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B. Construction Site Chemical Control

  1. Limit application, generation, and migration of toxic substances;
  2. Ensure the proper storage and disposal of toxic materials; and
  3. Apply nutrients at rates necessary to establish and maintain vegetation without causing significant nutrient runoff to surface waters.

1. Applicability

This management measure is intended to be applied by States to all construction sites less than 5 acres in area and to new, resurfaced, restored, and reconstructed road, highway, and bridge construction projects. This management measure does not apply to: (1) construction of a detached single family home on a site of 1/2 acre or more or (2) construction that does not disturb over 5,000 square feet of land on a site. (NOTE: All construction activities, including clearing, grading, and excavation, that result in the disturbance of areas greater than or equal to 5 acres or are a part of a larger development plan are covered by the NPDES regulations and are thus excluded from these requirements.) Under the Coastal Zone Act Reauthorization Amendments of 1990, States are subject to a number of requirements as they develop coastal NPS programs in conformance with this management measure and will have flexibility in doing so. The application of management measures by States is described more fully in Coastal Nonpoint Pollution Control Program: Program Development and Approval Guidance, published jointly by the U.S. Environmental Protection Agency (EPA) and the National Oceanic and Atmospheric Administration (NOAA) of the U.S. Department of Commerce.

2. Description

The purpose of this management measure is to prevent the generation of nonpoint source pollution from construction sites due to improper handling and usage of nutrients and toxic substances, and to prevent the movement of toxic substances from the construction site.

Many potential pollutants other than sediment are associated with construction activities. These pollutants include pesticides (insecticides, fungicides, herbicides, and rodenticides); fertilizers used for vegetative stabilization; petrochemicals (oils, gasoline, and asphalt degreasers); construction chemicals such as concrete products, sealers, and paints; wash water associated with these products; paper; wood; garbage; and sanitary wastes (Washington State Department of Ecology, 1991).

The variety of pollutants present and the severity of their effects are dependent on a number of factors:

  1. The nature of the construction activity. For example, potential pollution associated with fertilizer usage may be greater along a highway or at a housing development than it would be at a shopping center development because highways and housing developments usually have greater landscaping requirements.

  2. The physical characteristics of the construction site. The majority of all pollutants generated at construction sites are carried to surface waters via runoff. Therefore, the factors affecting runoff volume, such as the amount, intensity, and frequency of rainfall; soil infiltration rates; surface roughness; slope length and steepness; and area denuded, all contribute to pollutant loadings.

  3. The proximity of surface waters to the nonpoint pollutant source. As the distance separating pollutant-generating activities from surface waters decreases, the likelihood of water quality impacts increases.

a. Pesticides

Insecticides, rodenticides, and herbicides are used on construction sites to provide safe and healthy conditions, reduce maintenance and fire hazards, and curb weeds and woody plants. Rodenticides are also used to control rodents attracted to construction sites. Common insecticides employed include synthetic, relatively water-insoluble chlorinated hydrocarbons, organophosphates, carbamates, and pyrethrins.

b. Petroleum Products

Petroleum products used during construction include fuels and lubricants for vehicles, for power tools, and for general equipment maintenance. Specific petroleum pollutants include gasoline, diesel oil, kerosene, lubricating oils, and grease. Asphalt paving also can be particularly harmful since it releases various oils for a considerable time period after application. Asphalt overloads might be dumped and covered without inspection. However, many of these pollutants adhere to soil particles and other surfaces and can therefore be more easily controlled.

c. Nutrients

Fertilizers are used on construction sites when revegetating graded or disturbed areas. Fertilizers contain nitrogen and phosphorus, which in large doses can adversely affect surface waters, causing eutrophication.

d. Solid Wastes

Solid wastes on construction sites are generated from trees and shrubs removed during land clearing and structure installation. Other wastes include wood and paper from packaging and building materials, scrap metals, sanitary wastes, rubber, plastic and glass, and masonry and asphalt products. Food containers, cigarette packages, leftover food, and aluminum foil also contribute solid wastes to the construction site.

e. Construction Chemicals

Chemical pollutants, such as paints, acids for cleaning masonry surfaces, cleaning solvents, asphalt products, soil additives used for stabilization, and concrete-curing compounds, may also be used on construction sites and carried in runoff.

f. Other Pollutants

Other pollutants, such as wash water from concrete mixers, acid and alkaline solutions from exposed soil or rock, and alkaline-forming natural elements, may also be present and contribute to nonpoint source pollution.

Revegetation of disturbed areas may require the use of fertilizers and pesticides, which, if not applied properly, may become nonpoint source pollutants. Many pesticides are restricted by Federal and/or State regulations.

Hydroseeding operations, in which seed, fertilizers, and lime are applied to the ground surface in a one-step operation, are more conducive to nutrient pollution than are the conventional seedbed-preparation operations, in which fertilizers and lime are tilled into the soil. Use of fertilizers containing little or no phosphorus may be required by local authorities if the development is near sensitive waterbodies. The addition of lime can also affect the pH of sensitive waters, making them more alkaline.

Improper fueling and servicing of vehicles can lead to significant quantities of petroleum products being dumped onto the ground. These pollutants can then be washed off site in urban runoff, even when proper erosion and sediment controls are in place. Pollutants carried in solution in runoff water, or fixed with sediment crystalline structures, may not be adequately controlled by erosion and sediment control practices (Washington Department of Ecology, 1991). Oils, waxes, and water-insoluble pesticides can form surface films on water and solid particles. Oil films can also concentrate water-soluble insecticides. These pollutants can be nearly impossible to control once present in runoff other than by the use of very costly water-treatment facilities (Washington Department of Ecology, 1991).

After spill prevention, one of the best methods to control petroleum pollutants is to retain sediments containing oil on the construction site through use of erosion and sediment control practices. Improved maintenance and safe storage facilities will reduce the chance of contaminating a construction site. One of the greatest concerns related to use of petroleum products is the method for waste disposal. The dumping of petroleum product wastes into sewers and other drainage channels is illegal and could result in fines or job shutdown.

The primary control method for solid wastes is to provide adequate disposal facilities. Erosion and sediment control structures usually capture much of the solid waste from construction sites. Periodic removal of litter from these structures will reduce solid waste accumulations. Collected solid waste should be removed and disposed of at authorized disposal areas.

Improperly stored construction materials, such as pressure-treated lumber or solvents, may lead to leaching of toxics to surface water and ground water. Disposal of construction chemicals should follow all applicable State and local laws that may require disposal by a licensed waste management firm.

3. Management Measure Selection

This management measure was selected based on the potential for many construction activities to contribute to nutrient and toxic NPS pollution.

This management measure was selected because (1) construction activities have the potential to contribute to increased loadings of toxic substances and nutrients to waterbodies; (2) various States and local governments regulate the control of chemicals on construction sites through spill prevention plans, erosion and sediment control plans, or other administrative devices; (3) the practices described are commonly used and presented in a number of best management practice handbooks and guidance manuals for construction sites; and (4) the practices selected are the most economical and effective.

4. Practices

As discussed more fully at the beginning of this chapter and in Chapter 1, the following practices are described for illustrative purposes only. State programs need not require implementation of these practices. However, as a practical matter, EPA anticipates that the management measure set forth above generally will be implemented by applying one or more management practices appropriate to the source, location, and climate. The practices set forth below have been found by EPA to be representative of the types of practices that can be applied successfully to achieve the management measure described above.

  • a. Properly store, handle, apply, and dispose of pesticides.

    Pesticide storage areas on construction sites should be protected from the elements. Warning signs should be placed in areas recently sprayed or treated. Persons mixing and applying these chemicals should wear suitable protective clothing, in accordance with the law.

    Application rates should conform to registered label directions. Disposal of excess pesticides and pesticide-related wastes should conform to registered label directions for the disposal and storage of pesticides and pesticide containers set forth in applicable Federal, State, and local regulations that govern their usage, handling, storage, and disposal. Pesticides and herbicides should be used only in conjunction with Integrated Pest Management (IPM) (see Chapter 2). Pesticides should be the tool of last resort; methods that are the least disruptive to the environment and human health should be used first.

    Pesticides should be disposed of through either a licensed waste management firm or a treatment, storage, and disposal (TSD) facility. Containers should be triple-rinsed before disposal, and rinse waters should be reused as product.

    Other practices include setting aside a locked storage area, tightly closing lids, storing in a cool, dry place, checking containers periodically for leaks or deterioration, maintaining a list of products in storage, using plastic sheeting to line the storage area, and notifying neighboring property owners prior to spraying.

  • b. Properly store, handle, use, and dispose of petroleum products.

    When storing petroleum products, follow these guidelines:

    • Create a shelter around the area with cover and wind protection;
    • Line the storage area with a double layer of plastic sheeting or similar material;
    • Create an impervious berm around the perimeter with a capacity 110 percent greater than that of the largest container;
    • Clearly label all products;
    • Keep tanks off the ground; and
    • Keep lids securely fastened.
    Oil and oily wastes such as crankcase oil, cans, rags, and paper dropped into oils and lubricants should be disposed of in proper receptacles or recycled. Waste oil for recycling should not be mixed with degreasers, solvents, antifreeze, or brake fluid.

  • c. Establish fuel and vehicle maintenance staging areas located away from all drainage courses, and design these areas to control runoff.

    Proper maintenance of equipment and installation of proper stream crossings will further reduce pollution of water by these sources. Stream crossings should be minimized through proper planning of access roads. Refer to Chapter 3 for additional information on stream crossings.

  • d. Provide sanitary facilities for constructions workers.

  • e. Store, cover, and isolate construction materials, including topsoil and chemicals, to prevent runoff of pollutants and contamination of ground water.

  • f. Develop and implement a spill prevention and control plan. Agencies, contractors, and other commercial entities that store, handle, or transport fuel, oil, or hazardous materials should develop a spill response plan.

    Post spill procedure information and have persons trained in spill handling on site or on call at all times. Materials for cleaning up spills should be kept on site and easily available. Spills should be cleaned up immediately and the contaminated material properly disposed of. Spill control plan components should include:

    • Stop the source of the spill.
    • Contain any liquid.
    • Cover the spill with absorbent material such as kitty litter or sawdust, but do not use straw. Dispose of the used absorbent properly.
  • g. Maintain and wash equipment and machinery in confined areas specifically designed to control runoff.

    Thinners or solvents should not be discharged into sanitary or storm sewer systems when cleaning machinery. Use alternative methods for cleaning larger equipment parts, such as high-pressure, high-temperature water washes, or steam cleaning. Equipment-washing detergents can be used, and wash water may be discharged into sanitary sewers if solids are removed from the solution first. (This practice should be verified with the local sewer authority.) Small parts can be cleaned with degreasing solvents, which can then be reused or recycled. Do not discharge any solvents into sewers.

    Washout from concrete trucks should be disposed of into:

    • A designated area that will later be backfilled;
    • An area where the concrete wash can harden, can be broken up, and then can be placed in a dumpster; or
    • A location not subject to urban runoff and more than 50 feet away from a storm drain, open ditch, or surface water.
    Never dump washout into a sanitary sewer or storm drain, or onto soil or pavement that carries urban runoff.

  • h. Develop and implement nutrient management plans.

    Properly time applications, and work fertilizers and liming materials into the soil to depths of 4 to 6 inches. Using soil tests to determine specific nutrient needs at the site can greatly decrease the amount of nutrients applied.

  • i. Provide adequate disposal facilities for solid waste, including excess asphalt, produced during construction.

  • j. Educate construction workers about proper materials handling and spill response procedures. Distribute or post informational material regarding chemical control.

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    This page last updated October 4, 1999