Waste Minimization

By initiating a waste minimization program, you can reduce the costs, liabilities, and regulatory burdens of hazardous waste management. Some waste minimization initiatives are:

• Petroleum-based fluids from vehicles, including used oil, transmission fluid and brake fluid, should be collected and recycled.

• Absorbents should be used to clean up minor fluid leaks and spills which occur during routine vehicle maintenance.

• Coolants from radiators should be collected and recycled.

• Parts washing should be done in a self-contained, recirculating solvent sink.

• Waste petroleum based fluids, absorbents for clean ups, coolants and spent solvent should each be collected and placed in a Department of Transportation (DOT) approved waste receptacle. These wastes should be recycled wherever possible. Waste disposal should be in accordance with applicable federal, state and local waste regulations.

• Use biodegradable cleaning agents and safe alternatives to hazardous materials.

• Uncovered vehicle storage areas should have a separate stormwater collection system with an oil/grit separator which discharges to the municipal sanitary sewer or to a dead holding tank.

Baseline Best Management Practices: After the storm water assessment is completed, identified sources of pollutants must be controlled. If possible, baseline BMPs should be used. They are inexpensive, simple, and include the following applicable methods:

• Good Housekeeping - Good housekeeping practices are designed to maintain a clean work environment, reduce spill possibility, and enhance safety. Good housekeeping includes routine inspection for leaks or conditions that could lead to discharges;

• Preventive Maintenance - Preventive maintenance includes timely inspection and maintenance of pipes, pumps, storage tanks, and storm water management devices (cleaning oil/water separators or catch basins);

• Visual Inspections - Visual inspections of areas where spills or leaks have previously occurred, material storage areas, outdoor material processing areas, waste generation areas, and loading/ unloading areas, is an effective means of early detection. Watch for obvious signs of storm water contamination.

• Spill Prevention and Response - Spill prevention and response includes the identification of potential spill sites and their drainage points. This should include material handling procedures, storage requirements, and spill clean-up procedures;

• Sediment and Erosion Control - Sediment and erosion control applies to the identification of those areas, which due to their topography, activities, or other factors, have a high potential for erosion; and

• Runoff Management - Runoff management includes flow diversion (channels, gutters, drains, sewers), exposure minimization (devices used to limit exposure of storm water to contaminants such as dikes, curbing, catch basins and sumps), mitigative practices (techniques to clean up or recover released substances such as sweeping, shoveling, vacuuming and the use of sorbents and gels) and other preventive practices (dust control, routine monitoring of operations, warning signs and labels, and control of vehicle washing).

   

Advanced Best Management Practices: In some cases, baseline BMPs will be insufficient to address storm water pollution prevention needs. In these situations, advanced BMPs are necessary. Tailored to the specific needs of your facility, the hierarchy of advanced BMPs is substitution or process changes, recycling, treatment, or structural controls.

Additional guidance on advanced BMPs may be found in Chapter 3 (Activity- Specific Source Control BMPs) and Chapter 4 (Site-Specific Industrial Storm Water BMPs) of "Storm Water Management for Industrial Activities, Developing Pollution Prevention Plans and Best Management Practices," U.S. Environmental Protection Agency, EPA 832-R-92-006, September 1992. Always check with your base Environmental Office to ensure that implementation of advanced BMPs is consistent with the requirements of other environmental plans at your installation.

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