Asbestos Containing Material

• A full inventory of asbestos containing material (ACM) in the facility should be conducted. The inventory should identify materials, locations and condition. Materials may include insulation, floor tiles, roofing material, valve gaskets and other common building materials.
• Periodically inspect asbestos containing materials to assess changes in condition.
• All known ACM should be labelled to prevent inadvertent disturbance.
• When planned maintenance, repair and modification work has the potential to disturb ACM, consider removing the asbestos that will be disturbed and replacing it with non-asbestos material.
• All personnel in the facility should have asbestos awareness training to understand where asbestos is in the facility and what to do if it is disturbed.
• The facility emergency plan should include a scenario for response to an unplanned release of ACM. The response should include:
  - Shutting down ventilation systems in the affected area.
  - Evacuation of personnel from the area.
  - Placing barricades and signs to prevent personnel from entering the area.
  - A means such as an on call contract for an asbestos abatement firm to clean up the release and sample and confirm clean up.
• All asbestos related work, including inventory, inspection, abatement work and abatement planning should be performed by qualified and trained personnel that meet the training requirements outlined in the regulations for their areas of responsibilities.
• Remove all ACM from a facility being demolished or renovated before any disruptive activity begins.
• Keep ACM adequately wet before, during and after removal operations. To "adequately" wet asbestos-containing material means to sufficiently mix or penetrate the material with liquid to prevent the release of particulates or fibers. If visible emissions are observed coming from the material, then it has not been adequately wetted.
• After it is wetted, bulk asbestos waste must be containerised before it is transported. Seal the waste material in leak-tight containers while it is wet and label the containers appropriately. If the waste will not fit into containers, place it in leak-tight wrapping.

Blowdown Water

Mitigating the potential impact of a power plant's blowdown water (or "boiler blowdown") on the environment may be accomplished by reducing both the volume and hazardous make up of blowdown water through one or more of the practices described below.

• Minimise the volume of blowdown water by optimizing the frequency of cleaning boilers. One or a combination of the following practices are worth considering:
  - Conducting frequent chemical analyses to define normal cycle chemistry will facilitate identifying when the chemistry is abnormal and, therefore, when cleaning should take place.
  - Consider using such techniques as ultrasonic imaging, thermocouples, removable test strips and fiberscopic inspections to determine the location and/or type of deposits.
  - Consider sampling the boiler tubes annually to track scale build-up.
• Consider controlling the composition of the boiler feed water through an elevated oxygen treatment process (as opposed to using chemical additives such as hydrazine and morpholine) - which has been found to result in a more unified, finer-grained magnetite layer that requires less frequent cleaning.
• Consider inspecting for and replacing seals on the steam cycle appurtenances - which will potentially reduce the amount of oxygen that enters the system and, in turn, the frequency of boiler cleanings.
• Consider establishing a boiler cleaning frequency that is set according to the build-up of scale, rather than simply a predetermined schedule. This may reduce unnecessary cleanings.
• Consider using on-line cleaning, which entails cleaning the boiler with a sodium polyacrylate injection while it continues to operate. This practice takes less time, uses less hazardous chemicals and yields a waste stream that is easier to handle; however, the associated risk is potential contamination of the steam turbine. In addition, fewer deposits can be removed with this practice.

Cooling Water

Reducing the potential impact of a power plant's cooling water on the environment may be accomplished by one (or a combination of) of the maintenance and operational practices described below.

Maintenance Practices

• Maintain the cooling tower properly, i.e., according to the manufacturer's specifications. This will ensure the equipment operates efficiently and properly - which will potentially reduce the amount of contaminants found in cooling water. Scheduling routine monitoring and maintenance activities are additional ways to maintain the cooling tower(s) effectively.
• Include guidelines addressing chemical substitution options into service contracts to ensure potentially hazardous additives are not used or their use is minimised.
• During repair or reconstruction of existing open recirculating tower systems, limit the use of copper based materials - which will potentially reduce the metal content of cooling water discharges.

Alternative Operational Practices

• Identify the optimal chemicals for the prevention of biological growth and corrosion. For example, chlorinated biocides are less toxic than brominated biocide; and polyphosphate and organophosphate inhibitors are less toxic than chromate corrosion inhibitors.
• Consider using electrically powered water conditioning units. For example, automatic bleed/feed controllers enables the facility to continuously monitor the concentration of dissolved material in the cooling water. When the concentration exceeds a preset level, the controller opens the bleed valve and activates the chemical feed pump, thereby keeping the tower at the optimal concentration at all times and unintentional discharge of active chemicals is eliminated.
• Consider magnetic water conditioning - which reduces the need for chemical additives.
• Consider using ozone treatment in lieu of common biocide use. However, several documented disadvantages associated with this practice need to be weighed: 1) the potential for corrosion in cooling towers unless careful dosing of ozone practiced; 2) potential rapid fouling on high temperature surfaces in recirculating systems; and 3) health and safety issues related to potential worker exposure to ozone.
• Consider pretreating makeup water to reduce the chemical treatment requirements for scale and corrosion control and increase the ability to recycle the water.
• Consider using materials of construction for cooling tower equipment and piping such as polyethylene, titanium, and stainless steel, which require less scale/corrosion inhibitors.

PCBs

• Establish and maintain a PCB management system that includes proper identification, marking, record keeping, inspection, and testing of PCB related equipment.
• Training programs should include hazards associated with PCBs and procedures for proper storage and disposal.
• Emergency response and SPCC Plans should include sections on how to prevent and respond to potential spills or releases of PCBs or PCB contaminated material.
• Label all equipment that contains oil as "PCB contaminated material" or as "non-PCB contaminated" equipment.
• To the extent reasonable and cost effective, replace PCB materials and PCB contaminated materials with non-PCB products. Equipment that no longer contains PCBs or PCB contaminated material can then be reclassified and labelled as "non-PCB contaminated".
• Assign responsibility and accountability for PCB items to specific personnel.
• Test bulk used oil for PCBs if there is reason to believe the oil may be contaminated with PCBs.

Recycling

• Maintain an inventory of used equipment, tools, solvents, paints and cleaners that can be used by other departments at the school. Train employees to check inventory of materials on hand before purchasing new items, chemicals, paints and cleaners.
• Used oil, and lubricants can be added to fuel oil and burned in oil burners and furnaces or sent off site to be refined and reused. (Note: Special regulations apply to using used oil as a fuel or fuel additive. Check the Used Oil section of the EVC.)
• Investigate the potential for using your local community for recycling programmes for:
  - Lead Acid Batteries
  - Pallets
  - Drums and containers
  - Toner cartridges
  - Paper and cardboard
  - Glass
  - Copper and other metals

Stormwater

• Maintain good housekeeping. Keep outdoor areas clean and free from litter. Sweep footpaths and roads.
• Cover all waste bins to prevent the infiltration of rainfall or snow, which can leach out oil and other contaminants that would end up in the storm drains.
• Prevent and respond to spills quickly. Do not let material enter the storm water collection system. Keep adequate spill response kits and equipment available to respond to spills of oil, fuel, grease and other material. Train responders in proper response procedures.
• Think about how you might control or eliminate potential sources of storm water pollution. For example:
  - Minimise the use of fertilisers, pesticides, herbicides, perhaps by implementing an Integrated Pest Management (IPM) programme.
  - Don't allow run off from non-permitted activities such car or vehicle washing to enter sewers or drains.
  - Focus irrigation water so that paved areas such as sidewalks, roadways and parking lots are not wetted, leading to unnecessary runoff.
  - Clean up leaves and lawn clippings so they don't enter storm water collection systems and potentially clog them.
  - Encourage employees to not litter. Place bins in strategic locations and maintain them periodically.
• Train employees in the importance of storm water pollution control. Some employees should be trained in spill response techniques. All should be trained to not discharge material to the storm water collection system.
• Invest in appropriate treatment and storm water control infrastructure including drop inlets, channels, retention and detention basins, treatment vaults, infiltration galleries, filters, oil/water separators, etc.
• Use riprap, vegetation, and other slope stabilisation techniques to control sediment and erosion. Make it a project requirement to control runoff from construction and excavation activities.
• Perform periodic inspections to identify potential sources of storm water pollution and assess effectiveness of control measures.

Storage Tanks

• Facilities with tanks should designate a department and/or a specific person to be responsible and accountable for tank condition, material and maintenance.
• Inventory and assess the condition, use and need for storage tanks. For tanks that are not needed remove or decommission tanks in accordance with local regulatory requirements.
• All tanks should be included in the Spill Prevention, Control, and Countermeasures (SPCC) Plan, if one is required for that facility. The plan should meet regulatory requirements and include anticipated release scenarios and describe the facility's means of responding to spills and releases of stored material. The facility should maintain adequate spill control equipment and train personnel to be able to stabilise the largest anticipated release.
• All tanks should have secondary containment.
• All tanks should have a leak detection system appropriate for the tank contents, size and material of construction. This system should be checked at least every 30 days.
• Spill buckets should be installed at fill points to contain drips and spills that may occur during delivery. Keep spill buckets clean and free of liquid and debris.
• Tanks should have overfill protection systems installed that may include automatic shutoff devices, overfill alarms or ball float valves. Be sure the delivery person knows what type of overfill protection your tank has.
• Be sure you order the correct amount of product for delivery. Accept only the amount of product that will fill the tank to 90% of capacity. Make sure to account for product already in the tank.
• Staff should monitor product delivery to ensure overfilling do not occur and be available to respond to spills if they occur.
• Be prepared to respond to releases. Be sure all personnel involved with tank operation and maintenance are familiar with the SPCC plan. Perform practice drills. If a spill or release occurs:
  - Take action as soon as possible that does not endanger personnel to prevent release of additional product.
  - Turn power off to the dispenser. For flammable or combustible material keep ignition sources away from the release area.
  - Contain the pill or release in accordance with your SPCC plan.
  - Report releases or suspected releases to local regulatory agencies in accordance with local regulations.
• Maintain records of:
  - Inventory control.
  - Release detection inspections.
  - Maintenance activities.
  - Spills and releases and responses.

Used Oil

• Label all containers and tanks with the appropriate label depicting the containers' contents.
• Keep containers and tanks in good condition. Don't allow tanks to rust, leak or deteriorate. Fix structural defects immediately.
• Never store used oil in anything other than tanks and storage containers. Used oil may also be stored in units that are permitted to store regulated hazardous waste.
• Take steps to prevent leaks and spills. Keep machinery, equipment containers, and tanks in good working condition and be careful when transferring used oil. Have absorbent materials available on site.
• If a spill or leak occurs, stop the oil from flowing at the source. If a leak from a container or tank can't be stopped, put the oil in another holding container or tank.
• Contain spilled oil. For example, containment can be accomplished by erecting absorbent berms or by spreading a sorbent over the oil and surrounding area.
• Clean up the oil and recycle the used oil, as you would have before it was spilled. Remove, repair or replace the defective tank or container immediately.
  
  Maintenance Practices

• Maintain cooling towers to the manufacturer's specifications by scheduling routine monitoring and maintenance activities.
• Include specific language in service contracts encouraging vendors to substitute less toxic chemicals where feasible.
• During repair or reconstruction of existing open recirculating tower systems, limit the use of copper based materials.

Alternative Operational Practices

• Consider using electrically powered water conditioning units. For example, automatic bleed/feed controllers enables the facility to continuously monitor the concentration of dissolved material in the cooling water. When the concentration exceeds a preset level, the controller opens the bleed valve and activates the chemical feed pump, thereby keeping the tower at the optimal concentration at all times. Unintentional discharge of active chemicals is minimised in this manner.
• Consider magnetic water conditioning - which reduces the need for chemical additives.
• Determine optimal chemicals for the prevention of biological growth and corrosion. For example, chlorinated biocides are less toxic than brominated biocides; and polyphosphate and organophosphate inhibitors are less toxic than chromate corrosion inhibitors.
• Consider using ozone treatment in lieu of common biocide use. However, several documented disadvantages associated with this practice need to be weighed: 1) the potential for corrosion in cooling towers unless careful dosing is practices; 2) potential rapid fouling on high temperature surfaces in recirculating systems; and 3) health and safety issues related to potential worker exposure to ozone.
• Pretreat makeup water to reduce the chemical treatment requirements for scale and corrosion control and increases the ability to recycle the water.
• Consider using polyethylene, titanium, and stainless steel materials of construction for cooling tower equipment and piping instead of materials such as stainless steel because they requires less scale/corrosion inhibitors.