virgin product containers tightly closed except when adding/removing
material to a container, observe smoking bans, and ensure ignition sources such as
welding torches are shut off when working proximate to hazardous
waste/materials. Non-hazardous oily rags and other absorbents are stored away
from waste accumulation areas, in fire-resistant safety canisters which are
emptied daily, to prevent spontaneous combustion.
MassDOT facilities seldom if ever generate other hazardous waste materials that
may be incompatible with the above routinely generated wastes. When special
circumstance arise where a non-compatible waste is generated that may react with
other waste materials (i.e. battery acid, alkaline materials, chlorine bleach, etc.),
the material is moved to an isolated hazardous waste storage shed at the facility if
available, self-transported to another facility for isolated storage subject to waste
generator status, or immediately collected for transport to a TSD facility by a
licensed waste hauler.
Hazardous materials shall be stored within areas where containment measures are
employed, and away from floor or storm drains, to the extent practical.
Flammable materials shall be stored in flammable storage cabinets.
4.2 Hazardous Waste/Hazardous Materials Loading/Unloading Safety
Procedures
During transfer of hazardous waste/hazardous materials drums and other
containers from garages to storage sheds, or from sheds to a TSD transport
vehicle, all MassDOT and contractor personnel shall use proper drum lifting tools
such as overhead drum clamps, drum lifting forks, drum dollies or other devices
designed specifically for such purpose. Persons involved in container transfers
should be outfitted with proper work attire including steel toe boots, work gloves,
hard hat and eye protection. A spill kit or adequate supply of absorbent or
containment materials should be near by in the event of a spill during transfer of
containers.
4.3 Storm Water Pollution Prevention and Drainage Controls
To prevent contamination of storm water from hazardous wastes/hazardous
materials generated at MassDOT facilities, routine vehicle maintenance and
repairs are performed indoors whenever possible. When outdoor vehicle or
equipment repairs are required, spill containment pads, buckets or other means to
collect spillage must be employed.
Hazardous waste containers are stored indoors and provided secondary
containment in the event of a leaking container. Transfer of full hazardous waste
containers from satellite accumulation areas to outdoor sheds, or from
accumulation areas or sheds to a transport vehicle should only be performed in
dry weather whenever possible.
Hazardous waste accumulation and hazardous materials storage sheds will be
located as far from drainage structures or nearby receiving waters or wetlands as
possible. Small Quantity Generator facilities which handle hazardous waste and
which are not equipped with storm drains fitted with oil/grease traps will have
readily available for deployment, drain-block pads made from Neoprene, latex, or
other suitable material to seal off storm drains in the event of spill while
transferring hazardous waste outdoors to or from accumulation areas.
4.4 Power Outage or Equipment failure
Power outages would have no significant affect on routine MassDOT hazardous
waste operations. Hazardous wastes at MassDOT facilities are not managed or
processed via any mechanical equipment, therefore equipment failure has no
bearing on MassDOT hazardous waste management. Power outages would not be
expected to impact and/or cause releases of hazardous materials management.
4.5 Protection of the Public and the Environment during Emergencies
MassDOT facilities are gated, and restricted from access by the general public.
Hazardous wastes are stored at least 50 feet from the adjacent property boundaries
as per state and federal requirements. Due to the limited volume and types of
hazardous wastes generated/accumulated and hazardous materials stored at
MassDOT facilities, a spill emergency at the facility is unlikely to pose a threat to
the general public.
As indicated elsewhere in this plan, adequate spill containment materials,
secondary containment, and fire/explosion-proof accumulation sheds are provided
for the protection of the environment and public health and welfare.
4.6 Personnel Exposure Protection
Persons engaged in Hazardous Waste operations, whether routine or emergency,
shall wear appropriate Personal Protective Equipment suited to the nature of the
work being performed and the hazardous waste being generated or handled. This
includes work coveralls, work gloves, eye protection and where appropriate,
protective rubber gloves for equipment repair activities. Activities involving
transfers of hazardous wastes to or from containers, or spill cleanup shall also
require the use of heavy duty rubber gloves or work gloves with surgical latex
gloves as liners; coveralls, tyvek, or other splash protection, eye protection (full
face protection if skin irritant).
In the event of a fire involving hazardous wastes, or spills of highly flammable
wastes/materials such as gasoline, MassDOT personnel should evacuate the area
and notify the Fire Department, the Emergency Coordinator and other necessary
emergency services immediately.
5.0 Emergency Evacuation Procedures
Most MassDOT facilities engaged in hazardous waste/materials activities are small to
large, open vehicle garages with few personnel. If an emergency occurs that would
require evacuation of the buildings or facility, persons identifying the emergency should
alert others in the garage by yelling an appropriate warning (i.e. “Fire”) contact
emergency services, and then if safe to do so, attempt to determine if anyone else is in the
building that may not have heard the alert, and evacuate as required. A plan of the
facility, showing all exits shall be posted at various highly visible locations throughout
the facility.
A hazardous waste/materials emergency at a maintenance facility located at the District
Administrative Headquarters may result in evacuation of the administration building or
the entire property. In such cases, the general emergency evacuation plan for the building
should be implemented.
Appendix C
Storage Tank Monitoring and Management Addendum
Appendix C. Storage Tank Monitoring and Management Addendum
In the event of a petroleum release, tank failure or leak detection equipment alarm condition,
immediately notify the MassDOT by using the appropriate District Call Down List procedures as
outlined in Appendix B or if not available call Highway Operations Center (HOC) (800) 227­
0608 or #321 on a mobile phone.
General
Storage tanks are used at MassDOT facilities for the storage of petroleum products such as
gasoline, diesel fuel, kerosene, heating oil and other products such as calcium chloride and liquid
propane. This section of the manual is specifically geared toward the storage of virgin petroleum
products in above and below ground tanks. For information relating to the storage of products
such as waste oil and/or hazardous wastes in containers consult Section 1.0, Hazardous Waste, of
the Facility Environmental Handbook.
The operation and maintenance of storage tank systems are regulated by both federal and state
laws. An overview of the operation and maintenance requirements for underground and
aboveground storage tanks is provided below. Included are outlines of the requirements for:
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Permitting,
Aboveground Tanks,
Spill Prevention Control and Countermeasure (SPCC) requirements,
Underground Tanks,
Alarm conditions,
Petroleum inventory reconciliation,
Stage II Vapor Recovery,
Fire Suppression Systems, and
Record retention.
The following is a list of the most common fuels stored in tanks and their corresponding fill port
color codes.
Fuel List
Color Codes
Unleaded Regular Gasoline
Diesel
#2 Heating Fuel
Kerosene
White with Black Cross
Yellow
Green
Brown
The following are additional identification markings of tanks and access ports.
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Vapor Recovery (Stage I) – Orange
Calcium or Magnesium Chloride – Label and NFPA Placard
Propane – Label and NFPA Placard
Permitting
The State of Massachusetts and the local authorities require certain tank systems to have several
types of permits, registrations and licenses for the storage of virgin petroleum products.
1
A license is typically required by the MassDEP, local government (i.e. local fire department,
town clerk) for the storage of a petroleum product on site. The license is usually a permanent
part of the property and lists the amount of petroleum storage allowed at this facility. The
license must be updated when an increase in storage is anticipated.
The installation and removal of both UST and AST systems generally require a permit from the
local authorities including the fire department and local government (i.e. Conservation
Commission, Town Clerk, etc.). In addition the town may require the registration of the tank
system(s) on an annual or other periodic basis. These registrations keep a current listing of the
types and sizes of the tanks on site. MassDOT is currently not required to submit town
registrations.
For UST systems and some AST systems, the state also requires a form to be submitted with the
local fire department’s signoff showing the current tank system(s) component information. This
form referred to as a FP290 also contains a permit provision. Currently, MassDOT is only
required to obtain the FP290 Part 3 Permit from the local authority. This permit is to be
amended if any major modification is completed on the tank system (i.e. piping changes, fuel
type conversions, and dispenser changes)
When a tank system is removed, MassDOT and/or the removal contractor shall file the proper
notification of the removal by forwarding the FP290R form and submittal of an amended FP290
Part 3 Permit showing the appropriate changes.
Copies of the FP290 Part 3 Permit should be posted near the tank monitoring equipment and also
kept at a central location along with the facility storage license and any FP290 and/or FP290R
forms. If additional copies are required please contact your supervisor, the MassDOT
Environmental Services or access the permits through the web site.
Regulations
Several regulations cover the design, installation, and operation and maintenance of underground
and aboveground petroleum storage tanks. The following regulations can be reviewed for further
information.
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Massachusetts: 527 CMR 5.0 – Operation and Maintenance of Buildings and other Structures
used as Garages, Service Stations and the Related Storage, Keeping and Use of Gasoline or
other Motor Fuel.
Massachusetts: 527 CMR 9.0 – Tank and Containers
Nation Fire Protection Association: NFPA 30 Flammable and Combustible Liquids Code
Code of Federal Regulations: CFR Part 280 – Technical Standards and Corrective Action
Requirements for Owners and Operators of Underground Storage Tanks
Aboveground Storage Tanks
An aboveground storage tank is defined as a horizontal or vertical tank that is in a fixed location
without backfill above or below grade. MassDOT currently uses aboveground storage tanks at
several facilities for the storage of liquid propane, heating oils, and vehicle fuels. Aboveground
storage tanks are not required to be permitted if less than 10,000 gallons in capacity. Mobile
fueling tanks/trucks are not covered as part of this section.
2
Aboveground Storage Tank
Regulations governing the proper installation, operations and maintenance of these types of
storage tanks containing combustible liquids can be found in 527 CMR 9.03 Aboveground
Storage Tanks Greater Than 10,000 Gallons Capacity and Tanks Storing Combustible Liquids.
For aboveground tanks storing Class I liquids section 527 CMR 9.04 is the governing
regulations. Additional regulations for aboveground tank can be found in section 9.07 General
Provisions.
These regulations have requirements for proper location of a tank from property lines or public
ways, requirements for being placed on a suitable concrete slab and for protection from vehicular
impact by use of protective barriers (i.e. lalley columns, bollards). The piping requirements
outline in section 9.07 give specific size requirements for fill pipes (1 ¼ inch) and the proper
placement (greater than five feet from any door or window) and the proper height of vent piping
(12 feet above ground level).
The filling of any tank is important, especially aboveground storage tanks. Proper filling
procedures must be followed during every fuel delivery to limit spills and overfills. The operator
must ensure the available volume in the tank is greater than the volume of product to be
transferred to the tank before the transfer is made. The transfer operation must also be constantly
monitored to prevent overfilling and spilling. A proper tank volume chart must be made
available to the person delivering the product.
All aboveground tanks and piping shall be periodically inspected to observe the overall condition
of the equipment and area. The following are items that should be observed and reported if
found deficient.
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Tank for signs of leakage,
Tank for damage, rust and deterioration,
Tank seams for damage,
Tank supports/foundations for deterioration or damage,
Signs and labels posted and legible,
Tank monitoring systems are operating and not in alarm,
Vents are not obstructed,
Pipe system and supports are not damaged or leaking,
Spill buckets are clean,
Fill ports are locked and properly color coded, and
Protective bollards/fencing in good condition.
3
If any deficiencies are noted during a routine inspection call the DME or their designee
immediately.
Spill Control and Countermeasure Plans
A Spill Control and Countermeasure Plan (SPCC), which establishes procedures, methods and
equipment to prevent the discharge of oil into or upon navigable waters, must be maintained at
facilities which store petroleum products above certain threshold limits. A facility is subject to
these requirements if 1) the aboveground petroleum storage capacity is above 1,320 gallons
(aggregating tanks that are 55 gallons or greater) and 2) based on location, the facility could
reasonably be expected to discharge oil of quantities that may be harmful into or upon the
navigable waters of the United States, adjoining shorelines or affect certain natural resources.
The Environmental Protection Agency (EPA) has developed a set of regulations under 40 CFR
Part 112 that cover the requirements of the SPCC plan, inspections and record keeping.
Important Elements of a SPCC Plan:
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A plan can be either self-certified or reviewed and certified in whole or in part by a
Professional Engineer as being in accordance with good engineering practices, that include
considerations of applicable industry standards, meets the intent of the regulations, includes
procedures for inspections and testing and also certifies that the plan is adequate for the
facility.
Self-certification can only be conducted at “Qualified Facilities”. Qualified facilities are
defined as facilities having less than 10,000 gallons of aggregate storage and have not had a
single release greater than 1,000 gallons and/or 2 releases within a 12 month period greater
than 42 gallons.
The plan must be reviewed every 5 years and be self-certified or re-certified by a
Professional Engineer.
A prediction of the direction, rate of flow, and total quantity of oil that would result from
each major type of failure must be established.
Appropriate containment and/or diversionary structures or equipment to prevent the
discharge of oil have been put in place.
A schedule of inspections has been developed.
A record of the inspections is retained.
Yearly training of personnel on the use of the plan and the operation and maintenance of the
equipment that is provided to prevent discharges.
Designate a person accountable for oil spill prevention.
Develop an Emergency notification procedures and contact list.
(The complete SPCC plan requirements can be found in 40 CFR 112)
All aboveground tanks should be inspected regularly at each facility regardless if the site is
subject to SPCC plan submittal requirements. The visual inspection shall by conducted by
facility personnel for signs of leaks or corrosion and to check the amount of inventory in the
tank(s).
4
Underground Storage Tanks
Underground storage tank systems consist of several components. These components are
commonly known as the tank, piping, dispenser, monitoring system and overfill and spill
equipment. These components are discussed in more detail below. The following schematic
shows a typical UST system and the major components.
Dispenser
Veeder Root
Spill Bucket
Vent
Dispenser Pan
Interstitial Probe
DW Piping
VR Probe
Tank Detail Items
C. Tank-Mounted Fittings
D. Interstitial Reservoir
A. Interstitial Flow Channels
B. Strike Plates
Tank Accessory Item Descriptions
1. Piping Sump
2. Water tight Entries
3. Containment Collar
4. Interstitial Probe
5. Interstitial Reservoir
6. Piping Sump Sensor
7. Interstitial Fluid
8. Veeder Root Volume Probe
9. Veeder Root Monitor Console
10. Tank hold down Straps
11. Tank anchor pad or deadmen
12. Fuel Dispenser
13. Dispenser Pan
14. Double walled piping
15. Submersible Pump
16. Drop Tube
17. Shut-off valve
18. Spill Bucket
19. Vent
5
The typical tank system diagram shows a double walled fiberglass tank. The majority of the
underground tank systems are double walled fiberglass. However, MassDOT utilizes double
walled steel tanks at several of its facilities. The steel tanks are required to be additionally
protected against steel corrosion. The protection and special requirements are explained in the
Cathodic Protection section.
Leak Detection/Monitoring Systems
Each UST system includes a provision to check the integrity of the system on demand and detect
a leak from any portion of the tank and the piping system. UST systems are usually monitored
by an automatic gauging system (e.g. Veeder Root). These systems are capable of monitoring
inventory, ullage, level of water in the tank, interstitial monitoring between the primary and
secondary tank and perform tank tightness testing on a periodic basis.
The monitoring systems have a series of complex electronic equipment comprised of a
monitoring console, various probes and liquid detection devices and overfill alarm lights and
horns. If the monitoring equipment detects an alarm condition in any portion of the system a
signal is sent to the control panel and a visual and audible alarm is set off along with a
corresponding LCD read out at the panel further explaining the alarm condition.
Veeder Root Monitor Console
Common Alarms
At the Veeder Root monitoring system panel various conditions can cause an alarm signal to
annunciate as a beeping sound, show as a yellow or red flashing light and show on the LCD
panel face explaining the alarm location in code. All alarms should be checked for accuracy by
pressing the RED Alarm Test button. Any alarm condition that is not returned to the “All
Functions Normal” mode by pressing the Alarm Test button shall be reported to the Maintenance
Engineer or their designee.
There are four major sensors located at the tank to sense piping conditions, tank integrity, the
area under the fuel dispenser, and the volume probe that can detect sudden product gains/losses
and the presence of water.
The sensors are:
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Piping Sump Sensor
Interstitial Tank Sensor
Dispenser Pan Sensor
Volume Probe
6
Piping Sump Sensor
One of the sensors is located in the piping sump. The sensor can detect a leak from the
underground piping. If the piping fails and leaks into the secondary containment the
containment is designed to drain back to the piping sump and collect in the piping sump
reservoir. The piping sump sensor will detect the increase in water or product in the piping sump
and send an alarm to the console. This alarm condition will be noted on the Veeder Root console
as an “H” alarm with the corresponding tank number and the words “High Liquid or High Fuel”.
Piping Sump
Piping Sump Sensor Alarm Procedures
Caution should be taken when investigating any tank alarm condition. The areas to be
investigated may contain gasoline or diesel fuel vapors and/or product. Smoking is strictly
prohibited around these tank systems.
1. Check the Veeder Root Monitor Console for the proper alarm and tank identification.
2. Press the RED “Alarm Test” button to see if the alarm will clear.
3. If the alarm condition persists only authorized individuals should proceed with the
following steps.
4. Remove the steel piping sump tank pad cover.
5. Remove the piping sump cover.
6. Inspect the piping sump for liquid.
7. If liquid is not present inspect the sensor and electrical connections for condition. If the
sensor is still in alarm contact your supervisor.
8. If liquid is present, check if the liquid appears to be water, fuel or a mixture.
9. If the liquid contains fuel or a mixture contact your supervisor.
10. All liquid that is in the piping sump must be containerized and disposed of properly.
11. Once the liquid is removed from the piping sump the “Alarm Test” button should be pressed
to reset the system.
Piping sump cleaning should be conducted by an authorized employee or contractor. Piping
sumps can hold upwards of 100 gallons of liquid if full. The presence of liquid may indicate a
more serious problem if the condition continues.
7
Interstitial Sensor
The second major sensor is in the interstitial space of the double walled tank. The tank is
constructed of two separate tanks. The area between the two tanks is referred to as the interstitial
space. A tank can have a dry interstitial space or one filled with a brine (saltwater) solution.
With a dry sensor, the alarm will sound at the console if any liquid is detected in the interstitial
space. A wet system sensor alarm will sound if a loss or gain of liquid is detected. This alarm
condition will be noted on the Veeder Root console as an “L” alarm with the corresponding tank
number and the words “High Liquid”. A diagram of a typical interstial space is shown below.
Interstitial Space
Interstitial Space
Brine Solution
An interstitial sensor alarm may indicate a serious condition with the tanks integrity. The alarm
condition should be reported to the Maintenance Engineer or their designee. Only a trained
contractor should investigate this alarm condition.
Dispenser Pan Sensor
The following photo is a fuel dispenser unit showing the outside cover removed. The
containment area at the bottom of the dispenser is commonly known as the dispenser pan. Many
of the locations have sensors in this area to detect a dispenser pipe and/or a pump motor leak at
the dispenser. These alarms will come across as a “H-3” with the words “High Liquid or High
Fuel” at the Veeder Root console.
Fuel Dispenser
Dispenser Pan
8
Alarm Procedure
Caution should be taken when investigating any tank alarm condition. The areas to be
investigated may contain gasoline or diesel fuel vapors and/or product. Smoking is strictly
prohibited around these tank systems.
1. Check the Veeder Root Console for the proper alarm identification.
2. Press the RED “Alarm Test” button to see if the alarm will clear.
3. If alarm condition persists only authorized individuals should proceed with the following
steps.
4. Remove the fuel dispenser cover(s).
5. Inspect the dispenser pan for liquid.
6. If liquid is not present inspect the sensor and electrical connections for condition. If the
sensor is still in alarm contact your supervisor.
7. If liquid is present confirm if the liquid is water, fuel or mixture.
8. If the liquid contains fuel or a mixture contact your supervisor.
9. All liquid that is in the dispenser pan must be containerized and disposed of properly.
10. Once the liquid is removed from the dispenser pan the “Alarm Test” button should be
pressed to reset the system.
Dispenser pan cleaning should be conducted by an authorized employee or contractor. Piping
sumps can hold upwards of 15 gallons of liquid if full. The presence of liquid may indicate a
more serious problem if the condition continues.
Tank Volume Probe
The magentostrictive (Mag) probe (volume probe) performs several functions within the tank
system. Its main function is to provide accurate product volume readings that are displayed at
the Veeder Root Console. The probe can also detect the presence of water in the tank by sending
warnings or alarms to the console as “High Water Tank #”. The activation of a water level
warning and/or alarm condition may indicate a serious problem. All water warning or alarms
must be reported to the District Maintenance Engineer or their designee immediately. The
presence of water may affect the quality of the petroleum product in the tank and have a direct
effect on the vehicles or equipment that it serves. The water may also denote a serious tank
condition that should be corrected. The removal and proper disposal of water from within the
tank shall be conducted by a trained vendor.
Magnetic probes also perform volumetric tank tightness testing as required by regulation. The
probe has the ability to check the volume of liquid over a period of time to detect leaks that may
be as little as 0.1 gallons per hour (gph).
9
Magnetic Probe
Water/Fuel Float
Veeder Root Volume Probe
The mag probe also monitors the volume change during fuel deliveries. The probe identifies the
increasing levels of fuel during the delivery and sends an alarm when the tank volume reaches
90% full. The alarm condition shows at the Veeder Root Monitor Console and also sends a
signal to the overfill and acknowledgement system as an alarm and light to notify the delivery
driver to cease filling operations. More detail is provided in the Outside Alarms section below.
Common Alarms
The following table lists the most common alarms condition codes that will show on the LCD
display on the Veeder Root Monitor Console Panel that may indicate an environmental issue. A
complete listing of alarms and warnings can be found in the Veeder Root TLS350R Operation
Manual located near the console.
10 Table 1
Alarm Condition
L3 – High Liquid
High Fuel
Common Alarm Condition Codes
Alarm Location
Probable Cause
Gasoline Tank Manhole 1) Water entering/collecting in piping sump. Piping Sump Sensor
Check entries, seals and cover. 2) Product line failure/breach between
dispenser and sump. Check secondary piping and seals. L4 –
High Liquid
High Fuel
Diesel Tank Manhole –
Piping Sump Sensor
1) Water entering/collecting in piping sump. Check entries, seals and cover. 2) Product line failure/breach between
dispenser and sump. Check secondary piping and seals. H3 – High Liquid
High Fuel
Fuel Dispenser Pan Sensor
– located under dispenser
unit.
1) Product line failure/breach within dispenser. Check pipes, seals, gaskets and hoses.
L1 – High Liquid
Gasoline UST – Double
wall - Interstitial Sump
Sensor Hydrostatic
Reservoir
1) Expansion/contraction of brine solution
between primary and secondary tank walls.
2) Surface water entering brine reservoir. 3) Failure/breach of primary and/or secondary tank walls.
L2 –
High Liquid
Diesel UST – Double wall Interstitial Sump Sensor
Hydrostatic Reservoir
1) Expansion/contraction of brine solution
between primary and secondary tank walls.
2) Surface water entering brine reservoir. 3) Failure/breach of primary and/or secondary tank walls Overfill Tank 1 Gasoline UST – Product in
tank greater than 90% of
total volume.
1) Tank filled to level greater than 90% of total volume. Stop delivery immediately, check for overfill. 2) Check exterior overfill alarm, acknowledge alarm and reset. Overfill Tank 2 Diesel UST – Product in
tank greater than 90% of
total volume.
1) Tank filled to level greater than 90% of total volume. Stop delivery immediately, check for overfill 2) Check exterior overfill alarm, acknowledge alarm and reset. High Product Tank 1
Gasoline UST – Product in
tank greater than 95% of
total volume.
1) Tank filled beyond 90% alarm to greater than 95% of total volume. 2) Check 90% alarm settings and verify proper operation. Alarm will activate until product falls below 95% level. High Product Tank 2
Diesel UST – Product in
tank greater than 95% of
total volume.
1) Tank filled beyond 90% alarm to greater than 95% of total volume. 2) Check 90% alarm settings and verify proper operation. Alarm will activate until product falls below 95% level. 11 Alarm Condition
High Water
Tank 1
Alarm Location
Gasoline Tank – Water
observed in tank.
Probable Cause
1) Water entered tank during delivery or by
surface water through fill port at spill bucket.
2) Have water properly removed from tank if
level indicates more than 3/4 inches.
High Water
Tank 2
Diesel Tank – Water
observed in tank
1) Water entered tank during delivery or by
surface water through fill port at spill bucket.
2) have water properly removed from tank if
level indicates more than 3 inches.
Audible alarms at the Veeder Root Panel can be silenced by pressing the “Alarm Test” button on
the panel. The alarm condition will still be seen on the LCD display until the condition is
corrected. Contact your District Maintenance Engineer or their designee for corrective action
procedures.
Spill/overfill
All UST systems are equipped with spill and overfill prevention devices to minimize a release
while product is transferred from the delivery vehicle to the UST.
Outside Alarms
The Veeder Root system includes an outside component to warn the fuel delivery driver that the
tank volume is reaching the allowable maximum volume. The system consists of an overfill
alarm box with a red light and horn that will annunciate when the fuel in the tank reaches 90%
capacity and an acknowledgement box to test and silence the alarm. The driver should test the
alarm light and horn system prior to starting the delivery of product to ensure the system is
functioning. Once the delivery reaches the 90% level the Veeder Root Alarm will light and the
horn will sound until the driver depresses the acknowledgement button. These systems are
usually located on the nearest building wall and are mounted so that the driver can see and hear
the alarm when filling the tanks. Typically the alarm box is mounted several feet above the
acknowledgement box.
Overfill/Acknowledgement
As described above, most MassDOT locations have this overfill/acknowledgement monitoring
system. However, supplementary overfill protection devices may be installed on tank systems
that are designed to automatically restrict the flow or automatically shut off the flow of fuel to
the tank when the tank is nearly full. Each facility must have at least one of these overfill
devices in place to prevent overfills.
12 Spill Prevention
A spill prevention device such as a spill box or bucket is designed to contain small amounts of
fluids, typically up to 5 gallons, in a catch basin once the delivery truck’s hose is removed from
the fill pipe. The spill bucket may accumulate solid debris and excessive liquids and should be
inspected and cleaned on a regular basis. The delivery truck driver must follow standard
practices and exercise caution whenever delivering fuel.
Spill Bucket Labeled for
Unleaded Gasoline
Spill Bucket Uncleaned
Guidelines for Pumping Out UST Fill Port Sumps and Fuel Pump Sumps
1. Check sumps for water on a regular basis (at least monthly) or before calling for a fuel
delivery.
2. Check for signs of wear, fill cap tightness and that the bucket area is clean of debris and
liquids. Fuel port sumps must be pumped out before any fuel deliveries.
3. Sumps should contain only rain water. If fuel is present in any of the sumps contact the
District Maintenance Engineer or designee immediately.
4. To drain the water from the sumps use a proper pump (a hand pump or a spark free
electric pump).
5. Sump water must only be disposed of into a floor drain. NEVER PUMP TO THE
GROUND OR TO A CATCHBASIN!
6. If the fueling facility does not have any floor drains, the water must put into a proper
container and transported to the nearest facility with floor drains.
7. The transport container should be properly labeled (Sump Water), the container must be
closed, and the container must be secured in the vehicle to prevent shifting while in
transit.
8. If large amounts of water are regularly being pumped from the sumps notify the District
Maintenance Engineer.
13 Filling Procedures
The following general operating procedures should be followed to minimize a spill or overfill
event during a delivery:
1. Prior to the fuel delivery a check on the available capacity of the tanks volume versus the
volume of product being delivered must be made.
2. Maintain spill response materials in close proximity to the fuel transfer location.
3. Review/test the operation of any equipment designed to prevent or limit spill events.
Including testing the overfill alarm and acknowledgement equipment.
4. Check the condition of the spill bucket and that it is free of liquids and/or debris prior to
filling.
5. Monitor fuel transfer activities to prevent overfilling and spilling.
6. Cease filling operation immediately when the overfill alarm is activated.
Securely close and lock all tank fill ports and monitoring locations to prevent unauthorized
access.
Check the tank for water after every fuel delivery.
Cathodic Protection
MassDOT utilizes double walled steel underground storage tanks at three of its refueling
locations and at eight MassPike toll interchanges (for heating oil). Because these tanks are made
of bare steel and are not coated by a fiberglass shell the tanks require special protection. The
steel tanks where initially installed with a cathodic protection system to reduce the amount of
corrosion caused by the reaction between the steel and the soil and/or groundwater around the
tank. The cathodic protection system consists of a sacrificial anode bag or tube that is affixed to
the tanks outer wall. This anode system keeps a steady charge on the steel tank and reduces or
eliminates the corrosion process.
The cathodic protection system is required to be tested by a state certified cathodic system tester.
Special leads where installed with the tank to allow the testing company to hook up to the wires
and test the charge created by the system. The test number is checked versus published
allowable readings to determine if the cathodic protection system is working. This test is to be
conducted every three years and based on the test readings may require more periodic testing. If
at any time the test results indicate that the system is not functioning properly steps are required
to be taken to verify the system is still working and adjustments may need to be made to get the
systems back to the proper charge. This may require further testing or the addition of new
sacrificial anode bags.
Petroleum Inventory Reconciliation
Vehicle dispensing systems are required to comply with daily and monthly inventory
reconciliation between use (gallons dispensed) and inventory (tank volume) as stated in
regulations number 527 CMR 9.0 and 527 CMR 5.0. It is the responsibility of the District
Maintenance Engineer or their designee to ensure that the proper data for each fuel tank at every
site is collected on a daily basis and the inventory control on each UST at every site in the
14 District is completed on a monthly basis. In the event that the electronic system is inoperable,
daily measurement of the inventory in the tank must be conducted by stick readings and the total
throughput of the dispensers shall be recorded until the system can be placed back in service.
The inventory and usage information is available through remote communication with the tank
systems. Boston Operation staff will download the required data through the inventory
monitoring system software program. Once the date is collected, the daily reconciliation must be
reviewed for abnormal loss or gains in the system.
The information from the daily reconciliation must be combined to reconcile the system on a
monthly basis. A simple calculation must be performed to add the daily gain/loss from each day
for the month. Currently, MassDOT has been granted an allowance of a net loss or gain of no
more than 1% of the monthly throughput plus 130 gallons. As an example: Say the facility
dispensed 2500 gallons for the month the acceptable net gain/loss calculated amount would be
(2500 gallons x 1%) 25 gallons + 130 gallons for a total of 155 gallons. If the monthly
reconciliation figures are greater than this allowance the MassDOT Monthly Abnormal Loss
Procedure flow chart must be followed. These procedures are outlined in Appendix C.
Records of these reconciliation data for each tank must be kept for a period of twelve months.
Complete details of the process are provided in the MassDOT Standard Operating Procedure for
Inventory Control for UnderGround Storage Tanks at MassDOT Facilities and in MassDOT
Inventory Control Training materials.
Dispensing Equipment and Procedures
Refueling depots contain equipment to allow only authorized users the ability to refuel vehicles
in a safe and controlled environment. Every facility is equipped with a key access system
(PetroVend) that allows the user to insert a preauthorized key and enter a corresponding PIN
code that engages the dispenser units. The system records the vehicle information, date and time
and the amount of fuel dispensed. The fuel pump or dispenser is set up for the pumping of both
gasoline and diesel fuel to be used in authorized vehicles only.
PetroVend Fuel Card
Proper operation of the dispenser, hose and nozzle units can reduce the amount of wear and tear
on the equipment and limit the number of spill incidents. It is important that every time that a
vehicle is refueled that the following procedures be followed.
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Turn OFF engine
DO NOT Smoke
Carefully avoid spillage
Do not top off a fuel tank
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Keep vapor recovery system engaged
Stop pumping once the dispenser automatically shuts off
Wait five seconds for fuel to completely drain into tank then remove nozzle from vehicle
Do not leave fueling vehicle unattended
Do not prop nozzle in the open position
Avoid dropping the dispenser nozzles on the ground or dragging the hoses across the
concrete.
Use absorbent material if spillage occurs
Report any warning signs of a suspected release
All transactions are stored by the systems controller and are remotely accessed on a daily basis
for information about the user, amount of inventory, product dispensed and to check on any
alarm conditions.
Vapor Recovery
Gasoline dispensing facilities are required to provide a system to recovery gasoline vapors
during deliveries (Stage I) and also during dispensing (Stage II) at facilities installed or modified
after November 1, 1989. More information is available in the Massachusetts Regulation:
Amendments to 310 CMR 7.24(6) Dispensing of Motor Vehicle Fuel (Stage II Vapor Recovery)
and MassDOT SOP Inspection and Repair of StageI/II Vapor Recovery Systems.
The regulations and SOPs spell out the requirements for maintenance and operation of the
systems and the required inspections and certifications. Some of these requirements are outlined
below.
Stage I
During the delivery of gasoline product into the storage tanks the delivery driver is responsible to
capture the vapors displaced by the new product entering the tank and return these vapors to the
delivery truck. This is accomplished by the driver properly hooking the fuel delivery hoses
through a coaxial fill or two point vapor recovery system. If properly attached, the driver will
drop the fuel through the hose and recover the displaced vapors through the coaxial tube or
second hose system. The vapors will return to the delivery truck to be properly captured at the
receiving facility.
A portion of the weekly inspection check list deals with the inspection of the tank components
that make up the Stage I portion of the system (see Weekly Inspection Checklist below).
Stage II
The Stage II portion of the vapor recovery system is designed to capture the gasoline vapors
displaced from the vehicle’s gas tank while fueling. The system consists of special fueling
nozzles that dispense fuel through the main hose and captures the vapors within the secondary
vapor holes. The vapor from the vehicle’s gasoline tank travels through the vapor recovery
piping to the underground storage tank and is eventually recaptured during the Stage I delivery
process.
The following is a typical Stage II vapor recover nozzle.
16 Fuel Nozzle
Stage II Components
Retractor
Ten Inch Loop
The Stage II Vapor recovery system has a weekly inspection requirement. The inspection
consists of viewing the components of the system and determining the operating condition. A
weekly inspection checklist has been developed as shown below.
Weekly Inspection Checklist
17 Balance Systems
Week of
_____________________
Component
*Nozzles
*Hoses
Retractor Cable
Hose Breakaways
Tank Vent Lines
Stage I Vapory
Recovery
Issue
1a. Are the nozzle boots torn, slit or loose?
1b. Are the nozzles leaking gasoline?
1c. Are the nozzle boots compressed when hanging from
the pump?
2a. Are the hoses flattened, kinked, cracked or taped?
2b. Are the hoses resting on the ground or the island?
2c. Dose the hose loop exceed 10 inches?
2d. Does the hose assembly (hose, breakaways, valves)
leak gasoline?
3a. Does the hose retract to the bottom of the retractor
bar?
Yes or No
4a. Is the hose breakaway between the nozzle and the
retractor bar?
4b. Are the hose breakaways installed in the proper
direction?
5a. Are there rain caps or PV valves installed on the top of
the vent pipe?
6a. Do both the fill and vapor recovery ports have caps?
6b. Are the fill and vapor recovery caps and gaskets in
good condition?
6c. Does the vapor break seal properly?
6d. Are the containment sumps clean and in good
condition?
If the component is in need of repair, please list the problem and date corrected in the following
table.
If you answer YES to a * Bold item, the system is to be taken OUT OF SERVICE until the
repairs are made!!!
Date of
Inspection
Components in need of repair
Date of Repair
Inspector signature
Inspection form is to be done weekly
Please sign and date the inspection form.
Print Name
Sign Name
Date Trained
Current Date
The Stage II Vapor recovery system is also required to have the entire system recertified by a
state licensed inspection company on an annual basis. The system components are tested, under
pressure, to make sure the system functions as it was designed. Once the system has passed the
certification requirements the testing records along with a signed State of Massachusetts Stage II
Form C must be submitted to the state. If any portion of the system, operation and maintenance
18 or record keeping is not in compliance the proper procedures must be followed to correct the
problem within 14 days or the system must be taken out of service until the issue is resolved.
Fire Suppression Systems
At some gasoline dispensing facilities a fixed fire suppression system has been incorporated in
the dispenser island canopy. If a fire suppression system is installed at the facility, inspections of
the system are required every six months. The system inspection is conducted by a state licensed
contractor who is knowledgeable on the particular system and its components. Inspection tags
should be located on a portion of the system and be visible. Many of the local fire departments
require proof of past fire suppression test results prior to issuing new tank permits.
Fire Suppression System
If a system appears to be past its inspection schedule date please contact your supervisor.
Record Retention
UST and AST records must remain on site or at a central location so that the records can be
made available upon request. Records that must be retained include:
1. Weekly Stage II inspection records and associated repair, out of service and annual
certification test results. These files should be retained for a period of twelve months.
2. Record of maintenance, repair and calibration to the leak detection equipment must be kept
for one year.
3. Most current registration and permit should be posted.
4. Site surveys and assessment of tank closure shall be kept indefinitely.
5. Petroleum Inventory Reconciliation records shall be kept for one year.
6. SPCC training, certification must be kept current within a year. The SPCC plan must be
updated every 5 years or when there is a major change.
For more information on storage tank issues refer to the following MassDOT Standard Operating
Procedure contained in Appendix A:
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Inspection and Repair of Stage I and II Recovery Systems
19 
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