Region 1: EPA New England

Common Violations

Common Violations - Found by EPA Inspectors at Municipal Vehicle Maintenance Facilities

Waste Containers – Labeling

• Label drums, tanks and other containers with the name of the material they hold (for example, waste oil) AND the type of hazard they present (example, flammable).

• Label waste containers with the date when contents were first added.

Waste Containers – Storage

• Indoors & outdoors: store waste containers on an impervious surface and provide secondary containment in case of leaks or spills.

• Containers must be appropriate for the waste they hold, in good condition, kept closed except briefly while in use, and inspected regularly.

• Identify and properly dispose of outdated, unused, forgotten or "donated" materials that may be hazardous, including paints.

Floor Drains

• You must know where pipes from all the facility's floor drains lead.

• Floor drains may not discharge to groundwater, surface water or land.

• Floor drains should discharge to the sanitary sewer (with approval from the sewer authority) OR should be equipped with an approved tight tank which is pumped out regularly by a licensed hauler.

Parts Cleaner Sink

• To reduce air pollution, the lid should be kept closed, except when the sink is in use.

Salt Storage

• Store road salt in a shed so that so that storm water cannot wash it into a storm drain, water body or ground water.

• Sweep up salt and salt/sand mixture spilled in the yard so it cannot wash away.

Spill Cleanup

• Some states handle unsaturated oily absorbents as a solid waste, which can be disposed of in the trash. Other states consider unsaturated oily absorbents as a special waste which has specific disposal requirements. Check with your state environmental agency for your state’s requirements.

• Place oily shop rags in sealed, labeled metal containers and have them laundered by a licensed facility.

Spill Prevention

• Facilities that store 42,000 gallons below ground (not regulated under UST) or 1,320 gallons or more of oil (used and new oil, heating oil, engine oil, lube oil) above ground must develop and implement a Spill Prevention, Control and Countermeasure Plan. Plans must be immediately available and reviewed/revised every five years.

MSDSs

• Material Safety Data Sheets should be current and accessible for every product used and stored at the facility.