Source Water Protection Hazardous Materials

Hazardous Materials

Businesses, governmental agencies, institutions and other organizations can use or store hazardous materials. For purposes of this document, hazardous materials include chemicals used in industrial and commercial processes. In addition, although not usually considered hazardous materials, salt/sand mixtures stored for road de-icing, street sweepings, and residue from vehicle washing and storage sites are included here. These materials can be found in a variety of settings, ranging from retail stores to local public works departments to large industrial organizations. In working on managing such materials locally, it will be important to work closely with local fire marshals and emergency response offices, since many issues relating to hazardous materials are handled by these authorities.

This document focuses on ways to manage hazardous materials in wellhead protection areas. Separate documents address management strategies for hazardous wastes and household hazardous wastes.

The following is a list of activities a public water supplier could choose to include in Wellhead Protection plans. These activities are not required of public water suppliers, but provide a menu of choices -- the methods chosen will depend on the local situation.

Education:

If a public water supplier chooses to focus on hazardous materials in the wellhead protection area, education should be included as a component of the management plan, regardless of whether other methods are also used. Messages to highlight in an educational program on hazardous materials include:

importance of proper handling of hazardous materials in wellhead protection area (making the connection between personal actions and the water supply)
reducing hazardous materials usage
importance of proper use, transportation and storage of hazardous materials
proper response procedures for spills

Listed below are a variety of educational activities that public water suppliers can undertake; these can be used as stand-alone educational activities or paired with voluntary practices or regulatory activities to help manage hazardous materials.

Information Packets. Public water suppliers can use information packets to reach organizations on salt storage, vehicle washing, spill prevention and response, and other hazardous materials issues.

Information packets can be distributed in a number of ways. Personal visits may be the most effective. Direct mail (flyers or water utility bill stuffers) and passive distribution methods such as making print information available at city halls, fire halls, libraries, community bulletin boards, and special events can also be used. When distributing information to residents of the wellhead protection area, public water suppliers may want to use existing, organized groups to assist in the task, such as lake associations, homeowners groups, or senior citizen organizations.

Special Events: Several types of events are available, which public water suppliers can sponsor or participate in. These events offer a good opportunity to emphasize the importance of proper hazardous material handling in the wellhead protection area:

Meetings/workshops for business people: This type of meeting can be sponsored by the water supplier or in conjunction with the Chamber of Commerce, Kiwanis, Rotary, Lions or other service organizations. The public water supplier can arrange for speakers on hazardous materials management, along with making information packets available. This type of meeting could also include a discussion of hazardous wastes. Another option would be to sponsor a workshop for businesses handling hazardous materials. The local Fire Marshal, county staff or the Minnesota Technical Assistance Program may be willing to provide information to a group of local businesses on hazardous material use, storage and transportation and reducing the use of hazardous materials.

Fairs and festivals: Public water suppliers can sponsor or co-sponsor a booth at community fairs and festivals. Annual wellhead protection festivals, county fairs, County Ground Water Festivals, Public Works Department Open Houses, and Lake Association "Lake Days" offer opportunities for water suppliers to highlight the Wellhead Protection area and provide handouts.

Demonstration projects: Demonstration projects can be an effective educational tool. At the local level, a public water supplier can work with a business to host an "open house" to provide ideas on correct hazardous material handling and storage for other local businesses, as well as ideas on reducing hazardous material use. As an alternative, public water suppliers may consider hosting an open house at the city public works department to demonstrate best management practices for salt storage, vehicle washing and hazardous material storage.

Recognition Programs. Cities could establish recognition programs (businesses could become "Wellhead Protectors," for example) for businesses handling both hazardous materials and waste. Cities could provide certificates, plaques or other recognition awards to businesses meeting certain criteria established by the city.

Signage: Public water suppliers can provide roadside signs indicating the boundaries of the wellhead protection area and encouraging transporters to drive carefully and avoid hazardous material spills/accidents. In some communities around the country, speed limits are reduced on roadways within wellhead protection areas and hazardous material transportation routes are re-routed outside of wellhead protection areas.

Signage can also be used at locations where hazardous materials are in use. Public water suppliers can provide signs to place near loading docks and other locations where hazardous materials are loaded and unloaded. These signs should indicate the need for avoiding spills, along with the need to quickly respond to spills that do occur.

Newsletters. Articles in newsletters can be useful in educating a wide variety of audiences. Public water suppliers may consider developing a newsletter specifically for landowners in the wellhead protection area. This type of newsletter can highlight a variety of issues related to the "special protection area" nature of the area and include information on hazardous materials.

Services:

In addition to education, public water suppliers can provide services to help manage a particular contaminant source. These services go beyond education but do not involve regulation. For hazardous materials, services can include both technical assistance and financial assistance.

Activities undertaken by public water suppliers to assist organizations with hazardous materials management fall into the technical assistance category. Also included here are monitoring activities that may be instituted to track changed practices and potential problems.

Design and Operation Assistance. Public water suppliers can work with businesses handling hazardous materials in the wellhead area to ensure the design and operation of the businesses will help prevent ground water contamination. Public water suppliers can provide such assistance directly or work with local fire officials to incorporate wellhead protection concerns into existing assistance efforts. This technical assistance can take a variety of forms:

Provide technical assistance on reducing the use of hazardous materials in particular businesses. Minnesota Technical Assistance Program (MnTAP) staff may be able to assist with this.
Assist businesses in developing spill contingency plans and conducting spill response training, pollution prevention plans, and spill- and fire-prevention storage practices. Spill prevention strategies can include moving hazardous material activities indoors (away from floor drains), installing spill containment methods (curbing, containment dikes, etc.) and covering and providing an impermeable surface for materials stored outdoors. Staff responding to spills should be knowledgeable about use of spill equipment, preventing spills from reaching stormwater drainage ways, and cleanup and disposal of spilled materials.
Assist businesses in securing all necessary permits and licenses, in coordination with state and local agencies. As new organizations locate in the wellhead protection area, public water suppliers can provide an environmental permits checklist.
Assist businesses with internal tracking of hazardous material usage to help in reducing the quantities of hazardous materials stored on site. Public water suppliers can provide a tracking sheet or spreadsheet to do this.
Assist businesses in implementing Best Management Practices for outdoor vehicle and equipment washing, outdoor vehicle maintenance, material loading and unloading and de-icing sand/salt storage. Best management practices for vehicle washing include using detergents that are biodegradable and contain no phosphates, recycling the washwater or ensuring that washwater is discharged to a wastewater treatment facility. For vehicle maintenance, the use of drip pans underneath vehicles or moving the maintenance activities indoors are effective. Material loading and unloading areas should be covered with a building overhang or awning. Sand and salt should be protected from rainfall with a tarp or other covering and stored on an impermeable surface or stored indoors.
Work with city staff to find appropriate sites for use of street sweepings as fill material.
Work with local authorities to reduce speed limits on transportation routes within the wellhead protection area, to reduce the risk of hazardous materials transportation accidents.

Monitoring. Monitoring includes a variety of tracking/evaluation activities, as well as ground water monitoring. In general, monitoring activities may require follow-up actions if monitoring indicates potential problems.

Inventory the types and quantities of hazardous materials normally stored at businesses in the wellhead protection area (use existing information, where possible, such as information provided under the Community Right to Know program). By doing this, public water suppliers may be able to determine where to target assistance efforts.
Provide site visits to ensure that storage of hazardous materials meets the isolation distances in the state well code, that hazardous materials are being stored in a safe manner and that spill response equipment is available on site.
Review contingency plans developed under the Community Right to Know program and site plans for new businesses to ensure that these plans are protective of the wellhead protection area.
Public water suppliers may choose to conduct periodic soil or ground water sampling in the wellhead area, as an early-warning system to alert the city to potential contamination before it reaches the water supply well.

Grants and Loans. Public water suppliers can act as an information and referral service for available grants and loans. Existing grant and loan programs include County Challenge Grants, available through your county water planning office and Pollution Prevention Grants, available through the Office of Environmental Assistance. In some cases, public water suppliers may choose to establish grant and loan programs for wellhead protection activities.

Public water suppliers can promote the availability of grants and loans to businesses handling hazardous materials through flyers and direct mail. Grants and loans can be used for a variety of activities:

Developing pollution prevention plans to reduce the use of hazardous materials in the wellhead protection area
Implementing best management practices, operational controls and/or building design practices to reduce leaks and spills and to minimize risks from storage practices
Reducing outdoor storage of hazardous materials or encouraging outdoor storage on impermeable, curbed surfaces in a secure, covered area
Disconnecting floor drains in hazardous material storage areas
Installing secondary containment (curbing, containment dikes) for hazardous material storage areas
Finding alternative sites outside of the wellhead area for use of street sweepings as fill
Reducing the quantities of hazardous materials stored in the wellhead protection area (e.g., financial incentives to cap the amount of hazardous materials stored on site)
Encouraging new businesses that use lower volumes of hazardous materials to locate in the wellhead area
Relocating high-volume hazardous material operations to areas outside the wellhead protection area.

Regulation:

Regulation is another category of methods a public water supplier can undertake to manage hazardous materials in a wellhead protection area. In many cases, education and services will be preferable to regulatory actions. If regulation is chosen, public water suppliers should work closely with the businesses in the wellhead protection area to develop workable regulatory programs.

In undertaking the regulatory activities listed below, public water suppliers will also need to work closely with local planning and zoning commissions with jurisdiction in the wellhead protection area.

Work with existing regulatory programs. Public water suppliers should work closely with state and local regulators, including the fire marshal, on regulatory efforts. Public water suppliers could explore the possibility of prioritizing wellhead protection area businesses for technical assistance and inspections by state and local programs.

Adopt Ordinances related to hazardous materials: Public water suppliers could explore adopting hazardous-material ordinances. The Ramsey County Soil and Water Conservation District has developed a hazardous material ordinance for wellhead protection areas. Some options for specific ordinances are listed below:

Requiring an environmental permits checklist and local review of site plans for new businesses
Requiring contingency plans to be filed with the public water supplier
Requiring local registration of the types and quantities of hazardous materials used by businesses in the wellhead protection area
Requiring businesses to track in-house use of hazardous materials
Prohibiting floor drains and requiring secondary containment (curbing, containment dikes) for hazardous material storage areas
Prohibiting use of street sweepings as fill in wellhead protection areas
Requiring impermeable, curbed surfaces and covered storage areas for outdoor storage
Requiring implementation of best management practices for salt storage and vehicle washing
Requiring periodic ground water monitoring in certain circumstances. For example, locations where large volumes of hazardous materials are used or where there is reason to suspect a problem is occurring could be required to conduct sampling as an early-warning-system to detect ground water contamination before it reaches the water supply.

Phase-Out Zoning: In Dayton, Ohio, the city developed a scoring system for businesses located in the wellhead protection area, based on the quantities and toxicity of hazardous substances and wastes used and produced. Each business receives a numerical score. When a business in the wellhead protection area relocates or leaves the area, the city ordinance requires that the next business to occupy the property must have a "score" equal to or less than the previous business’ score.

Prohibitive Zoning: A number of wellhead protection programs across the country have adopted ordinances prohibiting new businesses involving hazardous substances or wastes from locating in the wellhead area, creating "green spaces." If public water suppliers are considering this type of ordinance, they will need to work very closely with the Planning and Zoning Commission of the local unit of government with jurisdiction in the wellhead area.