MVA-Environmental-Handbook.pdf

Environmental Handbook For Contractors

August 31, 2020

Office of Planning and Capital Programs 6601 Ritchie Highway, N.E., Rm. 223

Glen Burnie, MD 21062

MDOT MVA | Office of Planning & Capital Programs (OPCP)

Table of Contents

1.0 INTRODUCTION

2.0 CHEMICAL SUBSTANCES

2.1 General

2.2 Refrigerants

2.3 Asbestos

3.0 HAZARDOUS WASTE

3.1 Aerosol Cans & Their Contents

3.2 Capacitors

3.3 Lead and Oil-Based Paints

3.4 Hazardous Waste Containers

3.5 Hazardous Waste Manifests

3.6 Unidentified Waste Drums

4.0 UNIVERSAL WASTE

4.1 Batteries

4.2 Pesticides

4.3 Mercury-Containing Equipment

4.4 Used Lamps and Bulbs

4.5 PCB Ballasts

5.0 NON-HAZARDOUS WASTE

6.0 SPILL RESPONSE

6.1 Spill Prevention, Control, and Countermeasure (SPCC)

6.2 How to Control an Oil Spill

6.3 How to Control Other Non-Oil Spills

7.0 STORMWATER POLLUTION PREVENTION

7.1 General Practices and Compliance

7.2 Illicit Discharge Detection

8.0 WASTEWATER

ATTACHMENT “A” – CONTRACTOR ACCEPTANCE

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1.0 INTRODUCTION

The Maryland Department of Transportation Motor Vehicle Administration (MDOT MVA) is committed to the protection and enhancement of the environment, as detailed by the MDOT MVA Environmental Policy and Mission Statements (attached herewith), as well as Compliance Focused Environmental Management System (CFEMS) Policy #41000-

002. These documents highlight MDOT MVA’s reliance on both its CFEMS and the following seven elements to support MDOT MVA’s environmental protection and sustainability of all natural resources: (1) management commitment, (2) employee commitment, (3) compliance, (4) planning, (5) sustainability, (6) communication, and (7) continuous improvement.

As part of MDOT MVA’s commitment to compliance and continuous improvements, this Handbook is provided as an environmentally responsible guideline for all Contractors working at MDOT MVA including the Glen Burnie Headquarters, all 24 branch locations, and 18 Vehicle Emission Inspection Program (VEIP) stations. MDOT MVA developed this Handbook to identify some of the environmental impacts, responsibilities, and regulatory requirements Contractors have while working at MDOT MVA facilities.

All Contractors and Subcontractors must return a signed copy of Attachment A:

Contractor Acceptance to MDOT MVA prior to the initiation of any work at any MDOT MVA facility. Contractors are responsible for providing all of their subcontractors with a copy of this Handbook. Contractors are responsible for overseeing their employees’ and their subcontractors’ adherence to this Handbook and all applicable regulations.

While performing work for the MDOT MVA, it is the responsibility of the Contractor to be in compliance with all applicable Federal, State, and local regulations, including all environmental regulations and all site-specific environmental permits.

This manual is GUIDANCE only and does not constitute definitive legal opinion. The relevant regulations should always be consulted and, in case of doubt, legal opinion should be sought.

For any questions or concerns related to the contents of this Handbook, all MDOT MVA Contractors shall contact the Office of Planning and Capital Programs (OPCP):

Maryland Department of Transportation Motor Vehicle Administration

Office of Planning and Capital Programs 6601 Ritchie Highway, N.E., Room 223

Glen Burnie, Maryland 21062 Phone: 410-762-5144 | Fax: 410-768-7266 MVAEnvironmental@mdot.state.md.us

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2.0 CHEMICAL SUBSTANCES

2.1 General

For any chemical, chemical compound or chemical mixture brought onto MDOT MVA property by a Contractor or used by a Contractor while on MDOT MVA property, the Contractor is responsible for possessing and reviewing the Safety Data Sheet (SDS) for that chemical substance. The Contractor must adhere to the safety and Personal Protective Equipment (PPE) requirements from the SDS and follow all handling and disposal requirements.

2.2 Refrigerants

Contractors handling air conditioning or refrigerant appliances at any MDOT MVA site must comply with all applicable regulations, including but not limited to 40 CFR Part 82, Subpart F – Protection of Stratospheric Ozone, Recycling and Emissions Reduction. All Contractors who perform work on air conditioning and refrigerant appliances at MDOT MVA must possess valid United States Environmental Protection Agency (EPA) certification per 40 CFR Part 82. Such work at MDOT MVA may include adding refrigerant to new or existing systems, recycling refrigerant, repairing leaks or other general service needs to the appliances.

For facilities with air-conditioning equipment that contain circuits with a refrigerant charge greater than fifty (50) pounds, EPA requires that any leaks are repaired within thirty (30) days of the discovery of the leak when those leaks result in the loss of fifteen

(15) percent or more of the charge over a year. In addition, detailed recordkeeping of all work must be maintained. Contractors performing service or maintenance on equipment that contain circuits with a refrigerant charge greater than fifty (50) pounds shall:

provide a record of the quantity of refrigerant added to the equipment during all servicing and maintenance procedures;

notify FM&E within 24-hours should any leaks be discovered;

provide MDOT MVA with a calculation of the current leak rate projected over a consecutive 12-month period if a leak is discovered; and, maintain all other records as required by 40 CFR Part 82.

To determine whether an MDOT MVA site has greater than fifty (50) pounds of refrigerant on site in an individual circuit, Contractors shall contact FM&E prior to initiating any work on air conditioning equipment.

2.3 Asbestos

In compliance with Maryland Executive Order 01.01.1987.22, all MDOT MVA owned buildings have been inspected by an accredited asbestos inspector. Samples were taken and analyzed to confirm the presence or absence of asbestos containing material (ACM). Upon confirmation of the presence of ACM, an Asbestos Management Plan

MDOT MVA | Office of Planning & Capital Programs (OPCP) Page 5 was developed to provide information on the periodic monitoring of the condition of ACM remaining in our buildings through re-inspections and periodic surveillance.

Before Contractors start work at MDOT MVA facilities, the MDOT MVA will inform the Contractor on the presence and location of any known ACM located in the work area. If the tasks of the Contractor will disturb or demolish the ACM, the Contractor is required to notify the MDOT MVA FM&E prior to proceeding with any work. In the case that any ACM is disturbed at ANY point in the course of completing a task, the Contractor is required to IMMEDIATELY stop work and contact MDOT MVA FM&E.

If the Contractor is a certified asbestos abatement firm, and their tasks are related to asbestos removal and abatement, all abatement work is to proceed in compliance with 40 CFR Part 763, COMAR 26.11.23, and any other applicable Federal, State and local regulations. MDOT MVA has developed an abatement oversight checklist which will be provided to the Contractor prior to abatement activities. The Contractor is required to review and sign the checklist prior to, and at the completion of the abatement work.

3.0 HAZARDOUS WASTE

Hazardous waste is a solid waste that the United States Environmental Protection Agency (EPA) has defined as a specifically “listed waste” or a solid waste that displays any of the following four (4) characteristics: (1) ignitability, (2) corrosivity, (3) reactivity, or (4) toxicity. This section details common hazardous wastes that may be generated during Contractor operations at MDOT MVA facilities; however, the noted wastes should not be considered a complete list of all potential wastes at MDOT MVA.

Contractors must manage all hazardous waste storage, handling, and disposal in accordance with all applicable regulations, including, but not limited to:

29 CFR 1910 Subpart H – Hazardous Materials;

COMAR 26.13 – Disposal of Controlled Hazardous Substances; and, 40 CFR 260-265 – Resource Conservation and Recovery Act.

For hazardous wastes generated through Contractor activities at MDOT MVA sites, the Contractor is considered a co-generator of the waste. The Contractor shall perform all duties required of a waste generator and is required to notify MDOT MVA of any hazardous waste generating activities. The Contractor is responsible for all hazardous waste generator responsibilities, including required recordkeeping, and will ensure that all generator responsibilities are being performed properly in accordance with all applicable regulations. This handbook sets forth the mutual agreement between MDOT MVA and the Contractor that the Contractor shall perform all generator duties and keep MDOT MVA informed of all hazardous waste generating activities.

Contractors are responsible for performing hazardous waste determinations for all wastes that are generated as a result of their activities. Copies of all hazardous waste determinations, including analytical results, shall be provided to the Office of Planning and Capital Programs as they are generated.

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Contractors are not permitted to place any hazardous waste in MDOT MVA solid waste containers.

Contractors shall contact the MDOT MVA Office of Planning and Capital Programs with any questions regarding proper disposal for hazardous wastes.

3.1 Aerosol Cans & Their Contents

An aerosol can is a container in which gas under pressure is used to aerate and dispense liquid through a valve as a spray or foam.

The Contractor is responsible for the proper disposal of all aerosol cans and their contents. Unused contents from the aerosol container can be considered hazardous.

Contractors must remove all full, partially full and empty aerosol cans from the MDOT MVA site when contracted activities have been completed.

3.2 Capacitors

If a capacitor is labeled as PCB-containing or if the capacitor does not have the label indicating “No PCBs,” the Contractor shall treat and dispose of the used capacitor as a hazardous waste. See section 4.0 below for information on universal wastes, including PCB-Containing Lamp Ballasts.

3.3 Lead and Oil-Based Paints

Contractors must dispose of waste lead and oil-based paints properly, as these waste paints can be considered hazardous wastes. Only completely clean and empty paint cans and containers can be disposed of as solid wastes.

Contractors shall notify MDOT MVA FM&E of any unused paints prior to characterizing them as hazardous wastes. MDOT MVA may wish to retain the unused paint for future projects or repairs to the painted area.

3.4 Hazardous Waste Containers

If it is necessary to temporarily store hazardous waste on MDOT MVA property as generated by the Contractor through the course of their contracted activities, the Contractor shall contact the Office of Planning and Capital Programs for permission to store the waste prior to doing so. The Contractor is responsible for supplying all containers, labels, secondary containment, and other materials in order to ensure compliance with applicable regulations.

Hazardous wastes must be properly stored in closed containers while on MDOT MVA property. All containers shall be appropriately identified with “Hazardous Waste” labels, which clearly indicate the specific contents of the container and the waste collection start date for the container. Contractors are required to ensure that all containers used for storing hazardous waste are in good condition, with lids that properly seal.

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Contractors shall properly store any hazardous waste containers within appropriate secondary containment. The Contractor shall ensure proper disposal and removal of any containers containing hazardous wastes prior to the completion of Contractor’s task.

3.5 Hazardous Waste Manifests

Hazardous waste manifests shall be completed for off-site shipment and disposal.

Contractors are required to coordinate the completion of all hazardous waste manifests with the MDOT MVA Office of Planning and Capital Programs.

3.6 Unidentified Waste Drums

Should the Contractor discover an unidentified drum containing an unknown waste, the Contractor must contact the MDOT MVA Office of Planning and Capital Programs.

4.0 UNIVERSAL WASTE

The US EPA has regulations to address “universal wastes,” which are widely generated wastes including batteries, waste pesticides, mercury containing equipment, and used lamps/bulbs. Contractors are responsible for reviewing and understanding the requirements for handling, storing, and disposing of universal wastes, as well as any PPE required for handling universal wastes. Universal waste storage, handling, and disposal must be managed in accordance with the following regulations:

40 CFR 273: Standards for Universal Waste Management;

40 CFR 273.2: Applicability – Batteries;

40 CFR 273.3: Applicability – Pesticides;

40 CFR 273.4: Applicability – Mercury-containing Equipment;

40 CFR 273.5: Applicability – Lamps;

COMAR 26.13.10.06.: Scope – Standards for Universal Waste Management;

COMAR 26.13.10.07: Applicability – Batteries;

COMAR 26.13.10.08: Applicability – Pesticides; and, COMAR 26.13.10.09: Lamps, Mercury-Containing Equipment and PCB

Containing Ballasts.

Contractors may generate the following universal wastes at MDOT MVA facilities:

batteries, waste pesticides, mercury containing equipment, used lamps and bulbs, and PCB-containing ballasts. Contractors are responsible for storing universal wastes in Contractor-provided universal waste containers with fitting lids. All containers must be properly labeled with the contents and the accumulation start date. All universal wastes must be removed by the Contractor from the site prior to completion of their task.

Contractors are not permitted to place any universal wastes in MDOT MVA solid waste containers. The Contractor is required to properly recycle all universal wastes.

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4.1 Batteries

Batteries that are considered universal wastes include, but are not limited to, nickel-cadmium, lead acid, and lithium batteries. All universal waste batteries must be removed from the MDOT MVA site by the Contractor according to all applicable regulations.

Alkaline batteries including AA, AAA, C, D, and 9V batteries are not considered universal waste. It is MDOT MVA policy to recycle alkaline batteries. Contractors are also encouraged to recycle spent alkaline batteries.

4.2 Pesticides

Once a pesticide is discovered and a decision has been made to discard the pesticide, the pesticide is considered a universal waste. The Contractor shall handle all waste pesticides according to the applicable universal waste regulations.

Pesticides application on MDOT MVA sites are only permitted for the Maryland Department of Agriculture certified or registered pesticide applicators. The certified/registered applicators must follow all Federal, State and local requirements for applying pesticides and disposing of waste pesticides.

4.3 Mercury-Containing Equipment

Mercury-containing equipment to be handled as a universal waste can include thermostats, mercury switches and relays, gas flow regulators, and water meters and other potential materials. Contractors must properly recycle universal waste mercury-containing equipment.

Mercury that has been removed from equipment cannot be handled as universal waste.

Contractors shall properly dispose of these materials as hazardous waste.

4.4 Used Lamps and Bulbs

Used lamps and bulbs that are generated through the course of any Contractor project must be handled as universal waste by the Contractor in accordance with all Federal and State regulations. Universal Waste lamps include, but are not limited to, fluorescent, high intensity discharge, neon, mercury vapor, high pressure sodium, and metal halide lamps or bulbs. Broken lamps/bulbs must be immediately swept up and may need to be handled as a hazardous waste. Do not use a standard vacuum cleaner. Place materials in a closed container to avoid generating dust.

4.5 PCB Ballasts

PCB-ballasts that are generated through the course of any Contractor project must be handled as universal waste by the Contractor in accordance with all Federal and State regulations. Contractors shall manage and recycle the universal waste PCB ballasts.

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It is MDOT MVA policy to recycle non-PCB ballasts. Contractors are encouraged to recycle non-PCB ballasts.

5.0 NON-HAZARDOUS WASTE

Contractors may generate non-hazardous wastes during their work at MDOT MVA.

Non-hazardous wastes may include used oil, fuel filters, gasoline filters, diesel and oil filters, used anti-freeze, recyclables, used absorbent materials, drums of non-hazardous waste, waste latex paints, and others. Contractors are responsible for performing a hazardous waste determination before deeming these items non-hazardous.

Contractors are exclusively responsible for the handling and disposal or recycling of all non-hazardous wastes which are generated through their work at MDOT MVA facilities.

Non-hazardous waste storage, handling, and disposal must be conducted in accordance with all applicable Federal, State and local regulations. Contractors are responsible for following MDOT MVA policy regarding all non-hazardous wastes and for disposing of all non-hazardous waste using a licensed waste transporter if required.

6.0 SPILL RESPONSE

6.1 Spill Prevention, Control, and Countermeasure (SPCC)

MDOT MVA has developed a Spill Prevention, Control and Countermeasure (SPCC) Plan for its Glen Burnie Headquarters facility. The SPCC Plan is implemented in accordance with the EPA regulations 40 CFR 112 as well as COMAR 26.10.01. The SPCC Plan dictates measures for the prevention and the control of spills of oil-related materials at MDOT MVA facilities. Oil is defined as, “oil of any kind or form, including, but not limited to: fats, oils, or greases of animals, fish, or marine mammal origin;

vegetable oils, including oils from seeds, nuts, fruits, or kernels; and, other oils and greases including petroleum, fuel oil, sludge, synthetic oils, mineral oils, oil refuse, or oil mixed with wastes other than dredged soil” (40 CFR 112.2).

The Contractor is required to comply with all aspects of the SPCC Plan. Contactors shall contact OPCP to review and understand the MDOT MVA SPCC Plan.

If a Contractor brings fifty-five (55) or more gallons of petroleum, oil or lubricants (POLs) onto the MDOT MVA Glen Burnie Headquarters facility grounds for any reason and for any length of time, the Contractor is required to notify the MDOT MVA Office of Planning and Capital Programs prior to bringing the POL on site. The Contractor must provide secondary containment and appropriate spill response equipment (e.g., booms, pads, absorbent) for the storage of the POLs.

6.2 How to Control an Oil Spill

Contractors are required to control a POL spill at any MDOT MVA facility in accordance with the guidelines from the SPCC Plan:

contractors must not place themselves or any other persons in danger when responding to any spill;

MDOT MVA | Office of Planning & Capital Programs (OPCP) Page 10 before proceeding with clean-up, Contractors shall wear appropriate PPE;

for any small quantity spills, Contractors are required to place absorbent materials from oil spill kits on the spill and shovel the absorbent mixture up into a labeled container for disposal; and, for any large quantity spills, Contractors are required to use equipment available and contain the spill or create a berm or dig a trench.

6.3 How to Control Other Non-Oil Spills

Contractors who handle any chemicals or potentially harmful materials while at an MDOT MVA facility are required to posses their own spill kit on site at all times. The Contractor’s spill kit must contain all necessary PPE for clean-up, appropriate booms and mats and approved containers for storage of spill response materials and equipment.

If a spill should occur, the Contractor shall follow the SWIMS spill countermeasure procedure, if possible:

Stop the leak – i.e., shut the open valve, shut off ventilation, shut off all ignition sources in the area, etc.

Warn others – employees shall immediately contact the MVA’s Office of Environmental Management (OEM) (See Contact Information at the end of this document, Page A-3).

Isolate – i.e., rope off the spill site or verbally tell others to stay back.

Minimize – employees shall make every effort to minimize their exposure, be sure to not touch any affected materials, and to stay upwind of the spill site.

Standby – stay near the spill site until spill responders arrive, and be available to assist if required.

7.0 STORMWATER POLLUTION PREVENTION

7.1 General Practices and Compliance

Any Contractor working at MDOT MVA shall be aware that with every precipitation event, sediment and existing pollutants on natural and paved surfaces can be transported into nearby storm drains. This potentially contaminated stormwater is then transported to surface waters, such as local streams and rivers, and potentially to the Chesapeake Bay. This stormwater run-off has the potential to impact both human and environmental health and safety.

All Contractors working at MDOT MVA facilities are required to maintain a work area that minimizes surface pollution and inhibits pollution of stormwater. MDOT MVA requires that Contactors maintain a workspace in compliance with all applicable stormwater and erosion and sediment control regulations and guidelines, including but not limited to the following:

Maryland Stormwater Management Guidelines for State & Federal Projects;

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Stormwater Management Regulations (COMAR 26.17.02);

Maryland Stormwater Design Manual (all volumes);

Maryland Erosion and Sediment Control Guidelines for State & Federal Projects;

Erosion and Sediment Control Regulations (COMAR 26.17.01); and, Standards and Specifications for Soil Erosion and Sediment Control.

According to the State regulations, Contractors shall not disturb more than 5,000 square feet or 100 cubic yards of earth (soil) at any MDOT MVA facility unless an Erosion and Sediment Control plan for the work has previously been reviewed and approved by the Maryland Department of the Environment. In the event that the Contractor anticipates disturbing more than 5,000 square feet or 100 cubic yards of soil, the Contractor shall notify MDOT MVA FM&E immediately.

7.2 Illicit Discharge Detection

MDOT MVA has an Illicit Discharge Detection and Elimination (IDDE) program as required by its status as an operator of a Phase II regulated Small Municipal Separate Storm Sewer System (MS4) under EPA’s National Pollutant Discharge Elimination System (NPDES). The program requires that MDOT MVA detect and eliminate any illicit discharges to the storm sewer system.

Contractors shall notify OPCP immediately in the event that an illicit discharge is discovered on any MDOT MVA site. Contractors shall be aware of MDOT MVA’s IDDE program and requirements and shall not cause any illicit discharges while on site.

EPA defines an illicit discharge as “any discharge to an MS4 that is not composed entirely of stormwater.” Source of illicit discharges can include, but are not limited to:

sanitary wastewater;

effluent from septic tanks;

car wash wastewaters;

improper oil disposal;

radiator flushing disposal;

laundry wastewaters;

spills from roadway accidents;

improper disposal of auto and household toxics; and, dumping into stormwater drains.

8.0 WASTEWATER

In accordance with Federal, State and local regulations, Contractors may not discharge into the waters of the State any waste or wastewater regardless of volume. Contractors must properly collect and dispose of any wastewater generated as a result of their activities. If wastewater will be generated as a result of their activities, Contractors shall contact the Office of Planning and Capital Programs for review and approval of the planned procedure for wastewater collection and disposal prior to performing the activity. At all times, Contractors must comply with all applicable wastewater regulations, including but not limited to COMAR 26.08 – Water Pollution.