10 Maintenance Operations
It is the objective to manage the potential environmental risks associated with golf course maintenance operations. Our industry has a need and responsibility to implement, manage, measure, and improve all aspects of environmental stewardship. It is imperative that hazardous materials be handled, stored, recycled, and disposed in a safe, healthy, and environmentally sound manner.
Pollution prevention includes the proper delivery, storage, handling, and disposal of all chemicals, washwater, and wastewater. For example, washwater from pesticide application equipment must be managed as a pesticide. Conversely, wastewater not contaminated with harmful chemicals can be reused or discharged to a permitted stormwater treatment system. The “Pesticide Management” chapter offers maintenance operations-related BMPs specifically for pesticides.
For unintended releases of any chemicals, an emergency plan, spill kit, and first-aid kit should be readily available.
10.1 Regulatory Considerations
10.1.1 Hazardous Waste
Hazardous wastes are regulated by EPA under RCRA. Hazardous waste has properties that make it dangerous or potentially harmful to human health or the environment. These wastes could include some chemicals used in golf course maintenance operations such as solvents and pesticides. (See the “Pesticide Management” chapter for regulatory considerations for pesticides.)
In Virginia, DEQ has implemented a hazardous waste program and therefore has primary responsibility for enforcing hazardous waste regulations. Hazardous waste releases may be regulated under SARA Title III (42 CFR 103), also known as the Emergency Planning and Community Right-to-Know Act, depending upon the chemical hazard and the volume released.
10.1.2 Petroleum Storage Tanks
Virginia DEQ’s Tank Compliance Program regulates underground storage tanks (USTs) and above-ground storage tanks (ASTs). Guidance is available from DEQ to assist with regulatory compliance.
USTs are regulated in Virginia under two regulations: the Technical Standards and Corrective Action Requirements Regulation (9 VAC 25-580-10 et seq.) and the Petroleum UST Financial Responsibility Requirements Regulation (9 VAC 25-590-10 et seq.). Some differences exist between the federal UST regulation and Virginia’s UST regulations; state regulations are sometimes more stringent or implemented differently from the federal regulations. For example in Virginia, tank owners and operators are required to show that they have complied with the Uniform Statewide Building Code by obtaining a permit issued by the local code official and any required inspections for UST installation, upgrade, repair, or closure.
ASTs are regulated in Virginia under the Facility and Aboveground Storage Tank Regulations (9 VAC 25-91-10 et seq). Other state laws apply to ASTs and are included in the statewide building and fire codes, which local code officials administer.
10.1.3 Local Regulations
Local building and fire codes should be reviewed with respect to the siting, construction, and operation of maintenance facilities, such as fueling areas and pesticide storage areas. In addition, USTs in Virginia must be permitted by the local code official and inspected as required. Finally, any discharges to sanitary sewer systems require a permit from the local wastewater treatment facility.
10.2 Storage and Handling of Fertilizers
The nutrients in fertilizers, particularly nitrogen and phosphorus, can present water quality issues if not handled properly. Fertilizers also must be stored properly because their oxidizing properties pose fire hazards.
Fertilizers should be stored in a dry area and, ideally, in a concrete building with a metal or other flame-resistant roof. At the least, fertilizers should be stored on a concrete pad and covered from the elements. Nitrate-based fertilizers, while stable themselves, act as an oxidizer and can react with combustible and reducing materials. The presence of a fire hazard depends on other general combustible materials in the vicinity of nitrate-based fertilizers, which can accelerate a fire. Therefore, nitrate-based fertilizers must be stored separately from pesticides, solvents, and fuels.
Fertilizers should be loaded into or unloaded from application equipment away from surface waters or drinking wells. To minimize accidental release and allow for easy cleanup of spilled fertilizer, a covered impervious surface (for example, a concrete pad) is ideal. The surface area should be cleaned after loading or unloading to further control dust and spills and prevent accidental off-site release.
10.3 Equipment Washing
Equipment washing areas are primarily used to wash mowing equipment, which can transport organic matter such as grass clippings or soil into surface waters with runoff. Washing procedures should incorporate the minimal use of water and spring-operated shutoff nozzles to conserve water resources. In general, unless the washwater contains contaminants such as petroleum products, pesticides, solvents, or degreasers, it may not need to be collected before being discharged. However, even uncontaminated washwater should never be allowed to discharge directly into, or in the vicinity of, surface waters and storm drains.
Washing areas can be simple or more complex. The simplest system is a “dog leash” system that uses a short, portable hose to wash off the grass over a turfed area. The washwater infiltrates into the soil. The washing location should be moved around, depending upon the amount of water used and the percolation rate of the soil, to avoid any potential problems with mud and surface runoff.
Well-designed equipment washing areas incorporate an impervious surface and a system to recycle, discharge, or divert washwater and minimize the potential for environmental impacts.
Clippings should be brushed or blown off equipment with compressed air prior to washing since dry clippings are easier to handle, store, and dispose of than wet ones. In addition, this practice decreases the possibility of nutrients, such as N and P, leaching out of wet clippings and into the washwater. Any remaining grass clippings can be separated from the washwater using an above-ground screening system or a tank containing separation baffles that trap the clippings to separate them from the water. Collected wet clippings can be composted or used as mulch if they are not contaminated with pesticides or petroleum.
10.3.1 Washwater Disposal and Recycling
Disposal of washwater depends on a number of variables, including the volume of washwater generated, the nature of the surrounding area, and the frequency of the operations. For limited washdown of ordinary field equipment, it may be legal to allow the washwater to flow to an area for infiltration, such as a grassed retention area or swale. Discharge to a septic system is illegal. Other options for managing washwater include:
- Discharge to a sanitary sewer system.
- Treatment onsite.
Discharges to a wastewater treatment system require a permit and may require pretreatment, such as the use of an oil/water separator and separation of grass clippings or other solids.
10.3.2 Onsite Treatment
Onsite treatment uses separation systems to separate clippings from the water. Soaps or degreasers can be used in washing equipment that is treated onsite. Separation systems can use an above- or below-ground catch-and-release system to capture clippings and discharge washwater.
Above-ground systems capture clippings through a screening mechanism and discharge washwater to the ground surface for infiltration. There must be no connection to surface water in this system. Clippings must be collected regularly and returned to a turfed area or composted.
Below-ground catch-and-release systems capture clippings by an above-ground screening mechanism or a below-ground tank before discharging the washwater to an underground infiltration network. If a tank is used to capture clippings, the clippings must be disposed of by a licensed liquid industrial waste hauler.
10.3.3 Recycle Wash Systems
Two types of recycling systems are available to purify wastewater and pipe it back for reuse: 100% closed-loop recycle and partial recycle systems. Although expensive, recycle systems conserve water resources and lower water bills and sewer discharge fees.
Closed-loop recycle systems recycle both washwater and rinse water with no discharges of wastewater to ground or surface waters. These systems must be properly operated and maintained to prevent accidental discharges. Florida DEP has published BMPs for the use of closed-loop recycle systems in Guide to Best Management Practices: 100% Closed-Loop Recycle Systems at Vehicle and Other Equipment Wash Facilities. In some cases, the use of closed-loop systems may require an industrial wastewater permit. Partial recycle systems separate washwater from rinse water and recycle the washwater. Excess rinse water may be disposed of onsite. More information on partial recycle systems is also available in the Florida DEP’s guidance on closed-loop recycle systems referenced above.
10.3.4 Oil/Water Separators
Oil/water separators are generally not necessary, unless the water from the system is to be reclaimed for some particular end use (such as recycle systems), or as required by an industrial wastewater permit, local government, or receiving utility. If used, the oil collected in these systems may be classified as a hazardous waste, making disposal expensive. Usually, filters from these systems may be disposed of at an approved landfill. Keep all disposal records to document proper disposal of this waste.
10.4 Equipment Storage and Maintenance
All equipment used in the maintenance and operation of golf courses should be stored, maintained, and cleaned in a way that eliminates or minimizes the potential for pollution. When not in use, equipment should be stored in a clean, safe, and protected area, such as covered and sealed impervious areas. Fluid leaks from stored equipment should be identified and the equipment repaired. Assigned parking areas aid in the identification of equipment with fluid leaks.
Application equipment must be stored in covered areas protected from rainfall because of the potential for pesticide or fertilizer residue to wash off the exterior of this equipment. Pesticide and fertilizer equipment should be stored separately from other equipment.
10.5 Fueling Facilities
Fueling areas should be properly sited, designed, constructed, and maintained to prevent petroleum products from being released into the environment through spills or leaks. Above-ground tanks are easier to monitor for leakage and are therefore the preferred storage method. Because of the potential for groundwater contamination from leaking USTs, leak detection monitoring is a critical aspect of UST compliance. Any leaks or spills must be contained and cleaned immediately.
Fueling areas should be sited on impervious surfaces, equipped with spill containment and recovery facilities, and located away from surface waters and water wells. Catch basins in fueling areas should be directed toward an oil/water separator or sump to prevent petroleum from moving outside any containment structure. Floor drains in fueling areas should be eliminated unless they drain to containment pits or storage tanks.
10.6 Waste Handling
Facilities need to regularly review how they handle the disposal of unwanted, expired, or accumulated items, including chemicals, paints, pesticides, tires, batteries, used oils, solvents, paper products, plastic or glass containers, and aluminum cans. Developing recycling programs reduces waste and minimizes the quantity of waste reaching landfills. In some cases, recycling of some wastes may be required locally, and superintendents should be aware of these requirements.
All packaging from chemicals, their containers and other wastes should be properly disposed of. Pesticide-specific waste handling requirements are identified on the pesticide label and are discussed in the “Pesticide Management” chapter.
10.7 Maintenance Operations Best Management Practices
- Review groundwater sensitivity information before constructing any fertilizer storage facilities or handling areas.
- Storage facilities should not be located in areas with high probability of flooding.
- Locate dry fertilizer storage buildings or liquid fertilizer secondary containment over 500 feet away from a well, water supply, or surface water runoff area.
- Construct storage buildings to prevent seepage or spillage of fertilizer under normal conditions.
- Unless stored in a totally enclosed building, all nonliquid fertilizer materials should be covered and stored within an appropriate secondary containment storage structure.
- Construct liquid fertilizer secondary containment capable of holding 125 percent of the volume of the largest container plus the volume of the butts of all other containers inside the liquid containment area.
- Construct dry storage for secondary containment that is of sufficient thickness and strength to withstand loading conditions.
- Design loading areas to prevent spillage onto unprotected areas and create a proper cleanup area by installing curbed containment.
- Post warning signs on chemical storage buildings, especially near entry or exit areas.
- Storage facilities should be secured and allow access only to authorized staff.
- Replace worn or faulty valves, plugs, and threaded fittings in storage containers.
- Install backflow prevention devices or use air gap separation on water supply lines used for fertilizer mixing or equipment rinsing.
- Lock valves and shutoff devices while storage containers and facilities are not in use.
- Follow hazard safety rules, worker protection laws, and fire prevention rules while handling and storing fertilizer.
- Apply appropriate sealant to seams and cracks in all storage facilities and load/wash/rinse pad areas.
- Use approved containers designed for and compatible with the fertilizer being stored.
- Shelves should be made of plastic or reinforced metal. Metal shelving should be coated with paint to avoid corrosion. Wood shelving should not be used due to its ability to absorb spilled chemicals.
- Exhaust fans and an emergency wash station should be provided.
- Light and fan switches should be located on the exterior of the storage facility.
- Store liquid materials below dry materials to prevent contamination from a leak.
- Train staff and other management on how to access and use the facility’s SDS database.
- Maintain accurate inventory lists.
- Brush or blow off accumulated grass clippings from equipment using compressed air before washing.
- Wash equipment on a concrete pad or asphalt pad that collects the water. After the collected material dries, collect and dispose of it properly.
- Washing areas for equipment not contaminated with pesticide residues should drain into oil/water separators before draining into sanitary sewers or holding tanks.
- Do not wash pesticide-application equipment on pads with oil/water separators. Do not wash near wells, surface water, or storm drains.
- Use spring-loaded spray nozzles to reduce water usage during washing.
- Minimize the use of detergents. Use only biodegradable, non-phosphate detergents.
- Use non-containment washwater for irrigation.
- Do not discharge non-contaminated wastewater during or immediately after a rainstorm, since the added flow may exceed the permitted storage volume of the stormwater system.
- Do not discharge washwater to surface water, groundwater, or susceptible/leachable soils either directly or indirectly through ditches, storm drains, or canals.
- Never discharge to a sanitary sewer system without written approval from the appropriate entity.
- Never discharge to a septic tank.
- Do not wash equipment on a pesticide mixing and loading pad. This keeps grass clippings and other debris from becoming contaminated with pesticides.
- Solvents and degreasers should be used over a collection basin or pad that collects all used material.
Equipment Storage and Maintenance
- Store equipment in areas protected from rainfall. Rain can wash residues from equipment and potentially contaminate the surrounding soil or water.
- Perform equipment maintenance activities in a completely covered area with sealed impervious surfaces.
- Drains should either be sealed or connected to sanitary sewer systems with the approval of local wastewater treatment plants.
- Solvents and degreasers should be stored in locked metal cabinets away from any sources of open flame.
- Complete a chemical inventory and keep SDS of each on site. A duplicate set of SDS should be kept in locations away from the chemicals, but easily reached in an emergency.
- Use PPE when working with solvents.
- Use containers with dates and contents clearly marked when collecting used solvents and degreasers.
- Above-ground fuel tanks are preferred as they are more easily monitored for leaks as compared with underground tanks.
- Fueling stations should be located under roofed areas with concrete pavement whenever possible.
- Fueling areas should have spill containment and recovery facilities located near the stations.
- Develop a record-keeping process to monitor and detect leakage in USTs and ASTs.
- Visually inspect any AST for leakage and structural integrity.
- Secure fuel storage facilities and allow access only to authorized and properly trained staff.
- Label containers for collecting used solvents, oils, and degreasers.
- Recycle lead-acid batteries. If not recycled, batteries are classified as hazardous waste.
- Store old batteries on impervious surfaces in areas protected from rainfall.
- Recycle used tires, paper products, plastic or glass containers, aluminum cans, and used solvents, oils, and degreasers.
- Provide a secure and specifically designated storage for the collection of recyclable waste products.
- Recycle or properly dispose of light bulbs and fluorescent tubes.