Government of New York



Bridge Maintenance Skills Training

Program of Instruction

SECTION : I. Safety

Lesson: A7 Environmental Awareness

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TRAINING OBJECTIVES:

After this presentation, the employee will be able to recognize the most common environmental issues related to bridge maintenance activities and explain how to prevent or resolve them.

MATERIALS, RESOURCES, TRAINING AIDS:

NYSDOT Environmental Handbook of Transportation Operations

NYSDOT Fundamentals of Bridge Maintenance & Inspection

NYSDOT Safety Manual

NYSDOT Engineering Instruction (EI) 07-032. Maintenance Cleaning and Washing of Bridges (US Customary Units)

LESSON:

The New York State Department of Transportation (NYSDOT) is firmly committed to environmental excellence in providing a safe, efficient, balanced, and environmentally sound transportation system in the State of New York. Achieving this mission requires NYSDOT to conduct maintenance, manage equipment, and perform construction activities appropriately to prevent and/or minimize adverse impacts to the environment.

The NYSDOT must ensure compliance with various and complex federal and state environmental regulations covering all aspects of the environment. This lesson is intended to provide NYSDOT personnel with general awareness and guidance of the primary requirements that apply to the types of activities conducted by NYSDOT Operations. It is not intended to substitute for the actual regulations and interpretations by the environmental units that may be required for specific issues but, rather to serve as a summary of typical issues and as a flag for certain issues that may require more assistance from the Maintenance or Construction Environmental Coordinator (MEC and CEC, respectively), Regional Landscape Architecture/Environmental Services Unit (RLA/ESU) and/or other appropriate resource personnel. NYSDOT Operations activities are typically associated either with work conducted along the right-of-way (ROW) or as facility-based activities conducted at a residency or shop. In general, the environmental requirements are described in the context of the operation or type of facility or equipment most affected by the issue. The requirements, however, may affect multiple activities and operations and cross reference may be required. Since regulations and activities are frequently changing, this lesson is intended to be a working document that is updated periodically.

TRAINING OBJECTIVE 1

The employee will learn about environmentally safe work practices related to:

➢ Stream Work

➢ Bridge Washing

➢ Weathered Paint

➢ Air Quality

STREAM WORK:

➢ Streams classified as A, A(T), A(TS), AA, AA(T), AA(TS), B, B(T), B(TS), C(T), C(TS) are Protected Streams. Must coordinate washing schedule with restocking and breeding seasons. Information on the classification of a stream can be obtained from the regional Maintenance Environmental Contact (MEC) or the New York State Department of Environmental Conservation (NYSDEC) office. There is an MEC available in each regional office to answer any questions regarding environmental issues.

➢ The primary concerns regarding Protected Streams are degradation of trout spawning habitat, decreased fish egg survival due to heavy sediment loads, and various fish and wildlife concerns due to concentrated areas of salt, lead (from lead paint), and ammonia (from bird droppings), as well as temperature changes.

➢ Do not use machinery in a stream channel unless absolutely necessary. Work should be done from above if possible. If a job requires using equipment in a stream, keep all work within 50 feet of the bridge. For activities that require operating machinery in a Protected Stream, or dewatering a stream channel, schedule them between May 15 and September 30 to avoid trout spawning periods.

➢ Structures over Protected Streams should be washed only at times when stream flows are high enough to disperse effects. This is generally from early spring though early summer. However, washing shall be cancelled if stream flow drops below normal at any time.

Note: DEC stocks certain streams with trout between March 15 and May 15, which is also the ideal time to wash bridges over protected streams because water levels are usually the highest. It is important that bridge washing is NOT conducted during/immediately after the stream beneath the bridge is stocked. Contact your MEC or the DEC office for a stocking schedule, and plan bridge washing accordingly.

➢ Concrete chunks or dust, abrasives (like Black Beauty), asphalt chunks, debris from welding or torch cutting, sediment, and any other waste materials may not enter a stream or wetlands. These products may alter the stream bed, or release chemicals that degrade water quality, affecting the food chain and fish egg development. These materials must be disposed of as C&D Debris at suitable locations on NYSDOT property or taken to an off-site disposal facility that charges no fees and operates only during daylight hours (such as facilities requesting fill at no charge). Do not place this material within 30 feet of wetlands, archeological sites, or other sensitive environmental areas.

➢ NYSDEC regulations include Water Quality Standards for turbidity, oil, and other substances that apply to all surface waters. For turbidity, the standard is “no increase that will cause a substantial visible contrast to natural conditions”

➢ A permit from the NYSDEC Regional Wildlife Manager is required to remove a beaver dam or for trapping/ shooting any beaver outside of hunting season.

➢ Do not remove vegetation from stream bank unless absolutely necessary. If disturbing soil along the bank, use erosion and sediment control measures (including immediate seeding vegetation and mulching with straw, stone and straw check dams, silt fences, and sediment basins.)

➢ When crossing a stream with machinery, use a culvert pipe and gravel to avoid creating tire ruts that cause erosion and sedimentation.

➢ To work in a stream:

□ A permit from NYSDEC is required

□ One must be aware of the classification of the stream, the season, and any relevant trout stocking schedules

□ One must contain all waste products and debris, and dispose of them

off-site

BRIDGE WASHING:

➢ Before washing a bridge, all trash and debris-- such as paper, rubber, metal, wood-- must be collected from the bridge, and properly disposed of off-site according to §107-10 Managing Surplus Material & Waste. Prior to any other cleaning work, confirm that the bridge drainage system is not blocked by un-removable debris by prodding with a sewer rod or similar tool.

➢ Clean all loose sand, dirt, cinders, and similar material from the upper surface of the bridge deck by sweeping, vacuuming, etc. before washing. None of this material should enter a stream below. If the collected material is less than 1 cubic yard, it can be disposed of on the nearby roadside.

➢ Look for areas of loose paint. Do not wash areas with loose paint.

➢ Under the Migratory Bird Treaty Act of 1918, one can be fined up to $15,000 and/or be imprisoned up to half a year for disturbing any migratory bird, or an occupied nest. Some contractors have actually been charged for intentionally destroying migratory bird nests and fledglings while bridge washing. The areas within 3 feet laterally of the nest should not be cleaned or washed; pressure washing should start at the 3 feet line and progress away from the nest.

➢ Before April 15 and after August 15 nests of protected migratory birds on bridges will most likely be inactive and unoccupied. If confirmed to be unoccupied, the nests should be removed before cleaning operations begin.

➢ Migratory Bird Species include but are not limited to: Bald Eagle, Black-capped Chickadee, Cardinal, Black Vulture, Barn Swallow, Cliff Swallow, Sparrow, Barn Owl, Sparrow, Nighthawk, Downy Woodpecker, Mockingbird, Mourning Dove, Red-tailed Hawk, Crow, Raven, Catbird, Titmouse

➢ If water is to be taken from a local source, there may not be any loss of water elevation, at the site or immediately downstream of the site, to protect aquatic life.

➢ When possible, take water from a fire hydrant before taking it from a stream.

➢ To further protect aquatic life, water withdrawal shall be accomplished with use of a screened hose, with a screen size not to exceed ¼” square.

➢ To prevent the unintentional spread of invasive species such as zebra mussels, water withdrawn for washing from a local, on-site water source may not be transported to be used at another bridge site in a different watershed.

➢ If water is taken from an onsite source, equipment must be cleaned prior to leaving that watershed. All small equipment (pumps, hoses, barriers, silt fences, floating booms, cofferdams, shovels, rakes, jumping jacks, plate tampers, boots, buckets, industrial vacuums etc.) and large equipment (backhoes, excavators, trucks, tankers, rollers, trailers,

etc.) that comes into direct contact with water withdrawn from a local on-site water source must be cleaned (internally and externally) by soaking, dipping in, or scrubbing with a chlorine/water solution, and hot water or steam, and allowed to dry before the next use. The provisions of §107-12 Water Quality Protection shall apply when discharging wash water near an original body of water. Otherwise, wash water will be collected in suitable containers and disinfected prior to final disposal.

PAINT REMOVAL:

➢ Bridges built before 1989 may have paints that contain lead and asbestos. Washing of lead-based paint with a rating of 3 or lower must be avoided unless the specifications include instructions for collecting, separating, and disposing of lead-based paint chips. Removing lead-based paint chips requires the use of Class A (total) containment to prevent releasing lead into the environment. Do not proceed with removing procedures unless specifically directed to do so.

➢ In late 1988 the Department changed from lead-based paints to an epoxy and polyurethane system for all new painted bridges.

➢ Paint that does not contain lead used to be considered harmless; however, all paint is now considered hazardous to the environment, and all flaking paint should not be washed at all without the proper specifications.

➢ Paint condition is an important factor in determining whether painted steel should be washed. Ratings can range from a 7 (like-new condition) to a 1 (large patches missing). (See EI 07-032 for a detailed chart)

➢ Bridges with a paint rating of 3 or lower: Clean bridge deck by sweeping as described above. Then wash only the concrete surfaces. Otherwise, paint chips will pollute the environment.

➢ Unlike flaking paint, one should remove all loose rust on weathering steel bridges when washing. Loose rust that remains will eventually drop off and trap moisture on the bottom flange of girders causing accelerated deterioration. Rust chips have not been determined to be harmful to the environment.

➢ For details on weathered paint regulations and weathering steel, see

EI 07-032.

➢ It is very important to note that flaking lead-based paint should not be removed from bridges prior to washing. If any steel portions of the bridge surface have flaking paint, then those portions should not be washed. This is due to practical and economical concerns over methods used to collect paint chips. However, if small amounts of loose lead-based paint chips have settled on the flanges of beams, they are considered to have a minimal environmental effect, and need not be removed prior to washing.

AIR POLLUTION:

➢ Some activities generate large amounts of particulate matter (PM) into the air. These include abrasive blasting, compressed air cleaning, jack hammering, saw cutting, sweeping, idling diesel machinery.

➢ If a significant amount of particulate matter is inhaled repeatedly over time, it can cause serious respiratory illnesses.

➢ The smaller the particles, the deeper they go into the lungs.

➢ Concrete dust contains silica. Continuous overexposure to silica seriously scars lung tissue, leading to silicosis (no cure).

➢ Dust suppressant activities include wet saw cutting or jack hammering wet concrete.

➢ Current product most commonly used for abrasive blasting is coal sludge (Black Beauty), which contains less than 1% free silica, the kind that is very harmful to the lungs if breathed in. Do not use sand as a medium for abrasive blasting, because it contains a much higher percentage of free silica.

➢ Limit release of PM as much as possible near sensitive receptors:

□ Schools and playgrounds

□ Residential neighborhoods

□ Parks

□ Hospitals and nursing homes

□ Daycare centers

□ Densely populated areas

➢ To reduce PM hazard, try alternative mediums to coal slag (Black Beauty) for abrasive blasting, including garnet (larger particles, more efficient) and steel shot (self-contains all dust, recycles the medium). However, these alternatives are more expensive.

➢ Other ways to limit PM release include performing work on “off hours” (e.g. Saturday), monitoring wind direction and weather patterns during work, not leaving machinery idling unnecessarily, wet saw cutting instead of cutting dry concrete, and transporting soil and debris in covered vehicles to prevent dust from escaping.

TRAINING OBJECTIVE 2

The employee will learn about:

➢ Procedures to clean up hazardous spills before they contaminate the environment.

➢ Precautionary tools/materials that should be present at all times in case of a spill.

➢ Safety measures that should be taken to avoid spills.

HAZARDOUS SPILLS:

➢ Some materials common to bridge maintenance that are hazardous to the environment if spilled include paints, stains, rust coatings, paint thinner, fuels, hydraulic fluid, automotive fluid, diesel fuel.

➢ Materials that should be completely avoided: Methylene chloride (graffiti removal), Sand for abrasive blasting, Toluene (strong solvents) *This is carcinogenic!

➢ All crews should have a Spill Kit and related materials on board at all times, including a variety of the following: Specialty absorbent mats, rolls, pads, “socks”, blankets, dikes, berms; sand, clay, kitty litter, pulp, or sludge pellets; a broom and bucket.

➢ Store barrels and drums on specialized containment pallets in case of leakage.

➢ Do not clean asphalt tools with diesel fuel near streams, ponds, wells, or drainage sources. Apply with hand sprayers or other small tools to limit the amount used. All diesel used must be collected with tarps, sand pads, pails or other similar collection methods. Clean up materials must then be properly disposed of as petroleum contaminated soil/debris (i.e. in a lined municipal solid waste landfill or at a treatment facility).

➢ How to respond to a spill:

1. Inform and remove people from area

2. Identify the substance

3. If flammable, remove flame sources

4. Stop further leaking if possible

5. Contain spill with absorbent materials

6. Pump large amounts into an empty drum

7. Cover small amounts with an absorbent

8. Label all containers of spill debris

➢ Report spills of petroleum products and regulated chemicals to the NYSDEC Spills Hotline at 1-800-457-7362.

➢ Should be reported within 2 hours of discovery.

➢ You do not need to report a petroleum spill of 5 gallons or less:

□ If it is under the control of the spiller

□ If it hasn’t reached land or water

□ If it is cleaned up within 2 hours

□ If it is contained on concrete, plastic, metal, or another surface that won’t leak, BUT do call if it is spilled on asphalt!

➢ Do NOT need to report spills of: most herbicides, ethanol, salt

➢ Emergency bridge work in or near streams, wetlands, lakes and ponds: NYSDEC must be notified within 48 hours of beginning the work and must approve all emergency work.

➢ Abandoned drums along the right-of-way: call the Spill Hotline. Do not touch until it is known what substance it contains/contained, or if it was part of criminal activity.

➢ Usually, NYSDEC staff respond to spills in emergencies, but if NYSDOT has facilities and employees nearby, they might be asked to help, depending on the quantity of the spill. NYSDOT employees will do the following:

□ Set up traffic barricades around site

□ Spread sand petroleum spills, but NOT on spills of unknown or hazardous substances

□ Pick up contaminated sand, if the amount is small

□ Dispose of contaminated sand according to NYSDEC directions

➢ Friable asbestos might be found on old bridges, so old bridges should first be evaluated by personnel licensed in asbestos testing and removal.

➢ Keep all products clearly labeled and material safety data sheets (MSDS) near.

➢ Fire Diamond: A product safety label, telling information about Health Hazards, Flammability, Chemical Reactivity, Unique Hazards

TRAINING OBJECTIVE 3

The employee will learn how to safely store and dispose of hazardous and non-hazardous waste so it does not contaminate the environment.

WASTE MANAGEMENT:

➢ Hazardous materials- a broad category that includes any materials that may be harmful if spilled or released into the environment. They include the list in Training Objective 2 (paints, stains, rust coatings, paint thinner, fuels, hydraulic fluid, automotive fluid, diesel fuel.)

➢ Hazardous Waste- a narrow category that refers to significantly hazardous materials (ones that are very ignitable, reactive, corrosive, and/or toxic) that are left over and need to be disposed of. There are specific rules for materials classified as “Hazardous Waste.”

➢ Non-hazardous waste examples include:

□ Non-hazardous industrial waste- paint chips without lead, used oil, antifreeze, lightly contaminated soil

□ C & D (Construction and Demolition) Debris- bricks, glass, asphaltic pavement, concrete, soil, rock, plaster, wood, electrical parts, pipes

□ Non-hazardous solid waste- routine garbage, office trash, litter

➢ Dispose of non-hazardous wastes at Municipal Solid Waste or C&D Debris Landfill Facilities. Recycle when possible.

➢ Suggested Practice: If a paint can has only 1 inch or less of water-based paint left, leave it out to dry and then dispose of as C&D Debris.

➢ Suggested Practice: If small amounts of resins and hardeners remain, combine them to cure out, and then dispose of as C&D Debris.

The Resource Conservation and Recovery Act established that all materials listed as Hazardous Waste must be tracked from “cradle-to-grave”.

➢ You need a manifest (a multiple-copy tracking document) to transport a Hazardous Waste anywhere. Eventually, all Hazardous Waste must be transported to a Treatment, Storage and Disposal (TSD) facility.

➢ Example: lead (in batteries and old paint). For a list of Hazardous Wastes and their disposal requirements, see the Environmental Handbook for Transportation Operations.

➢ Hazardous Waste can be stored at a facility for 90-180 days, depending on amount. Really small amounts ( ................
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