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40 CONTRACTOR ACTIVITY CONTROL MEASURES

40.1

INTRODUCTION ............................................................................................................. 40-1

40.2

CONSTRUCTION PRACTICES........................................................................................... 40-1
40.2.1
40.2.2

Paving Operations............................................................................................. 40-2

40.2.3
40.3

De-watering Operations..................................................................................... 40-1

Structure Construction and Painting................................................................... 40-2

MATERIALS MANAGEMENT ............................................................................................. 40-3
40.3.1
40.3.2

Materials Use .................................................................................................... 40-4

40.3.3
40.4

Material Delivery and Storage............................................................................ 40-3

Spill Prevention and Control............................................................................... 40-4

WASTE MANAGEMENT.................................................................................................... 40-5
40.4.1
40.4.2

Hazardous Waste Management ......................................................................... 40-5

40.4.3

Contaminated Soil Management ........................................................................ 40-6

40.4.4

Concrete Waste Management ............................................................................ 40-7

40.4.5
40.5

Construction Waste Management....................................................................... 40-5

Sanitary/Septic Waste Management................................................................... 40-7

VEHICLE AND EQUIPMENT MANAGEMENT ...................................................................... 40-8
40.5.1
40.5.2

Vehicle and Equipment Fuelling......................................................................... 40-8

40.5.3
40.6

Vehicle and Equipment Cleaning........................................................................ 40-8

Vehicle and Equipment Maintenance ................................................................. 40-9

EMPLOYEE/SUBCONTRACTOR TRAINING ........................................................................ 40-9

Urban Stormwater Management Manual

40-i
Contractor Activity Control Measures

Employee/Subcontractor Training

There are two general classes of pollutants that may result
from dewatering operations; sediment, and toxins and
petroleum products. High sediment content in dewatering
discharges is common in runoff caught in sediment basins
unless actions are undertaken to reduce sediment
concentrations. On the other hand, toxins and petroleum
products are not commonly found in dewatering discharge
unless, the site or surrounding area has been used for light
or heavy industrial activities, or the area has a history of
groundwater contamination.

(a)

Description

To prevent or reduce the discharge of pollutants from
paving operations by using measures to prevent pollution
by runon and runoff, properly disposing of wastes, and
training employees and subcontractors. Runon of surface
water from uphill onto paved areas and runoff from areas
being paved can pollute stormwater by entraining particles
and chemicals in the runoff.
(b)

(b)

Actions and Measures

Actions and Measures
•

For sediment basins, either:
•

dose captured runoff (with fine grained or dispersive
soils) with a flocculating agent prior to pumping water
from the basin.

Locate materials storage areas such that they will not
be subject to stormwater runon from streams and onsite drainage structures.

•

Leaks and spills from paving equipment can contain
toxic levels of heavy metals and oil and grease. Place
drip pans or absorbent materials under paving
equipment when not in use. Clean up spills with
absorbent materials rather than burying.

•

Cover manholes when applying seal coat, slurry seal,
fog seal, etc.

•

If paving involves asphaltic concrete:

filter discharges (with coarse grained soils) using a
perforated or slit riser pipe wrapped in filter fabric, or

•

Avoid paving during wet weather.

•

In either case, the quality of discharge from de-watering
operations shall meet the INWQS standards for TSS and
turbidity as appropriate. In areas suspected of having
polluted groundwater, sample the groundwater near the
excavation site and have the water tested at a certified
laboratory in accordance with DOE requirements. Review
and select an appropriate disposal option for any polluted
water discharged during de-watering after discussion with
DOE and/or the Local Authority.

do not allow sand or gravel placed
asphalt to wash into drains, streets,
Paving should be swept and excess
gravel collected and removed from the

°

collect and remove all broken asphalt from the
site and recycle whenever possible

°

(c)

°

all material removed from the site must be
disposed of in compliance with local regulations

Maintenance Requirements

•

Maintain sediment controls and filters in good working
order.

•

Inspect excavated areas daily for signs of
contaminated water as evidenced by discolouration,
oily sheen, or odours.

(d)

Limitations

Contaminated water may indicate the presence of soil as
well.
40.2.2 Paving Operations

40-2

(c)

over new
or creeks.
sand and
site

Maintenance Requirements

•

Inspect employees and subcontractors to ensure that
measures are being followed.

•

Keep ample supplies of drip pans or absorbent
material on-site.

40.2.3 Structure Construction and Painting
Contractor Activity Control Measures

(a)

Description

The construction and painting of structures can generate
pollutants that can reach stormwater if proper care is not
taken. Contaminant sources may be solvents, paints and
varnish removers, finishing residues, spent thinners, soap
cleaners, kerosene, asphalt and concrete materials,
adhesive residues, and old asbestos insulation. Building
materials should be enclosed, covered, or bermed and
employees and subcontractors should be trained in
appropriate practices.
(b)

Actions and Measures

(a)

Description

To prevent or reduce the discharge of pollutants to
stormwater by minimising the storage of hazardous
materials on-site, storing materials in a designated area,
installing secondary containment, conducting regular
inspections, and training employees and subcontractors in
appropriate practices.
The following materials are commonly stored and used on
construction sites:
•

soil;

•

pesticides and herbicides;

•

Keep the work site clean and orderly. Remove debris
in a timely fashion. Sweep the area if appropriate.

•

fertilisers;

•

detergents;

•

Use soil erosion control techniques if bare ground is
exposed (refer Chapter 38 and 39).

•

plaster or other products;

•

Conduct painting operations consistent with local air
quality and health regulations.

•

petroleum products such as fuel, oil, and grease;

•

•

Properly store paints and solvents.

other hazardous chemicals such as acids, lime, paints,
solvents, and curing compounds.

•

Properly store and dispose of waste materials
generated from the activity.

(b)

•

Recycle residual paints, solvents, timber, and other
materials to the maximum extent practicable.

•

•

Do not dispose of residual paints and other liquids into
stormwater drains or watercourses.

)

place near the construction entrances, away from
stormwater drains and waterways

•

Clean all the drains in the immediate construction area
after construction is completed.

)

avoid transport near drainage paths or waterways

)

surround with earth berms

•

Educate employees who are doing the work.

)

place in an area which will be paved

•

Include appropriate provisions in subcontracts to make
certain proper housekeeping and disposal practices
are implemented.

(c)

Limitations

Actions and Measures
Designate areas of the construction site for material
delivery and storage.

•

Storage of reactive, ignitable, or flammable liquids
must comply with the relevant codes.

•

Keep an accurate, up-to-date inventory of materials
delivered and stored on-site.

•

During the rainy season, consider storing materials in
a covered area.
Do not store chemicals, drums, or bagged materials
directly on the ground. Place these items on a pallet
and when possible, in secondary containment.

•

If drums must be kept uncovered, store them at a
slight angle to reduce ponding of rainwater on the lids
and to reduce corrosion.
Try to keep chemicals in their original containers and
keep them well labelled.
Employees trained in emergency spill cleanup
procedures should be present when dangerous
materials or liquid chemicals are unloaded.

•

40.3

Handle hazardous
possible.

•

Hazardous waste that cannot be re-used or recycled
must be disposed of by a licensed hazardous waste
contractor.

•

•

•

Safer alternative products may not be available,
suitable, or effective in every case.

Keep inventories as small as practicable.
Minimise on-site storage of hazardous materials.

•

•

•
•

If significant residual materials remain on the ground
after construction is complete, properly remove
materials and any contaminated soil. If the area is to

MATERIALS MANAGEMENT

40.3.1 Material Delivery and Storage

Urban Stormwater Management Manual

materials

as

infrequently

as

40-3
Contractor Activity Control Measures

be paved, pave as soon as materials are removed to
stabilise the soil.
(c)

Maintenance Requirements

•

Keep designated storage areas clean and organised.

•

Conduct routine weekly inspections and check for
external corrosion of material containers.

•

Keep an ample supply of spill cleanup materials near
storage areas.

(d)

•

(c)

Train employees and subcontractors in the proper use
of materials.
Limitations

Alternative materials may not be available, suitable, or
effective in every case.
40.3.3 Spill Prevention and Control

Limitations

Storage sheds should meet building and fire code
requirements.
40.3.2 Materials Use
(a)

Description

To prevent or reduce the discharge of pollutants to
stormwater from leaks and spills by reducing the chance
for spills, stopping the source of spills, containing and
cleaning up spills, properly disposing of spill materials, and
training employees and subcontractors.
(b)
(a)

Description

To prevent or reduce the discharge of pollutants to
stormwater from material use by minimising hazardous
material use on-site, and training employees and
subcontractors in appropriate practices.
(b)

Actions and Measures

•

Define “Significant Spill”. Different materials pollute in
different amounts. Make sure that each employee
knows what a “significant spill” is for each material
they use, and what is the appropriate response for
“significant” and “insignificant” spills.

•

Hazardous materials and wastes should be stored in
covered containers and protected from vandalism.

Actions and Measures
•

•

Use less hazardous, alternative materials as much as
possible.

Place a stockpile of spill cleanup materials where it will
be readily accessible.

•

Train employees in spill prevention and cleanup.

•

Minimise the use of hazardous materials on-site.

•

Designate responsible individuals.

•

Use materials only where and when needed to
complete the construction activity.

•

Clean up leaks and spills immediately.

•

On paved surfaces, clean up spills with as little water
as possible. Use a rag for small spills, a dump mop for
general cleanup and absorbent material for larger
spills. If spilled material is hazardous, then the used
cleanup materials are also hazardous and must be
disposed of as hazardous waste.

•

Never hose down or bury dry material spills. Clean up
as much of the material as possible and dispose of
properly.

•

Report significant spills to the DOE or Local Authority
so they can assist in cleanup.

•

Refer to Section 40.5 for spill prevention guidelines for
vehicles and equipment.

•

Follow manufacturer’s instructions regarding uses,
protective equipment, ventilation, flammability, and
mixing of chemicals.

•

Personnel who use pesticides should be trained in
their use.

•

Fertilisers, herbicides, and pesticides should not be
over-applied.
Prepare only the amount needed.
Follow the recommended usage instructions. Overapplication is expensive and environmentally harmful.
Unless on steep slopes, till fertilisers into the soil
rather than hydroseed. Apply surface dressing in
several smaller applications, as opposed to one large
application, to allow time for infiltration and to avoid
excess material being carried off-site by runoff. Do
not apply chemicals just before it rains.

40-4

Urban Stormwater Management Manual
Contractor Activity Control Measures

Alternative materials may not be available, suitable, or
effective in every case.
(d)

Do not burn waste on-site.

•

Locate containers in a covered area and/or in a
secondary containment.

•

Provide an adequate number of containers with lids or
covers that can be placed over the container to keep
out rain and to prevent loss of wastes when it’s windy.

•

Plan for additional containers and more frequent
pickup during the demolition phase of construction.

•

Collect site trash daily if necessary, especially during
rainy and windy conditions.
Erosion and sediment control devices tend to collect
litter. Remove this solid waste promptly.

•

Make sure that toxic liquid wastes (used oils, solvents,
and paints) and chemicals (acids, pesticides, additives,
curing compounds) are not disposed of in waste
storage bins designated for construction debris.

•

Do not hose out waste storage bins on-site.
Arrange for regular waste collection before containers
overflow.
If a container does spill, clean up immediately.

•

Prepare a plan for spill prevention and control.
Update the plan as necessary and stock cleanup
materials as changes occur in the types of chemicals
on-site.

•

•

•

Keep ample supplies of spill control and cleanup
materials on-site near storage, unloading, and
maintenance areas.

Comply with local regulations for the management of
solid waste.

•

•

Maintenance Requirements

•

•

(c)

Make sure that construction waste is collected,
removed, and disposed of only at authorised landfill
disposal areas.

Limitations

It may be necessary to use a private spill cleanup company
on some projects.

40.4

WASTE MANAGEMENT

40.4.1 Construction Waste Management

(c)
(a)

Description

To prevent or reduce the discharge of pollutants to
stormwater from solid or construction wastes by providing
designated waste collection areas and containers,
arranging for regular disposal, and training employees and
subcontractors in waste management techniques. Solid
waste is one of the major pollutants resulting from
construction. Construction debris includes:
•

scrap or surplus building materials including scrap
metals, rubber, plastic, glass pieces, and masonry
products

•

domestic waste from site accommodation including
food containers such as cans, coffee cups, paper bags
and plastic wrapper, and cigarettes

Collect site rubbish daily.

•

Inspect construction waste areas regularly.

•

Arrange for regular waste collection.

40.4.2 Hazardous Waste Management

packaging materials including wood, paper and plastic

•

•

solid waste generated from trees and shrubs removed
during land clearing, demolition of existing structures
(rubble), and building construction

•

Maintenance Requirements

(b)
•
•

Actions and Measures
Select and use suitable and accessible on-site waste
collection areas.
Inspect waste storage bins for leaks and direct the
subcontractor to repair any bin that is not watertight.

Urban Stormwater Management Manual

(a)

Description

Many of the chemicals used on-site can be hazardous
materials, which become hazardous waste upon disposal.
These wastes may include:
•

paints and solvents

•

petroleum products such as oils, fuels, and grease

•

herbicides and pesticides

•

acids for cleaning masonry

•

concrete curing compounds

40-5
Contractor Activity Control Measures

In addition, sites with existing structures may contain
wastes, which must be disposed of in accordance with
Federal, State, or local regulations. These wastes may
include:

(iii)
•

Train employees and subcontractors
hazardous waste management.

•

sandblasting grit mixed with lead-based, cadmiumbased, or chromium-based paint

•

Warning signs should be placed in areas recently
treated with chemicals.

•

asbestos

•

other “scheduled” wastes

(c)

Training
in

proper

Maintenance Requirements

(b)

Actions and Measures

•

Inspect hazardous waste receptacles and areas
regularly.

(i)

Materials Use

•

Arrange for regular waste collection before containers
overflow.

•

Use all of a product before disposing of the container.

•

Do not remove original product labels as they contain
important safety and disposal information.

•

Do not over-apply herbicides and pesticides. Prepare
only the amount needed. Follow the recommended
usage instructions. Over-application is expensive and
environmental harmful. Apply surface dressing in
several smaller applications, as opposed to one large
application, to allow time for infiltration and to avoid
excess material being carried off-site by runoff. Do
not apply these chemicals just before it rains.

•

Place a stockpile of spill cleanup materials where it will
be readily accessible.

•

If a container does spill, clean up immediately.

Hazardous wastes that cannot be recycled must be
disposed of by a licensed hazardous waste contractor.

40.4.3 Contaminated Soil Management

Dispose of excess oil-based paints and sludge as
hazardous waste.

•

•

Limitations

Do not clean out brushes or rinse containers into a
gutter, stormwater drain, or stream.

•

(d)

(ii)
•

Waste Recycling/Disposal

Hazardous materials and waste should be stored in
covered containers and protected from vandalism.

•

Place hazardous
containment.

•

Do not mix wastes, this can cause chemical reactions,
make recycling impossible, and complicate disposal.

•

Hazardous materials must be labelled and stored in
accordance with DOE requirements.

•

Recycle any useful material such as used oil or waterbased paint.

•

Make sure that toxic liquid wastes (used oils, solvents,
paints) and chemicals (acids, pesticides, additives,
curing compounds) are not disposed of in waste
storage bins designated for construction debris.

40-6

Description

Contaminated soils occur on a site for several reasons
including:
•

Select and use designated on-site hazardous waste
collection areas.

•

•

(a)

waste containers in secondary

Make sure that hazardous waste (e.g. excess oil-based
paint and sludge) is collected, removed, and disposed
of only at authorised disposal areas.

past site uses and activities

•

detected or undetected spills and leaks

•

acid or alkaline solutions from exposed soil or rock
formations high in acid or alkaline-forming elements

Contractors may be liable for clean-up costs when they
unknowingly move contaminated soil. This highlights the
need for contractors to confirm that a site assessment has
been completed before earth moving commences.
To prevent or reduce the discharge of pollutants to
stormwater from contaminated soil and highly acidic or
alkaline soils, conduct pre-construction surveys, inspect
excavations regularly, and remediate contaminated soil
promptly.
(b)

Actions and Measures

•

If necessary, conduct thorough site planning preconstruction geologic surveys.

•

Look for contaminated soil as evidenced by
discoloration, odours, differences in soil properties,

Urban Stormwater Management Manual
Contractor Activity Control Measures

abandoned underground tanks or pipes, or buried
debris.
•

If the soil is contaminated, work with the DOE and/or
Local Authority to develop options for treatment
and/or disposal.

(c)

Maintenance Requirements

•

Implement spill prevention and control to prevent
leaks and spills as much as possible.

(d)

Limitations

wash out wastes into the temporary pit where the
concrete can set, be broken up, and disposed of
properly

•

When washing concrete to remove fine particles and
expose the aggregate, avoid creating runoff by
draining the water to a bermed or level area.

•

Do not wash sweepings from exposed aggregate
concrete into the street or a stormwater drain. Collect
and return sweepings to an aggregate base stockpile,
or dispose of in a waste storage bin.

Conduct daily inspections of excavated areas for signs
of contaminated soil.

•

locate washout areas at least 15 m from
stormwater drains, open ditches, or water bodies.
Do not allow runoff from this area by constructing
a temporary pit or bermed area large enough for
liquid and solid waste

°

Test suspected soils at a certified laboratory.

•

For on-site washout:
°

Prevent leaks and spills to the maximum extent
practicable. Contaminated soil can be expensive to
treat and/or dispose of properly. However, addressing
the problem before construction is much less
expensive than after the structures are in place.

•

•

(c)

Maintenance Requirements

•

Inspect subcontractors to ensure that concrete wastes
are being properly managed.
If using a temporary pit, dispose of hardened concrete
on a regular basis.

•

Contaminated soils that cannot be treated on-site
must be disposed of by a licensed hazardous waste
contractor.

•

•

The presence of contaminated soil may indicate
contaminated water as well.

40.4.5 Sanitary/Septic Waste Management

40.4.4 Concrete Waste Management

(a)

(a)

Description

To prevent or reduce the discharge of pollutants to
stormwater from concrete waste by conducting on-site
washout in a designated area.
(b)

Actions and Measures

Description

To prevent or reduce the discharge of pollutants to
stormwater from sanitary/septic waste by providing
convenient, well-maintained facilities and arranging for
timely service and disposal.
(b)

Actions and Measures

Sanitary or septic wastes should be treated or disposed of
in accordance with Federal, State, or local requirements.
These requirements may include:

•

Store dry and wet materials under cover, away from
stormwater drainage areas.

•

Locate sanitary facilities in a convenient location.

•

Avoid mixing excess amounts of fresh concrete or
cement on-site.

•

Untreated raw wastewater should not be discharged
or buried.

•

Perform washout of concrete trucks in designated
areas only.

•

Temporary septic systems should treat wastes to
appropriate levels before discharging.

•

Do not wash out concrete trucks into stormwater
drains, open ditches, streets, or streams.

•

If using an on-site disposal system, such as a septic
system, comply with local health agency requirements.

•

Do not allow excess concrete to be dumped on-site
except in designated areas.

•

Temporary sanitary facilities that discharge to the
sewer system should be properly connected to avoid
illicit discharges.

Urban Stormwater Management Manual

40-7
Contractor Activity Control Measures

•

Sanitary/septic facilities should be maintained in good
working order.

•

40.5.2 Vehicle and Equipment Fuelling

Arrange for regular waste collection by a licensed
subcontractor before facilities overflow.

(c)

Maintenance Requirements

•

Inspect facilities regularly.

•

Arrange for regular waste collection.

40.5

VEHICLE AND EQUIPMENT MANAGEMENT

40.5.1 Vehicle and Equipment Cleaning

(a)

Descriptions

Fuelling vehicles and equipment in areas where fuel can
spill or leak onto paved surfaces or into drainage pathways
can pollute stormwater.
To prevent fuel spills and leaks and reduce their impacts to
stormwater, use off-site facilities, fuel in designated on-site
areas only, enclose or cover stored fuel, implement spill
controls, and train employees and subcontractors.
(b)

Actions and Measures

•
(a)

Description

Use approved off-site commercial fuelling facilities
where available.

•

If fuelling occurs on-site; use designated areas,
located away from stormwater drains to prevent the
runon of stormwater and the runoff of spills.

To prevent or reduce the discharge of pollutants to
stormwater from vehicle and equipment cleaning by using
off-site facilities, or designated, contained on-site areas
where discharge to stormwater drains is prevented by
infiltrating or recycling the wash water.

•

Always use secondary containment, such as a drain
pan or drop cloth, when fuelling to catch spills/leaks.

•

Place a stockpile of spill cleanup materials where it will
be readily accessible.

(b)

•

Use adsorbent materials on small spills rather than
hosing down or burying the spill.
Remove the
adsorbent materials promptly and dispose or properly.

•

Avoid mobile fuelling of mobile construction equipment
around the site, transport the equipment instead to
designated fuelling areas. With the exception of
tracked equipment such as bulldozers and perhaps
forklifts, most vehicles should be able to travel to a
designated area with little lost time.

•

Train employees and subcontractors in proper fuelling
and cleanup procedures.

Actions and Measures

•

Use off-site commercial washing facilities if available.

•

If washing must occur on-site, use designated bermed
wash areas to prevent wash water from discharging
into stormwater drains, streams, and other water
bodies. The wash area can be sloped for wash water
collection and subsequent infiltration into the ground.

•

Use as little water as possible to avoid having to install
erosion and sediment controls for the wash area.

•

Preferably use phosphate-free, biodegradable soaps.

•

Do not permit steam cleaning on-site. Steam cleaning
can generate significant pollutant concentrations.

(c)

Maintenance Requirements

Limitations

Even phosphate-free, biodegradable soaps have been
shown to be toxic to fish before the soap degrades.

40-8

•

Keep ample supplies of spill cleanup materials on-site.

•

(c)

Regularly inspect fuelling areas and storage tanks for
leaks and signs of corrosion.

Urban Stormwater Management Manual
Contractor Activity Control Measures

40.5.3 Vehicle and Equipment Maintenance

(c)

Maintenance Requirements

•

Keep ample supplies of spill cleanup materials on-site.

•

Regularly inspect maintenance areas and workshops.

40.6

(a)

EMPLOYEE/SUBCONTRACTOR
TRAINING

Description

Maintaining vehicles and equipment outdoors or in areas
where vehicle or equipment fluids may spill or leak onto
the ground can pollute stormwater.
To prevent or reduce the discharge of pollutants to
stormwater from vehicle and equipment maintenance, it is
better to run a “dry site”. This involves using approved
off-site facilities, performing work in designated areas only,
providing cover for materials stored outside, checking for
leaks and spills, and containing and cleaning up spills
immediately.
(b)

Actions and Measures

(a)

Employee and subcontractor training, like maintenance or
a piece of equipment, is a method to implement BMPs
rather than a BMP in itself. Training is extremely important
and the elements of employee and subcontractor training
from the individual source controls should be integrated
into a comprehensive training program as part of a
company’s integrated ESCP.

•

Keep vehicles and equipment clean, don’t allow
excessive build-up of oil and grease.

•

Consider using off-site facilities to maintain vehicles
and equipment.

•

If maintenance must occur on-site, use designated
areas, located away from stormwater drains to
prevent the runon of stormwater and the runoff of
spills.

•

On large sites, establish a properly equipped, covered
workshop on-site for maintenance.

•

Always use secondary containment, such as a drain
pan drop cloth, to catch spills or leaks when removing
or changing fluids.

•

Place a stockpile of spill cleanup materials where it be
readily accessible.

•

Use adsorbent materials on small spills rather than
hosing down or burying the spill.
Remove the
adsorbent materials promptly and dispose of properly.

•

Regularly inspect on-site vehicles and equipment for
leaks and repair immediately.

•

Check incoming vehicles and equipment for leaking oil
and fluids. Do not allow leaking vehicles or equipment
on-site.

(c)

•

Segregate and recycle wastes, such as greases, used
oil or oil filters, cleaning solutions, automotive
batteries, and hydraulic and transmission fluids.

Train employees and subcontractors in proper maintenance
and spill cleanup procedures.

Urban Stormwater Management Manual

Description

The specific employee and subcontractor training aspects
of each of the source control are highlighted in the
previous sections of this chapter. The focus of this section
is more general, and includes the overall objectives and
approach for assuring that all employee and subcontractor
are properly trained in stormwater pollution prevention.
(b)

Objectives

Employee and subcontractor training should be based on
four objectives:
•

To promote a clear identification and understanding of
the problem, including activities with the potential to
pollute stormwater.

•

To identify solutions (BMPs) to stormwater pollution
problems.

•

To promote employee and subcontractor responsibility
and accountability for the problems and solutions.

•

To integrate employee and subcontractor feedback
into training and BMP implementation.
Approach

•

Integrate training regarding stormwater quality
management with existing training programs that may
be required by other regulations.

•

Train employees and subcontractors in standard
operating procedures and spill cleanup techniques.
Employees or subcontractors trained in spill

40-9
Contractor Activity Control Measures

containment should be present during the loading,
unloading, and handling of materials.
•

Personnel who use pesticides should be trained in
their use.
The Authority shall license pesticide
dealers, certify pesticide applicators, and conduct onsite inspections.

40-10

•

Proper education of off-site contractors is often
overlooked. The conscientious efforts of well-trained
employees and/or subcontractors can be lost by
unknowing off-site contractors, therefore, make sure
they are well informed about what they are expected
to do on-site.

Urban Stormwater Management Manual

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Contractor Activity Control Measures for Stormwater Pollution Prevention

  • 1. 40 CONTRACTOR ACTIVITY CONTROL MEASURES 40.1 INTRODUCTION ............................................................................................................. 40-1 40.2 CONSTRUCTION PRACTICES........................................................................................... 40-1 40.2.1 40.2.2 Paving Operations............................................................................................. 40-2 40.2.3 40.3 De-watering Operations..................................................................................... 40-1 Structure Construction and Painting................................................................... 40-2 MATERIALS MANAGEMENT ............................................................................................. 40-3 40.3.1 40.3.2 Materials Use .................................................................................................... 40-4 40.3.3 40.4 Material Delivery and Storage............................................................................ 40-3 Spill Prevention and Control............................................................................... 40-4 WASTE MANAGEMENT.................................................................................................... 40-5 40.4.1 40.4.2 Hazardous Waste Management ......................................................................... 40-5 40.4.3 Contaminated Soil Management ........................................................................ 40-6 40.4.4 Concrete Waste Management ............................................................................ 40-7 40.4.5 40.5 Construction Waste Management....................................................................... 40-5 Sanitary/Septic Waste Management................................................................... 40-7 VEHICLE AND EQUIPMENT MANAGEMENT ...................................................................... 40-8 40.5.1 40.5.2 Vehicle and Equipment Fuelling......................................................................... 40-8 40.5.3 40.6 Vehicle and Equipment Cleaning........................................................................ 40-8 Vehicle and Equipment Maintenance ................................................................. 40-9 EMPLOYEE/SUBCONTRACTOR TRAINING ........................................................................ 40-9 Urban Stormwater Management Manual 40-i
  • 2.
  • 3.
  • 4. Contractor Activity Control Measures Employee/Subcontractor Training There are two general classes of pollutants that may result from dewatering operations; sediment, and toxins and petroleum products. High sediment content in dewatering discharges is common in runoff caught in sediment basins unless actions are undertaken to reduce sediment concentrations. On the other hand, toxins and petroleum products are not commonly found in dewatering discharge unless, the site or surrounding area has been used for light or heavy industrial activities, or the area has a history of groundwater contamination. (a) Description To prevent or reduce the discharge of pollutants from paving operations by using measures to prevent pollution by runon and runoff, properly disposing of wastes, and training employees and subcontractors. Runon of surface water from uphill onto paved areas and runoff from areas being paved can pollute stormwater by entraining particles and chemicals in the runoff. (b) (b) Actions and Measures Actions and Measures • For sediment basins, either: • dose captured runoff (with fine grained or dispersive soils) with a flocculating agent prior to pumping water from the basin. Locate materials storage areas such that they will not be subject to stormwater runon from streams and onsite drainage structures. • Leaks and spills from paving equipment can contain toxic levels of heavy metals and oil and grease. Place drip pans or absorbent materials under paving equipment when not in use. Clean up spills with absorbent materials rather than burying. • Cover manholes when applying seal coat, slurry seal, fog seal, etc. • If paving involves asphaltic concrete: filter discharges (with coarse grained soils) using a perforated or slit riser pipe wrapped in filter fabric, or • Avoid paving during wet weather. • In either case, the quality of discharge from de-watering operations shall meet the INWQS standards for TSS and turbidity as appropriate. In areas suspected of having polluted groundwater, sample the groundwater near the excavation site and have the water tested at a certified laboratory in accordance with DOE requirements. Review and select an appropriate disposal option for any polluted water discharged during de-watering after discussion with DOE and/or the Local Authority. do not allow sand or gravel placed asphalt to wash into drains, streets, Paving should be swept and excess gravel collected and removed from the ° collect and remove all broken asphalt from the site and recycle whenever possible ° (c) ° all material removed from the site must be disposed of in compliance with local regulations Maintenance Requirements • Maintain sediment controls and filters in good working order. • Inspect excavated areas daily for signs of contaminated water as evidenced by discolouration, oily sheen, or odours. (d) Limitations Contaminated water may indicate the presence of soil as well. 40.2.2 Paving Operations 40-2 (c) over new or creeks. sand and site Maintenance Requirements • Inspect employees and subcontractors to ensure that measures are being followed. • Keep ample supplies of drip pans or absorbent material on-site. 40.2.3 Structure Construction and Painting
  • 5. Contractor Activity Control Measures (a) Description The construction and painting of structures can generate pollutants that can reach stormwater if proper care is not taken. Contaminant sources may be solvents, paints and varnish removers, finishing residues, spent thinners, soap cleaners, kerosene, asphalt and concrete materials, adhesive residues, and old asbestos insulation. Building materials should be enclosed, covered, or bermed and employees and subcontractors should be trained in appropriate practices. (b) Actions and Measures (a) Description To prevent or reduce the discharge of pollutants to stormwater by minimising the storage of hazardous materials on-site, storing materials in a designated area, installing secondary containment, conducting regular inspections, and training employees and subcontractors in appropriate practices. The following materials are commonly stored and used on construction sites: • soil; • pesticides and herbicides; • Keep the work site clean and orderly. Remove debris in a timely fashion. Sweep the area if appropriate. • fertilisers; • detergents; • Use soil erosion control techniques if bare ground is exposed (refer Chapter 38 and 39). • plaster or other products; • Conduct painting operations consistent with local air quality and health regulations. • petroleum products such as fuel, oil, and grease; • • Properly store paints and solvents. other hazardous chemicals such as acids, lime, paints, solvents, and curing compounds. • Properly store and dispose of waste materials generated from the activity. (b) • Recycle residual paints, solvents, timber, and other materials to the maximum extent practicable. • • Do not dispose of residual paints and other liquids into stormwater drains or watercourses. ) place near the construction entrances, away from stormwater drains and waterways • Clean all the drains in the immediate construction area after construction is completed. ) avoid transport near drainage paths or waterways ) surround with earth berms • Educate employees who are doing the work. ) place in an area which will be paved • Include appropriate provisions in subcontracts to make certain proper housekeeping and disposal practices are implemented. (c) Limitations Actions and Measures Designate areas of the construction site for material delivery and storage. • Storage of reactive, ignitable, or flammable liquids must comply with the relevant codes. • Keep an accurate, up-to-date inventory of materials delivered and stored on-site. • During the rainy season, consider storing materials in a covered area. Do not store chemicals, drums, or bagged materials directly on the ground. Place these items on a pallet and when possible, in secondary containment. • If drums must be kept uncovered, store them at a slight angle to reduce ponding of rainwater on the lids and to reduce corrosion. Try to keep chemicals in their original containers and keep them well labelled. Employees trained in emergency spill cleanup procedures should be present when dangerous materials or liquid chemicals are unloaded. • 40.3 Handle hazardous possible. • Hazardous waste that cannot be re-used or recycled must be disposed of by a licensed hazardous waste contractor. • • • Safer alternative products may not be available, suitable, or effective in every case. Keep inventories as small as practicable. Minimise on-site storage of hazardous materials. • • • • If significant residual materials remain on the ground after construction is complete, properly remove materials and any contaminated soil. If the area is to MATERIALS MANAGEMENT 40.3.1 Material Delivery and Storage Urban Stormwater Management Manual materials as infrequently as 40-3
  • 6. Contractor Activity Control Measures be paved, pave as soon as materials are removed to stabilise the soil. (c) Maintenance Requirements • Keep designated storage areas clean and organised. • Conduct routine weekly inspections and check for external corrosion of material containers. • Keep an ample supply of spill cleanup materials near storage areas. (d) • (c) Train employees and subcontractors in the proper use of materials. Limitations Alternative materials may not be available, suitable, or effective in every case. 40.3.3 Spill Prevention and Control Limitations Storage sheds should meet building and fire code requirements. 40.3.2 Materials Use (a) Description To prevent or reduce the discharge of pollutants to stormwater from leaks and spills by reducing the chance for spills, stopping the source of spills, containing and cleaning up spills, properly disposing of spill materials, and training employees and subcontractors. (b) (a) Description To prevent or reduce the discharge of pollutants to stormwater from material use by minimising hazardous material use on-site, and training employees and subcontractors in appropriate practices. (b) Actions and Measures • Define “Significant Spill”. Different materials pollute in different amounts. Make sure that each employee knows what a “significant spill” is for each material they use, and what is the appropriate response for “significant” and “insignificant” spills. • Hazardous materials and wastes should be stored in covered containers and protected from vandalism. Actions and Measures • • Use less hazardous, alternative materials as much as possible. Place a stockpile of spill cleanup materials where it will be readily accessible. • Train employees in spill prevention and cleanup. • Minimise the use of hazardous materials on-site. • Designate responsible individuals. • Use materials only where and when needed to complete the construction activity. • Clean up leaks and spills immediately. • On paved surfaces, clean up spills with as little water as possible. Use a rag for small spills, a dump mop for general cleanup and absorbent material for larger spills. If spilled material is hazardous, then the used cleanup materials are also hazardous and must be disposed of as hazardous waste. • Never hose down or bury dry material spills. Clean up as much of the material as possible and dispose of properly. • Report significant spills to the DOE or Local Authority so they can assist in cleanup. • Refer to Section 40.5 for spill prevention guidelines for vehicles and equipment. • Follow manufacturer’s instructions regarding uses, protective equipment, ventilation, flammability, and mixing of chemicals. • Personnel who use pesticides should be trained in their use. • Fertilisers, herbicides, and pesticides should not be over-applied. Prepare only the amount needed. Follow the recommended usage instructions. Overapplication is expensive and environmentally harmful. Unless on steep slopes, till fertilisers into the soil rather than hydroseed. Apply surface dressing in several smaller applications, as opposed to one large application, to allow time for infiltration and to avoid excess material being carried off-site by runoff. Do not apply chemicals just before it rains. 40-4 Urban Stormwater Management Manual
  • 7. Contractor Activity Control Measures Alternative materials may not be available, suitable, or effective in every case. (d) Do not burn waste on-site. • Locate containers in a covered area and/or in a secondary containment. • Provide an adequate number of containers with lids or covers that can be placed over the container to keep out rain and to prevent loss of wastes when it’s windy. • Plan for additional containers and more frequent pickup during the demolition phase of construction. • Collect site trash daily if necessary, especially during rainy and windy conditions. Erosion and sediment control devices tend to collect litter. Remove this solid waste promptly. • Make sure that toxic liquid wastes (used oils, solvents, and paints) and chemicals (acids, pesticides, additives, curing compounds) are not disposed of in waste storage bins designated for construction debris. • Do not hose out waste storage bins on-site. Arrange for regular waste collection before containers overflow. If a container does spill, clean up immediately. • Prepare a plan for spill prevention and control. Update the plan as necessary and stock cleanup materials as changes occur in the types of chemicals on-site. • • • Keep ample supplies of spill control and cleanup materials on-site near storage, unloading, and maintenance areas. Comply with local regulations for the management of solid waste. • • Maintenance Requirements • • (c) Make sure that construction waste is collected, removed, and disposed of only at authorised landfill disposal areas. Limitations It may be necessary to use a private spill cleanup company on some projects. 40.4 WASTE MANAGEMENT 40.4.1 Construction Waste Management (c) (a) Description To prevent or reduce the discharge of pollutants to stormwater from solid or construction wastes by providing designated waste collection areas and containers, arranging for regular disposal, and training employees and subcontractors in waste management techniques. Solid waste is one of the major pollutants resulting from construction. Construction debris includes: • scrap or surplus building materials including scrap metals, rubber, plastic, glass pieces, and masonry products • domestic waste from site accommodation including food containers such as cans, coffee cups, paper bags and plastic wrapper, and cigarettes Collect site rubbish daily. • Inspect construction waste areas regularly. • Arrange for regular waste collection. 40.4.2 Hazardous Waste Management packaging materials including wood, paper and plastic • • solid waste generated from trees and shrubs removed during land clearing, demolition of existing structures (rubble), and building construction • Maintenance Requirements (b) • • Actions and Measures Select and use suitable and accessible on-site waste collection areas. Inspect waste storage bins for leaks and direct the subcontractor to repair any bin that is not watertight. Urban Stormwater Management Manual (a) Description Many of the chemicals used on-site can be hazardous materials, which become hazardous waste upon disposal. These wastes may include: • paints and solvents • petroleum products such as oils, fuels, and grease • herbicides and pesticides • acids for cleaning masonry • concrete curing compounds 40-5
  • 8. Contractor Activity Control Measures In addition, sites with existing structures may contain wastes, which must be disposed of in accordance with Federal, State, or local regulations. These wastes may include: (iii) • Train employees and subcontractors hazardous waste management. • sandblasting grit mixed with lead-based, cadmiumbased, or chromium-based paint • Warning signs should be placed in areas recently treated with chemicals. • asbestos • other “scheduled” wastes (c) Training in proper Maintenance Requirements (b) Actions and Measures • Inspect hazardous waste receptacles and areas regularly. (i) Materials Use • Arrange for regular waste collection before containers overflow. • Use all of a product before disposing of the container. • Do not remove original product labels as they contain important safety and disposal information. • Do not over-apply herbicides and pesticides. Prepare only the amount needed. Follow the recommended usage instructions. Over-application is expensive and environmental harmful. Apply surface dressing in several smaller applications, as opposed to one large application, to allow time for infiltration and to avoid excess material being carried off-site by runoff. Do not apply these chemicals just before it rains. • Place a stockpile of spill cleanup materials where it will be readily accessible. • If a container does spill, clean up immediately. Hazardous wastes that cannot be recycled must be disposed of by a licensed hazardous waste contractor. 40.4.3 Contaminated Soil Management Dispose of excess oil-based paints and sludge as hazardous waste. • • Limitations Do not clean out brushes or rinse containers into a gutter, stormwater drain, or stream. • (d) (ii) • Waste Recycling/Disposal Hazardous materials and waste should be stored in covered containers and protected from vandalism. • Place hazardous containment. • Do not mix wastes, this can cause chemical reactions, make recycling impossible, and complicate disposal. • Hazardous materials must be labelled and stored in accordance with DOE requirements. • Recycle any useful material such as used oil or waterbased paint. • Make sure that toxic liquid wastes (used oils, solvents, paints) and chemicals (acids, pesticides, additives, curing compounds) are not disposed of in waste storage bins designated for construction debris. 40-6 Description Contaminated soils occur on a site for several reasons including: • Select and use designated on-site hazardous waste collection areas. • • (a) waste containers in secondary Make sure that hazardous waste (e.g. excess oil-based paint and sludge) is collected, removed, and disposed of only at authorised disposal areas. past site uses and activities • detected or undetected spills and leaks • acid or alkaline solutions from exposed soil or rock formations high in acid or alkaline-forming elements Contractors may be liable for clean-up costs when they unknowingly move contaminated soil. This highlights the need for contractors to confirm that a site assessment has been completed before earth moving commences. To prevent or reduce the discharge of pollutants to stormwater from contaminated soil and highly acidic or alkaline soils, conduct pre-construction surveys, inspect excavations regularly, and remediate contaminated soil promptly. (b) Actions and Measures • If necessary, conduct thorough site planning preconstruction geologic surveys. • Look for contaminated soil as evidenced by discoloration, odours, differences in soil properties, Urban Stormwater Management Manual
  • 9. Contractor Activity Control Measures abandoned underground tanks or pipes, or buried debris. • If the soil is contaminated, work with the DOE and/or Local Authority to develop options for treatment and/or disposal. (c) Maintenance Requirements • Implement spill prevention and control to prevent leaks and spills as much as possible. (d) Limitations wash out wastes into the temporary pit where the concrete can set, be broken up, and disposed of properly • When washing concrete to remove fine particles and expose the aggregate, avoid creating runoff by draining the water to a bermed or level area. • Do not wash sweepings from exposed aggregate concrete into the street or a stormwater drain. Collect and return sweepings to an aggregate base stockpile, or dispose of in a waste storage bin. Conduct daily inspections of excavated areas for signs of contaminated soil. • locate washout areas at least 15 m from stormwater drains, open ditches, or water bodies. Do not allow runoff from this area by constructing a temporary pit or bermed area large enough for liquid and solid waste ° Test suspected soils at a certified laboratory. • For on-site washout: ° Prevent leaks and spills to the maximum extent practicable. Contaminated soil can be expensive to treat and/or dispose of properly. However, addressing the problem before construction is much less expensive than after the structures are in place. • • (c) Maintenance Requirements • Inspect subcontractors to ensure that concrete wastes are being properly managed. If using a temporary pit, dispose of hardened concrete on a regular basis. • Contaminated soils that cannot be treated on-site must be disposed of by a licensed hazardous waste contractor. • • The presence of contaminated soil may indicate contaminated water as well. 40.4.5 Sanitary/Septic Waste Management 40.4.4 Concrete Waste Management (a) (a) Description To prevent or reduce the discharge of pollutants to stormwater from concrete waste by conducting on-site washout in a designated area. (b) Actions and Measures Description To prevent or reduce the discharge of pollutants to stormwater from sanitary/septic waste by providing convenient, well-maintained facilities and arranging for timely service and disposal. (b) Actions and Measures Sanitary or septic wastes should be treated or disposed of in accordance with Federal, State, or local requirements. These requirements may include: • Store dry and wet materials under cover, away from stormwater drainage areas. • Locate sanitary facilities in a convenient location. • Avoid mixing excess amounts of fresh concrete or cement on-site. • Untreated raw wastewater should not be discharged or buried. • Perform washout of concrete trucks in designated areas only. • Temporary septic systems should treat wastes to appropriate levels before discharging. • Do not wash out concrete trucks into stormwater drains, open ditches, streets, or streams. • If using an on-site disposal system, such as a septic system, comply with local health agency requirements. • Do not allow excess concrete to be dumped on-site except in designated areas. • Temporary sanitary facilities that discharge to the sewer system should be properly connected to avoid illicit discharges. Urban Stormwater Management Manual 40-7
  • 10. Contractor Activity Control Measures • Sanitary/septic facilities should be maintained in good working order. • 40.5.2 Vehicle and Equipment Fuelling Arrange for regular waste collection by a licensed subcontractor before facilities overflow. (c) Maintenance Requirements • Inspect facilities regularly. • Arrange for regular waste collection. 40.5 VEHICLE AND EQUIPMENT MANAGEMENT 40.5.1 Vehicle and Equipment Cleaning (a) Descriptions Fuelling vehicles and equipment in areas where fuel can spill or leak onto paved surfaces or into drainage pathways can pollute stormwater. To prevent fuel spills and leaks and reduce their impacts to stormwater, use off-site facilities, fuel in designated on-site areas only, enclose or cover stored fuel, implement spill controls, and train employees and subcontractors. (b) Actions and Measures • (a) Description Use approved off-site commercial fuelling facilities where available. • If fuelling occurs on-site; use designated areas, located away from stormwater drains to prevent the runon of stormwater and the runoff of spills. To prevent or reduce the discharge of pollutants to stormwater from vehicle and equipment cleaning by using off-site facilities, or designated, contained on-site areas where discharge to stormwater drains is prevented by infiltrating or recycling the wash water. • Always use secondary containment, such as a drain pan or drop cloth, when fuelling to catch spills/leaks. • Place a stockpile of spill cleanup materials where it will be readily accessible. (b) • Use adsorbent materials on small spills rather than hosing down or burying the spill. Remove the adsorbent materials promptly and dispose or properly. • Avoid mobile fuelling of mobile construction equipment around the site, transport the equipment instead to designated fuelling areas. With the exception of tracked equipment such as bulldozers and perhaps forklifts, most vehicles should be able to travel to a designated area with little lost time. • Train employees and subcontractors in proper fuelling and cleanup procedures. Actions and Measures • Use off-site commercial washing facilities if available. • If washing must occur on-site, use designated bermed wash areas to prevent wash water from discharging into stormwater drains, streams, and other water bodies. The wash area can be sloped for wash water collection and subsequent infiltration into the ground. • Use as little water as possible to avoid having to install erosion and sediment controls for the wash area. • Preferably use phosphate-free, biodegradable soaps. • Do not permit steam cleaning on-site. Steam cleaning can generate significant pollutant concentrations. (c) Maintenance Requirements Limitations Even phosphate-free, biodegradable soaps have been shown to be toxic to fish before the soap degrades. 40-8 • Keep ample supplies of spill cleanup materials on-site. • (c) Regularly inspect fuelling areas and storage tanks for leaks and signs of corrosion. Urban Stormwater Management Manual
  • 11. Contractor Activity Control Measures 40.5.3 Vehicle and Equipment Maintenance (c) Maintenance Requirements • Keep ample supplies of spill cleanup materials on-site. • Regularly inspect maintenance areas and workshops. 40.6 (a) EMPLOYEE/SUBCONTRACTOR TRAINING Description Maintaining vehicles and equipment outdoors or in areas where vehicle or equipment fluids may spill or leak onto the ground can pollute stormwater. To prevent or reduce the discharge of pollutants to stormwater from vehicle and equipment maintenance, it is better to run a “dry site”. This involves using approved off-site facilities, performing work in designated areas only, providing cover for materials stored outside, checking for leaks and spills, and containing and cleaning up spills immediately. (b) Actions and Measures (a) Employee and subcontractor training, like maintenance or a piece of equipment, is a method to implement BMPs rather than a BMP in itself. Training is extremely important and the elements of employee and subcontractor training from the individual source controls should be integrated into a comprehensive training program as part of a company’s integrated ESCP. • Keep vehicles and equipment clean, don’t allow excessive build-up of oil and grease. • Consider using off-site facilities to maintain vehicles and equipment. • If maintenance must occur on-site, use designated areas, located away from stormwater drains to prevent the runon of stormwater and the runoff of spills. • On large sites, establish a properly equipped, covered workshop on-site for maintenance. • Always use secondary containment, such as a drain pan drop cloth, to catch spills or leaks when removing or changing fluids. • Place a stockpile of spill cleanup materials where it be readily accessible. • Use adsorbent materials on small spills rather than hosing down or burying the spill. Remove the adsorbent materials promptly and dispose of properly. • Regularly inspect on-site vehicles and equipment for leaks and repair immediately. • Check incoming vehicles and equipment for leaking oil and fluids. Do not allow leaking vehicles or equipment on-site. (c) • Segregate and recycle wastes, such as greases, used oil or oil filters, cleaning solutions, automotive batteries, and hydraulic and transmission fluids. Train employees and subcontractors in proper maintenance and spill cleanup procedures. Urban Stormwater Management Manual Description The specific employee and subcontractor training aspects of each of the source control are highlighted in the previous sections of this chapter. The focus of this section is more general, and includes the overall objectives and approach for assuring that all employee and subcontractor are properly trained in stormwater pollution prevention. (b) Objectives Employee and subcontractor training should be based on four objectives: • To promote a clear identification and understanding of the problem, including activities with the potential to pollute stormwater. • To identify solutions (BMPs) to stormwater pollution problems. • To promote employee and subcontractor responsibility and accountability for the problems and solutions. • To integrate employee and subcontractor feedback into training and BMP implementation. Approach • Integrate training regarding stormwater quality management with existing training programs that may be required by other regulations. • Train employees and subcontractors in standard operating procedures and spill cleanup techniques. Employees or subcontractors trained in spill 40-9
  • 12. Contractor Activity Control Measures containment should be present during the loading, unloading, and handling of materials. • Personnel who use pesticides should be trained in their use. The Authority shall license pesticide dealers, certify pesticide applicators, and conduct onsite inspections. 40-10 • Proper education of off-site contractors is often overlooked. The conscientious efforts of well-trained employees and/or subcontractors can be lost by unknowing off-site contractors, therefore, make sure they are well informed about what they are expected to do on-site. Urban Stormwater Management Manual