Attach_1-_(A00002)BMPs_(rev1-PPW)_5Jan13.doc

ATTACHMENT 1

Best Management Practices The following are best management practices (BMPs) that are intended to mitigate potential impacts on natural resources, including vegetation, wildlife, migratory birds, threatened and endangered species, and water resources. It is the responsibility of all personnel performing maintenance to comply with the BMPs, unless otherwise noted. BMPs apply to all maintenance and repair activities (both waived and not waived regardless of in-house versus contracted work method) with one exception. The exception involves the waived areas where CBP will not apply for Clean Water Act (CWA) Section 404 permits or submit Storm water Pollution and Prevention Plans (SWPPP) for regulatory review and approval. This provision is necessary in order to maintain the integrity of waiver authority.

The following BMPs would be implemented for the Proposed Action. CBP would use an established planning and work development process to identify the BMPs that must be implemented for the project. To identify species-specific BMPs that must be implemented, environmental subject matter experts would identify which species potentially occur in the geographic location of each maintenance and repair activity using information such as that shown in Appendix D. They would then consider other available sources of information, such as prior survey data, aerial photographs, site visits, and previously developed environmental documentation, to evaluate whether suitable habitat for threatened and endangered species may occur at each project location. The environmental subject matter expert would also determine if a survey conducted by a qualified biologist is required prior to maintenance and repair activities to determine if habitat is present or required by a BMP. If necessary, the environmental SMEs would conduct further consultation with USFWS to clarify any compliance requirements.

Land Use

1. CBP will notify all land managers at least 5 days in advance of any scheduled maintenance and repair activities on their lands.

Geology and Soil Resources Silt fencing and floating silt curtains should be installed and maintained to prevent movement of soil and sediment and to minimize turbidity increases in water.

Implement routine road maintenance practices to avoid making wind rows with the soils once grading activities are complete and use any excess soils on site to raise and shape the road surface.

Only apply soil-binding agents during the late summer/early fall months to avoid impacts on federally listed species. Do not apply soil-binding agents in or near (within 100 feet) surface waters (e.g., wetlands, perennial streams, intermittent streams, washes). Only apply soil-binding agents to areas that lack any vegetation.

Obtain materials such as gravel, topsoil, or fill from sources that are compatible with the project area and are from legally permitted sites.

Vegetation

1. Herbicide and pesticide applications must be made under the supervision of a licensed applicator. A log of the chemical used, amount used, and specific location must be maintained.

2. If mechanical methods are used to remove invasive plants, the entire plant should be removed and placed in a disposal area. If herbicides are used, the plants would be left in place. All chemical applications on federally managed land must be used in coordination with the Federal land manager. Training to identify nonnative invasive plants would be provided for CBP personnel or contractors, as necessary.

3. If the tactical infrastructure maintenance and repair activities would take place on a Federal agency’s land, the appropriate agency’s herbicide policy must be followed for vegetation control. Contractors applying herbicides must verify that the appropriate agency's policy is being followed, if it exists. This information should be requested from the COTR.

4. New guidance from the USEPA on herbicide application in riparian areas is imminent. Check with COTR on the current status of these regulations prior to applying herbicide in such areas.

5. CBP would notify applicable owners and land managers 10 days prior to implementing clearing activities.

6. Where vegetation to be cleared is on a levee, the method of removal would ensure that the integrity of the levee is maintained.

7. Coordinate with the CBP ENV SME to determine if the maintenance activities occur in a highly sensitive area or an area that poses an unacceptable risk of transmitting diseases and invasive species. If it is determined that maintenance activities occur in such an area, follow the CBP cleaning protocol.

8. A fire prevention and suppression plan will be developed and implemented for all maintenance and repair activities that require welding or otherwise have a risk of starting a wildfire.

9. Identify fill material, sandbags, hay bales, and mulch brought in from outside the project area by its source location. Use sources that are sterile or weed-free.

10. Clearly demarcate the perimeter of all new areas to be disturbed during vegetation-clearing activities using flagging or temporary construction fencing. Do not allow any disturbance outside that perimeter.

11. Riparian vegetation should be protected during maintenance activities.

12. Avoid the removal of mature trees providing shade or bank stabilization within the riparian area of any waterway during maintenance or repair activities.

13. If vegetation must be removed, allow natural regeneration of native plants by cutting vegetation with hand tools, mowing, trimming, or using other removal methods that allow root systems to remain intact.

14. Vegetation targeted for retention would be flagged for avoidance to reduce the likelihood of being treated.

15. Periodic inspections of tactical infrastructure by the CBP SME would be conducted to evaluate and document conditions, including erosion and to ensure that prescriptions are followed and performed in the appropriate community types. As necessary, maintenance will be scheduled to minimize erosion and correct other adverse conditions.

16. Clearing of riparian vegetation will not occur within 100 feet of aquatic habitats to provide a buffer area to protect the habitat from sedimentation.

Wildlife If hollow bollards are necessary, cover hollow bollards (i.e., those that will be filled with a reinforcing material such as concrete) to prevent wildlife from entrapment. Deploy covers (and ensure they remain fully functioning) from the time the posts or hollow bollards arrive on the site and are unloaded, until they are filled with reinforcing material.

Ensure temporary light poles and other pole-like structures used for maintenance activities have anti-perch devices to discourage roosting by birds.

Clearing of riparian vegetation would not occur within 100 feet of aquatic habitats to provide a buffer area to protect the habitat from sedimentation.

Minimize animal collisions during maintenance and repair activities by not exceeding speed limits of 35 miles per hour (mph) on major unpaved roads (i.e., graded with ditches on both sides) and 25 mph on all other unpaved roads. During periods of decreased visibility (e.g., night, poor weather, curves), do not exceed speeds of 25 mph.

Do not permit pets owned or under the care of the contractor or sector personnel inside the project boundaries, adjacent native habitats, or other associated work areas.

To prevent entrapment of wildlife species, ensure excavated, steep-walled holes or trenches are either completely covered by plywood or metal caps at the close of each work day or provided with one or more escape ramps (at no greater than 1,000-foot intervals and sloped less than 45 degrees) constructed of earth fill or wooden planks.

Each morning before the start of maintenance activities and before such holes or trenches are filled, ensure they are thoroughly inspected for trapped animals. Ensure that any animals discovered are allowed to escape voluntarily (by escape ramps or temporary structures), without harassment, before maintenance activities resume; or are removed from the trench or hole by a qualified person and allowed to escape unimpeded.

Threatened and Endangered Species and Other Protected Species General BMPs Coordinate with COTR or ENV SME to determine which threatened and endangered species could occur in the vicinity of maintenance activities. In areas where there are no threatened and endangered or other species concerns, the personnel performing the maintenance activity are responsible for monitoring the implementation of general maintenance and repair BMPs to avoid impacts on the environment.

To protect individuals of listed species within the project area, suspend work in the immediate vicinity of the individual until it moves out of harm’s way on its own, or enlist a qualified specialist (individuals or agency personnel with a permit to handle the species) to relocate the animal to a nearby safe location in accordance with accepted species-handling protocols.

Vegetation clearing would not occur in suitable habitat within the range or designated critical habitat of threatened and endangered species. If a threatened or endangered species, PCE, or other indicators of suitable habitat occur within the project area, then further consultation with USFWS would be required.

Obtain all pertinent training materials for biological resources for the areas where maintenance activities would occur. Prior to arrival on the work site, ensure key personnel are aware of the biological resources potentially occurring in the project area and understand the proper BMPs to implement should threatened and endangered species be encountered in the project area.

Check visible space underneath all vehicles and heavy equipment for listed species and other wildlife prior to moving vehicles and equipment at the beginning of each workday and after vehicles have sat idle for more than 15 minutes.

Coordinate with the CBP ENV SME to determine if the maintenance activities occur in a highly sensitive area or an area that poses an unacceptable risk of transmitting diseases and invasive species. If it is determined that maintenance activities occur in such an area, follow the CBP cleaning protocol.

Migratory Birds Initial mechanical and chemical vegetation clearing and subsequent mechanical vegetation control should be timed to avoid the migration, breeding, and nesting timeframe of migratory birds (February 1 through September 1). Herbicide re-treatments could occur throughout the year. When initial mechanical and chemical vegetation clearing or subsequent mechanical vegetation control must be implemented during February 1 through September 1, a survey for nesting migratory birds will be conducted immediately prior to the start of activities. If an active nest is found, a buffer zone will be established around the nest and no activities will occur within that zone until nestling shave fledged and abandoned the nest.

A survey for migratory birds will also be conducted prior to all other maintenance and repair activities to be implemented during the nesting period in areas where migratory birds might be nesting.

If maintenance is scheduled during the migratory bird-nesting season, take steps to prevent migratory birds from establishing nests in the potential impact area. These steps could include covering equipment and structures, and use of various excluders (e.g., noise). Birds can be harassed to prevent them from nesting on the site. Once a nest is established, they cannot be harassed until all young have fledged and left the nest site. If nesting birds are found during the supplemental survey, defer construction or intrusive maintenance activities until the birds have left the nest. Confirmation that all young have fledged should be made by qualified personnel.

Species-Specific BMPs Arroyo Toad (Anaxyrus californicus) All vegetation clearing activities would avoid riparian vegetation within or 100 feet outside of critical habitats or other known arroyo toad breeding habitat, in order to provide a buffer area to protect the habitat from sedimentation.

Maintenance activities within areas of known arroyo toad occurrences, arroyo toad breeding habitat (i.e., in streams and immediately adjacent to streams) will not take place during the arroyo toad breeding season (March 15 to July 31). If these activities cannot be avoided during this season, a qualified biologist would conduct a survey to determine if arroyo toads are present. If they are determined to be present, maintenance activities will be delayed until the end of the breeding season or further consultation with USFWS will be conducted.

Avoid high-velocity releases from project activities (during and after maintenance) that could degrade breeding habitat.

Any use or storage of chemicals or fuels at project sites will be kept 0.3 miles away from toad habitat (i.e., areas of known arroyo toad occurrence, arroyo toad breeding habitat [in-stream and immediately adjacent], or critical habitat).

Use of herbicides will not occur within areas of known arroyo toad occurrences, arroyo toad breeding habitat, or critical habitat, unless approved by the USFWS.

Bighorn Sheep-Peninsular Ranges (Ovis canadensis nelsoni)

California Least Tern (Sternula antillarum browni), Western Snowy Plover (Charadriusalexandrinus nivosus)

1. All ground-disturbing activities and high-impact activities that require heavy equipment within suitable California least tern or Western snowy plover nesting habitat (i.e., beach habitat) would be avoided May 15 through August 15 for California least tern and March1 through September 30 for the Western snowy plover, which are the nesting seasons for these species. If these activities cannot be avoided during the nesting season, the COTR or ENV SME will notify California State Parks (CSP) and request the locations of known nest sites. If these activities are in close proximity to occupied California least tern or Western snowy plover habitat a qualified monitor will be used to avoid impacts.

2. Low-impact maintenance activities for roads, fences, walls, or other facilities can take place during periods of seasonal restrictions provided that the action does not involve significant amounts of heavy equipment. Determination is made between CBP, USFWS, and other landowners/managers that the project is low-impact and does not require significant amounts of heavy equipment.

Coastal California Gnatcatcher (Polioptila californica californica), Least Bell's Vireo (Vireo bellii pusillus), Light-footed Clapper Rail (Rallus longirostris levipes), Southwestern Willow Flycatcher (Empidonax trailli extimus), Yuma Clapper Rail (Rallus longirostris yumanensis) Vegetation control in suitable habitat of threatened or endangered bird species (see Table E-3 for a description of suitable habitat and nesting season for each species) will be limited to the minimum necessary to maintain drivable access roads and to maintain the functionality of other tactical infrastructure. This limited vegetation control will be conducted outside of the nesting season (see Table E-3). This restriction does not apply to areas where protocol surveys have been conducted and it has been determined that the area is not occupied and does not contain PCE.

If vegetation clearing is to be conducted adjacent to suitable habitat of a threatened or endangered bird species (Table E-3), qualified personnel with experience identifying suitable habitat of that species will delineate and clearly mark the suitable habitat to be avoided.

For all other maintenance activities to be conducted within suitable habitat of a threatened or endangered bird species during the nesting season (see Table E-3), the following avoidance measures will apply. A qualified biologist will conduct a survey for threatened and endangered birds prior to initiating maintenance activities. If a threatened or endangered bird is present, a qualified biologist will survey for nests approximately once per week within 500 feet (all other species) of the maintenance area for the duration of the activity. If an active nest is found, no maintenance will be conducted within 300 feet (all other species) of the nest until the young have fledged.

Table E-3. Threatened and Endangered Bird Species Suitable Habitat and Nesting Season Common Name Suitable Habit Nesting Season Coastal California gnatcatcher coastal sage scrub at an elevation of lessthan 750 meters (2,460 feet) February 1-July 31 Least Bell’s vireo Riparian habitat March 15-September 15 Light-footed clapperrail Coastal and freshwater marshes, nests in cordgrass (Spartina foliosa), and pickleweed (Salicornia virginica) orsecondarily bulrushes (Scirpus spp.) andcattails (Typha spp.)

March 1-Aug 31

Southwestern willow flycatcher dense riparian habitat along streams, rivers, lakesides, and other wetland Sep 16–Mar14 Yuma clapper rail freshwater marshes generally dominated by cattail [Typha spp.] and bulrush [Scirpus ssp.] with a mix of riparian trees and shrubs Mar 15–Jul 15

Annuals: California Orcutt Grass (Orcuttia californica), Otay Mesa Mint (Pogogynenudiuscula), Otay Tarweed (Deinandra conjugens), Saltmarsh bird’s-beak (Cordylanthusmaritimus ssp. maritimus), San Diego Button Celery (Eryngium aristulatum var. parishii), SanDiego Thornmint (Acanthomintha ilicifolia), Spreading Navarretia (Navarretia fossalis) In areas of known threatened and endangered annual plant species occurrences, critical habitat and suitable habitat vegetation clearing and control will be conducted during the period, between September 1 through December 31, when the species are dormant. No soil will be removed from sites and disturbances will be minimized.

From January 1 through August 31, all vegetation-clearing and -control activities would avoid areas of known threatened and endangered annual plant species occurrences; critical habitat and suitable habitat (see Table E-1). If vegetation-clearing or -control activities in such areas are unavoidable during this time, then a qualified biologist will conduct a survey (during the appropriate blooming season, see Table E-1) within the maintenance area. An area of sufficient size would be flagged to create a buffer large enough to ensure that threatened or endangered plant species are not directly or indirectly affected.

Use of herbicides will not occur within areas of known threatened and endangered plant species occurrences, critical habitat or suitable habitat (see Table E-1), unless approved by the USFWS.

Table E-1. Threatened and Endangered Annual Plant Species That Could Occur Within the Action Area Common Name Habit Blooming Season California orcutt grass Vernal pools and vernal pool complexes.

May–July Otay mesa-mint Vernal pools and vernal pool complexes.

May–July Otay tarweed Grasslands, open coastal sage scrub, maritime succulent scrub, and along some disturbed sites and cultivated fields.

May–June Saltmarsh bird’s-beak Coastal salt marshes.

May–October San Diego button celery Vernal pools and vernal pool complexes.

April–June San Diego thornmint Heavy clay soils within openings of coastal sage scrub, chaparral, and native grasslands of coastal SanDiego County.

April–June Spreading navarretia Vernal pools and vernal pool complexes.

April–June

Table E-2. Threatened and Endangered Perennial Plant Species That Could Occur Within the Action Area Common Name Habit Blooming Season Encinitas baccharis Steep slopes, in sandstone and volcanic substrates within fairly open maritime chaparral and dense mixed chaparral communities at elevations of 60 to 335 meters (196 to 1,099 feet).

August–November Jennifer’s monardella Ephemeral drainages, in semi-open canopies of coastal sage scrub and riparian scrub.

June–September Mexican flannelbush Closed-cone coniferous forests and southern mixed chaparral.

March–June Peirson’s milkvetch Slopes and hollows of the leeward side of sand dunes in the Sonoran desert plant community in the western portion of the Algodones Dunes of eastern Imperial County, California.

December–April San Diego ragweed Open native and nonnative grasslands and within openings of coastal sage scrub on sandy loam or clayloam soils.

April–October

Perennial Plants: Encinitas Baccharis (Baccharis vanessae), Jennifer’s/Willowy Monardella (Monardella stoneana), Mexican flannelbush (Fremontodendron mexicanum), Peirson’s Milkvetch (Astragalus magdalenae var. peirsonii), San Diego Ragweed (Ambrosia pumila)

Quino Checkerspot (Euphydryas editha quino)

Vernal Pool Species: Riverside Fairy Shrimp (Streptocephalus woottoni), San Diego FairyShrimp (Branchinecta sandiegonensis), California orcutt grass (Orcuttia californica), Otay Mesamint (Pogogyne nudiuscul), San Diego button celery (Eryngium aristulatum var. parishii),Spreading navarretia (Navarretia fossalis)

Water Resources

1. The ENV SME must be consulted to validate the need for site-specific storm water pollution prevention plans (SWPPPs), spill protection plans, and regulatory approvals. Site-specific SWPPPs and spill protection plans would be prepared and regulatory approval sought, if necessary, in cases of highly sensitive work sites and large scopes of work that pose a significant risk. Where a site-specific SWPPP is not necessary, the personnel performing the maintenance would comply with a generic SWPPP and spill protection plan that covers most routine maintenance and repair activities. Prior to arrival on the work site, key personnel would understand correct implementation of these BMPs and their responsibility to address deficiencies.

2. The ENV SME would provide locations that have the potential for wetlands or other waters of the United States. If no current existing U.S. Army Corps of Engineers (USACE) jurisdictional determination is available, delineation would be conducted and jurisdictional determination would be obtained from the USACE. Prior to conducting any activities that have the potential to affect wetlands and other waters of the United States, all Federal and state Clean Water Act (CWA) Section 404 individual or applicable nationwide permits and 401 and other applicable permits would be obtained.

3. Prepare and implement an SWPPP prior to applicable maintenance activities (greater than 1 acre of exposed dirt or as required by property manager). Implement BMPs described in the SWPPP to reduce erosion. Consider areas with highly erodible soils when planning the maintenance activities and incorporate measures such as waddles, aggregate materials, and wetting compounds in the erosion-control BMPs.

4. Coordinate with the ENV SME to determine which maintenance activities occur within the 100-year floodplain. Maintenance activities within the 100-year floodplain would be conducted in a manner consistent with Executive Order (EO) 11988 and other applicable regulations.

5. All maintenance contractors and personnel would review the CBP-approved spill protection plan and implement it during maintenance and repair activities.

6. Coordinate with ENV SME to ensure that CWA permits are in place for any changes to existing boat ramps.

7. Contact the ENV SME to coordinate with waterway permitting agencies when performing work below the ordinary high water mark.

8. Wastewater from pressure washing must be collected. A ground pit or sump can be used to collect the wastewater. Wastewater from pressure washing must not be discharged into any surface water.

9. If soaps or detergents are used, the wastewater and solids must be pumped/cleaned out and disposed of in an approved facility. If no soaps or detergents are used, the waste water must first be filtered or screened to remove solids before being allowed to flow off site. Detergents and cleaning solutions must not be oversprayed into or discharged into surface waters.

10. If the surrounding area has dense, herbaceous cover (primarily grasses) and there are no listed plant species or habitat for such, the wastewater (with or without detergent) could be discharged directly to the grassy area without collection or filtering as long as it is well dispersed and all the wastewater can percolate into the grass and soil. If wastewater runs off the grassy area, it must be filtered.

11. Prevent runoff from entering drainages or storm drains by placing fabric filters, sand bag enclosures, or other capture devices around the work area. Empty or clean out the capture device at the end of each day and properly dispose of the wastes.

12. Avoid contaminating natural aquatic and wetland systems with runoff by limiting all equipment maintenance, staging, lay down, and dispensing hazardous liquids (e.g., fuel and oil) to designated upland areas.

13. Avoid contamination of ground and surface waters by storing concrete wash water in open containers and frequently disposing of it on site by application as a binder to riprap areas. Avoid contamination of ground and surface waters by storing any water that has been contaminated (e.g., with maintenance materials, oils, equipment residue) in closed containers onsite until removed for disposal. In upland areas, storage tanks must be on-ground containers.

14. Avoid contamination of ground and surface waters by ensuring that water tankers that convey untreated surface water do not discard unused water where it has the potential to enter any aquatic or wetland habitat.

15. Cease work during heavy rains and do not resume work until conditions are suitable for the movement of equipment and materials.

16. Uncured concrete should not be allowed to enter the water.

17. Work should be done from the top of the bank or a floating barge, when practicable. Heavy equipment use within the active flowing channel should be avoided.

18. Floating dock components containing foam must be encapsulated to prevent the introduction of foam particles into the water.

19. For all in-water work in streams, sediment barriers would be used to avoid downstream effects of turbidity and sedimentation.

20. Do not pressure wash more than the area to be painted or treated (e.g., for graffiti removal) each day.

21. If the purpose of cleaning is for graffiti removal, spot clean, steam clean or scrape dirty areas rather than pressure washing entire sections of fence or levee wall.

22. Operate pressure-washing equipment according to manufacturer’s recommendations.

23. Except for emergency repairs required to protect human life, limit work within drainages to dry periods to reduce effects on downstream water quality.

24. Rip-rap should be placed on a layer of geo-textile fabric to prevent underlying sediment from being washed out through the openings of the rip-rap.

25. Rip-rap should be keyed into the wash/streambed to ensure its stability and effectiveness.

Air Quality

1. Good modern practices for earth moving/excavating activities would be implemented. These include using approved dust suppressants or adhesive soil stabilizers, paving, covering, landscaping, continuous wetting, or detouring maintenance and repair areas, barring access to maintenance and repair areas, or other acceptable means of reducing significant amounts of airborne dust. All Federal, state, county, and local ordinance would be adhered to during maintenance and repair of tactical infrastructure.

Noise

1. All Occupational Safety and Health Administration requirements would be followed with respect to maintenance and repair noise impacts. Ensure all motorized equipment possess properly working mufflers and are kept properly tuned to reduce backfires. Ensure all motorized generators will be in baffle boxes (a sound-resistant box that is placed over or around a generator), have an attached muffler, or use other noise-abatement methods in accordance with industry standards. For activities involving heavy equipment, seasonal restrictions might be required to avoid impacts on threatened or endangered species in areas where these species or their potential habitat occur. See species-specific BMPs.

Cultural Resources

1. If human remains are discovered during maintenance and repair of tactical infrastructure, CBP will adhere to the stipulations of Public Resources Code Section 5097.98 and Health and Safety Code 7050 and stop work within 15 meters (50 feet) of the discovery. CBP will then contact the county coroner and a professional archaeologist that meets the Secretary of the Interior’s Professional Qualifications Standards in archaeology or history to determine the significance of the discovery. If appropriate, CBP would also adhere to Native American Graves Protection and Repatriation Act (NAGPRA) and its implementing regulations (43 CFR 19). Depending on the recommendations of the coroner or the archaeologist, CBP will consult with culturally affiliated tribes and the California State Historic Preservation Officer regarding their management and disposition in compliance with NAGPRA.

2. Obtain all pertinent training materials for cultural resources for the areas where maintenance and repair activities would occur. Prior to arrival on the work site, ensure key personnel are aware of the cultural resources potentially occurring in the project area and understand the proper BMPs to implement should cultural resources be encountered in the project area.

Roadways and Traffic

Hazardous Materials and Waste Management

1. Where hazardous and regulated materials are handled, workers should collect and store all fuels, waste oils, and solvents in clearly labeled closed tanks and drums within a secondary containment system that consists of an impervious floor and bermed sidewalls capable of containing the volume of the largest container stored therein.

2. All paints and cleaning materials should be approved by the appropriate land manager.

3. Use a ground cloth or an oversized tub for paint mixing and tool cleaning. Properly dispose of the wastes.

4. Enclose spray-painting operations with tarps or other means to minimize wind drift and to contain overspray.

5. Clean paintbrushes and tools covered with water-based paints in sinks plumbed to a sanitary sewer or in portable containers that can be dumped into sanitary sewer drains. Never clean such tools in a natural drainage or over a storm drain.

6. Brushes and tools covered with non-water-based paints, finishes, thinners, solvents, or other materials must be cleaned over a tub or container and the cleaning wastes disposed of or recycled at an approved facility. Never clean such tools in a natural drainage or over a storm drain.

7. If maintenance activities would continue at night, direct shielded light only onto the area required for worker safety and productivity. Lights would not exceed 1.5-foot candles within the lit area.

8. Implement proper and routine maintenance of all vehicles and other maintenance equipment such that emissions are within the design standards of all maintenance equipment.

9. Use water-based paints instead of oil-based paints. Look for the words “Latex” or “Cleanup with water” on the label. Do not rinse into natural drainages (e.g., creeks, irrigation canals, wetlands) or storm drains.

10. Do not use paints more than 15 years old. They could contain toxic levels of lead.

11. Use ground or drop cloths underneath painting, scraping, sandblasting, and graffiti removal work. Properly dispose of the waste and scraps collected on the drop cloth.

12. Minimize site disturbance and avoid attracting predators by promptly removing waste materials, wrappers, and debris from the site. Any waste that must remain on site more than 12 hours should be properly stored in closed containers until disposal.

Socioeconomic Resources, Environmental Justice, and Protection of Children No BMPs were identified for socioeconomic resources, environmental justice, or the protection of children.