11 Maintenance Operations
New construction designs should consider combining storage, mixing, and washing operations in an integrated chemical management system. For existing facilities, updating these areas does not necessarily require a new building as many changes can be easily made. Information specific to pesticide storage and handling can be found in the “Pesticide Management” chapter of this document.
BMP Principles for Maintenance Operations
- Assess potential point source pollution risk for maintenance operations.
- Ensure compliance with regulatory requirements designed to prevent point source pollution.
- Manage organic and inorganic waste to minimize potential point source pollution.
11.1 Regulatory Considerations
Every golf course has a central area for the maintenance and storage of equipment and supplies. These areas can potentially become point sources of pollution because of unintended releases of chemicals such as pesticides, fertilizers, or fuel during storage or handling of these materials. Containment measures in these areas can easily prevent chemicals from becoming point sources of pollution.
11.1.2 New Maintenance Facilities Siting and Planning
The New York State Department of Health does not allow chemical storage or mixing and loading facilities within 100 feet of a potable well. Other requirements include local zoning for the siting of maintenance facility and operations, which vary by city and county. Requirements often include a minimum distance (set-back) from wetlands, surface wells, and property lines.Â The state’sÂ Freshwater Wetlands ActÂ requires a 100-foot buffer around wetlands. Some townships have even broader requirements.
Local building inspectors should be consulted during planning for new facilities to outline the permitting process and local requirements. Also, consider meeting with a representative from a NYSDEC regional office and the local fire marshal. The NYSDEC requests a State Environmental Quality Review (SEQR) for new construction, which is administered by local governments. NYSDEC comments on SEQR, as do other interested and involved agencies.
11.1.3 Chemical Storage
The NYSDEC currently offers guidelines for chemical storage and mixing and loading operations, as detailed later in this chapter. While there are currently only guidelines, regulations are in the process of being drafted. Please monitor the NYSBMP website for more information on the potential changes.
11.1.4 Backflow Prevention Devices
NYSDEC regulations require the use of Backflow Prevention Devices when public water is used with pesticide application equipment.
11.1.5 Hazardous Wastes
Some of the wastes generated in maintenance facilities must be handled as hazardous wastes. Examples of wastes that may be generated at a golf facility include, but are not limited to, the following:
- parts wash solvents
- waste gasoline
- cleaning materials
- waste oil
- lead-acid batteries
- aerosol cans
- spent fluorescent bulbs
- unusable pesticides and inner bag liners
- unusable herbicides and inner bag liners
A waste is a hazardous waste if it exhibits a specific characteristic (ignitability, corrosivity, reactivity, toxicity) or if it is included in any of the four specifically listed categories of hazardous waste. Many waste fluorescent lamps are hazardous wastes due to their mercury content. Other examples of lamps that, when spent, are commonly classified as hazardous waste include: high-intensity discharge (HID), neon, mercury vapor, high pressure sodium, and metal halide lamps.
USEPA issued the Universal Waste Rule in 1995 to streamline compliance with hazardous waste regulations. This rule is designed to reduce the amount of hazardous waste in the municipal solid waste stream, to encourage the recycling and proper disposal of some common hazardous wastes and to reduce the regulatory burden on waste generators. Universal wastes include such items as hazardous batteries, hazardous mercury-containing thermostats, certain pesticides, and hazardous lamps. Although handlers of universal wastes must meet less stringent standards for storing, transporting, and collecting wastes, the wastes must comply with full hazardous waste requirements for final recycling, treatment, or disposal.
Therefore, every golf club is responsible (and liable) for the safe handling of the product and for the proper waste disposal by a reputable waste removal service. These services should be certified and bonded for transporting your waste to similarly accredited processing centers.
11.1.6 Petroleum Storage
NYS has regulations for above and below ground storage of fuel and fuel oil in Part 613 of the Environmental Conservation Law. Every facility manager should review this regulation carefully. The regulations require daily inspection logs be kept, as well as annual inspections. Counties and cities may also have their own fuel storage regulations.
11.2 Design and Operation
New construction designs should consider combining storage, mixing, and washing operations in an integrated chemical management system. Buildings and infrastructure should be designed to account for the traffic and usage. The resulting design will provide a much better envelope of the operations compared with separately constructed areas. Integrated designs often include fuel storage and filling stations within the same containment areas. For existing facilities, updating these areas does not necessarily require a new building asÂ many changes can be easily made. Information specific to pesticides storage and handling can be found in theÂ “Pesticide Management” chapter of this document.
The goal of an ideal storage facility is the safe siting and storage of potential contaminants that ensures a high level of water quality protection. Modular or independent containment units can be installed in many sizes. The units are typically self-contained, fireproof, and secure and can be temperature controlled with ventilation. Options for such units include fire suppression, eye washes, and safety showers. Floor drains should include a sump and a chemical pump to move the chemicals discharged to a waste tank as in the figure below. The material can be reclaimed, diluted to label concentrations, and applied to turf areas or collected for disposal using certified hazmat haulers.
Below are NYSDEC guidelines for pesticide storage which can be applied to the storage of all chemicals. With respect to the storage of pesticides specifically, the pesticide label is the law and all pesticides should be stored according to instructions on their labels. In addition to the label, Part 326.11 of the New York Codes, Rules and RegulationsÂ states:Â “No person shall store any restricted pesticide or empty containers thereof in such a manner as may be injurious to human, plant or animal life or to property or which unreasonably interferes with the comfortable enjoyment of life and property throughout such areas of the State as shall be affected thereby.” Pesticide storage areas should be designed and managed in a manner that prevents or minimizes the risk of injury, harm to the environment or any impact on the use or value of property.
Guidelines are as follows:
- Storage facilities should be structurally separate from residential, office and general work areas; livestock quarters, food, feed or seed storage and water supply sources.
- Storage should be in separate buildings and at least 50 feet away from residential or farm property. Fencing is currently not stipulated but could be considered as an added precaution.
- Storage areas should have a raised berm on all sides and an impervious surface for containment.
- Facilities should be equipped with spill containment material and fire extinguishers. Suggested spill containment material includes absorbent spill containment pads, sweeping compound, brushes or brooms, a dust pan, a shovel, and a disposal container or bag.
- PPE should be available near but not within the storage area.
- The storage facility should be locked and properly posted with warnings.
- Annual updates should be provided to the local fire department and include a “Fire and Spill Response Plan.” Additional precautions might include provisions of the National Fire Protection Association codes.
- Chemicals should be segregated by function (e.g. fungicide, insecticide, and herbicide) and hazard level. All flammable and “incompatible” materials should be stored separately.
- Mixing areas should be similarly bermed with impervious surfaces.
- Indoor mixing areas should be properly vented.
- Bulk containers, construed to be equal to or greater than 55 gallons, should be locked. Drains should be used to collect any spills into a containment area. The spill containment system should have a capacity equal to or greater than 25% of the volume of pesticides stored.
- A water supply and wash station are required at or adjacent to the facility for emergencies.
- A suitable first aid kit for pesticide poisoning should be nearby.
- Forced air vent systems capable of exchanging the air volume three to four times per hour should be considered, along with temperature control for keeping temperatures under 95Â° F and above freezing.
- Local fire departments should be made aware of the pesticides and fertilizers stored to help them prepare in the event of a fire.
Very old or inadequate storage areas may or may not be out of compliance, but consider planning for improvements to implement these guidelines over time. Updating chemical storage areas does not necessarily require a new building. Many changes can be made to meet guidelines, such as:
- impervious flooring
- flooring sloped to a drain
- curbing to contain at least 25% of the volume of liquid chemicals and fertilizers stored
- ventilation to exhaust any fumes in the event of a spill
- PPE for workers and emergency wash stations
11.2.2 Mixing and Loading
Mixing, loading, and washing areas should be well ventilated and should take place in contained areas that are bermed, have impervious surfaces, and roofed to prevent rainfall spreading pesticide residue. Pesticide storage and handling require additional considerations and are regulated by NYSDEC. See the Pesticide Use web page on the NYS BMP website for more information specific to mixing and loading of pesticides. In addition, pesticide labels provide information on required PPE that must be used during handling or use of pesticides. SeeÂ EPA’s PPE for Pesticide Handler’s web pageÂ for more information.
Precautions should be in place to effectively respond to emergencies, such as the availability of proper PPE, spill response kits, and emergency wash stations. When mixing or loading, caution should be used and labels carefully reviewed to ensure that chemicals mixed together are compatible. Water used for mixing should be tested for pH to ensure that tank mixes do not expire prematurely due to alkaline hydrolysis.Â NYSDEC regulations require the use of Backflow Prevention Devices when public water is used.
11.3 Waste Management
Pesticide containers must be cleaned and disposed of or recycled properly. Procedures typically include triple rinsing nonflammable containers and either returning cleaned empty containers to the vendor or properly sealing and disposing of them in a sanitary landfill. Rinsate may be re-applied to turfgrass consistent with instructions on the label. Unused pesticides must be disposed of in accordance with state regulations, such as by returning to the supplier or disposing at an approved hazardous waste facility.
11.3.2 Lubricants, Greases, Paints, and Solvents
Lubricants, greases, paints, and solvents should be stored appropriately, typically in fireproof enclosures, separately from pesticides and fertilizers. Special cleaning stations are commercially available that contain and recycle solvents and degreasers.
In addition to any handling precautions specified on the product label or SDS sheet, added steps should be taken to prevent and contain any spills. Spills should be cleaned up using approved dry absorbents. Contaminated material should be stored in containers specially marked as hazardous waste and disposed of using licensed waste haulers and hazmat processors.
11.3.3 Organic Waste and Wastewater
The release of organic waste, such as grass clippings, associated with equipment cleaning needs the same level of protection afforded liquid and granular nutrients and pesticides. When debris is removed from equipment, it should not be released into open surface water or in a location near well heads or shallow groundwater. Often, effective equipment cleaning areas can be maintained as mixing and loading areas with impervious flooring and drains that allow for some separation of organic solids and liquids.
When using a simple wash-pad and collection area, the wash-water should be dispersed along the land, preferably along a designed bio-filtration system. Closed system cleaning stations are available that separate clippings/solids and treat the washwater. The recycled water is reused as washwater. Another approach to wastewater treatment uses microbes to break down chemical compounds. Both types of systems may require additional purification steps to remove odors and harmful bacteria. These systems must be carefully sized to process the peak water volume anticipated for contaminant levels expected. The equipment varies in costs but increases with structural requirements and permits. Two NYS BMP case studies provide more information of two types of equipment washing areas: Wash Load at Bedford Golf and Tennis Club and Opportunities for Improvement of Wash Pad Operations.
Nutrient BMPs recommend that clippings be widely redistributed to turf. Research has shown that nitrate levels in leachate increased to as much as 30 mg/L in areas that received four times the normal clippings return. Some clubs elect to collect clippings from fairways and then dump these clippings as yard waste. The accumulation of clippings and other yard wastes such a leaves, tree limbs, and other plant debris can be a substantial source of contamination to surface water and groundwater if placed close to water courses.
Clippings should be screened and collected when cleaning equipment in the maintenance area. They should not be allowed into the stream of wastewater. The inherent concentration of organic nitrogen and phosphorus, along with any pesticide residues, can contaminate the wastewater or reduce the effectiveness of wastewater treatment equipment. Ideally, clippings should be blown off using compressed air and then collected. If water is being used, sumps should screen and convey clippings and other solids prior to wastewater disposal or treatment. Many clubs have contracted with local composting companies to haul their organic waste. Material is generally accumulated in dumpsters and then frequently removed.
11.4 Emergency Management
Planning and preparations should be made for potential emergencies. Local emergency personnel such as local fire departments should be consulted, be notified about the locations of pesticide and fertilizer storage, and be given regularly updated lists of chemicals stored. Storage areas should be properly placarded. Training and orientation should also be conducted with employees to review plans and preparations.
New York State responds to reports of petroleum and other hazardous material releases through the Spill Response Program maintained by the NYSDEC. Spill response staff throughout the state investigate such spill reports and take action based on the type of material spilled, potential environmental damage, and safety risks to the public. Releases to the environment should be reported to the NYSDEC Spills Management Hotline at 1-800-457-7362. See the Chemical and Petroleum Spills web page on the NYSDEC websiteÂ for more information on reporting of spills.
Safety Data Sheets (SDS)
The Hazard Communication Standard (HCS) (29 CFR 1910.1200(g), revised in 2012, requires that the chemical manufacturer, distributor, or importer provide SDS for each hazardous chemical to users to communicate information on these hazards. More information on SDS can be found on the Hazard Communication Standard: Safety Data Sheets web page of the OSHA website.
An up-to-date file should be maintained with copies of all the SDS reports for all chemicals used, stored on the property, and made available to employees. Copies of these files can be provided to local fire departments and hospitals in case of any emergency.
Adequate provisions should be provided to immediately treat any person exposed to chemicals. These include eye wash stations and showers. First aid kits should be available to treat skin contact, ingestion, or inhalation.
Cornell’s Occupational and Environmental Health Department (OEHD) in the College of Agricultural Sciences has guidelines that can be used a template for spill management:
- Evacuate personnel from the immediate area of the spill.
- Control the spill. Do not endanger yourself. To the extent possible, shut off the source and block the flow.
- Call 911 if:
- anyone is injured
- the spill is too large for a local clean up
- the spill migrates off-site
- the spill threatens the health and safety of anyone
- Identify the spilled material(s).
- Barricade the area and notify others in surrounding areas not to enter the spill area.
- Wait for help to arrive.
Spill kits can be used for incidental releases. Follow these procedures:
- Consult the appropriate SDS and label (for pesticides).
- Wear the appropriate PPE.
- Contain the spill. Prevent spread or escape from the area by using sorbents.
- Clean up the spill. Never hose down an area until the cleanup is completed.
To clean up pesticides:
- Recover as much product as possible in a reusable form. Store and use as intended. Recover the rest of the product as a waste product by using an absorbent or sweeping compound.
- When all recoverable material is secured, clean contaminated surface residues using triple-rinse technique. For instance, a spill of liquid on the floor requires that the area be damp-mopped three times.
To clean up all other chemicals:
- Small liquid spills can be cleaned up with a commercially available absorbent. Avoid using paper towels; they increase the surface area and the rate of evaporation, increasing the fire hazard.
- For acid or base spills, use a sorbent that will neutralize the liquids (trisodium phosphate, sodium bicarbonate, or other commercially available products).
- Use a dustpan and brush to sweep up the absorbed spill. Wash the contaminated area with soap and water.
11.5 Maintenance Operations Best Management Practices
Storage and Handling of Chemicals
- Post warning signs on chemical storage buildings, and especially near any entry or exit areas.
- Storage facilities must be secured and allow only authorized staff to have access.
- Pesticide and fertilizer storage areas should preferably be located away from other buildings.
- Floors should be sealed with chemical-resistant paint.
- Floors should have a continuous sill to help contain any spills.
- Shelves should be made of plastic or reinforced metal. Metal shelving should be coated with paint to avoid corrosion. Wood should not be used due to its ability to absorb spilled chemicals.
- Exhaust fans and an emergency wash station should be provided.
- Light and fan switches should be exteriorly installed to illuminate and ventilate the building.
- Store chemicals in original containers.
- Store chemicals so that the label is clearly visible. Loose labels should be refastened.
- Store flammable chemicals separately from non-flammable chemicals.
- Store liquid materials below dry materials to prevent contamination from a leak.
- Use regulatory agency-approved, licensed contractors for the disposal of chemicals.
- Provide adequate staff training pertaining to the risks and liabilities of chemical storage and use.
- Train staff and other management on how to access and use the facility’s SDS database.
- Maintain accurate inventory lists.
- Brush or blow off accumulated grass clippings from mowing equipment using compressed air before washing.
- Wash equipment on a concrete pad or asphalt pad that collects the water. After the collected material dries, collect and dispose of it properly.
- Washing areas for equipment not contaminated with pesticide residues should drain into oil/water separators before draining into sanitary sewers or holding tanks.
- Do not wash pesticide application equipment on pads with oil/water separators. Do not wash near wells, surface water, or storm drains.
- Do not wash mowing equipment on a pesticide mixing and loading pad. This keeps grass clippings and other debris from becoming contaminated with pesticides.
- Use spring-loaded spray nozzles to reduce water usage during washing.
- Minimize the use of detergents. Use only biodegradable, non-phosphate detergents.
- Use non-containment washwater for field irrigation.
- Do not discharge non-contaminated wastewater during or immediately after a rainstorm, since the added flow may exceed the permitted storage volume of the stormwater system.
- Do not discharge washwater to surface water, groundwater, or susceptible/leachable soils either directly or indirectly through ditches, storm drains, or canals.
- Never discharge to a sanitary sewer system without written approval from the appropriate entity.
- Never discharge to a septic tank.
- Solvents and degreasers should be used over a collection basin or pad that collects all used material.
Equipment Storage and Maintenance
- Store equipment in areas protected from rainfall. Rain can wash residues from equipment and potentially contaminate the surrounding soil or water.
- Perform equipment maintenance activities in a completely covered area with sealed impervious surfaces.
- Drains should either be sealed or connected to sanitary sewer systems with the approval of local wastewater treatment plants.
- Solvents and degreasers should be stored in locked metal cabinets away from any sources of open flame.
- Complete a chemical inventory and keep SDS of each on-site. A duplicate set of SDS should be kept in locations away from the chemicals, but easily reached in an emergency.
- Use PPE when working with solvents.
- Use containers with dates and contents clearly marked when collecting used solvents and degreasers.
- Above-ground storage tanks (ASTs) for fuel are preferred as they are more easily monitored for leaks as compared with underground storage tanks (USTs).
- Fueling stations should be located under roofed areas with concrete pavement whenever possible.
- Fueling areas should also have spill containment and recovery facilities located near the stations.
- Develop a record-keeping process to monitor and detect leakage in USTs and ASTs.
- Visually inspect any AST for leakage and structural integrity.
- Secure fuel storage facilities and allow access only to authorized and properly trained staff.
- Label containers for collecting used solvents, oils and degreasers.
- Recycle lead-acid batteries. If not recycled, batteries are classified as hazardous waste.
- Store old batteries on impervious surfaces in areas protected from rainfall.
- Recycle used tires, paper products, plastic or glass containers, aluminum cans, and used solvents, oils, and degreasers.
- Provide a secure and specifically designated storage for the collection of recyclable waste products.
- Recycle or properly dispose of light bulbs and fluorescent tubes.
- Develop a facility emergency response plan that outlines the procedures to control, contain, and clean up spilled materials.
- Train all employees on the emergency response plan and emergency procedures.
- Keep an appropriate spill containment kit in a readily available space.
- For small liquid spills, use absorbents such as cat litter or sand and apply as a topdressing in accordance with the label rates, or dispose of as a waste.
- For small solid spills, sweep up and use as intended.
- Ensure that SDS documents are present and that all employees have been properly trained on their location and contents.
- Report releases to the NYSDEC Spills Management Hotline at 1-800-457-7362 when required.
- For larger spills, follow guidance from the NYSDEC and CHEMTREC for cleanup and disposal.