Why are trash and litter a stormwater issue?
In addition to being unsightly, litter and trash can cause stormwater system blockages leading to flooding. It can also harm aquatic life. Proper disposal of trash, litter, cigarette butts, and other wastes is just good business practice. It is essential not only so our airport looks clean and inviting, but also to deter vermin and to keep these wastes from entering the stormdrain system and making their way to our streams.
There are local collection points for trash disposal. These include compactors as well as roll-off dumpsters and a recycling center where tenants can properly dispose of waste.
Tenants are required to prevent or reduce pollutants exposed to or discharged to stormwater from tenant trash and waste. Tenant Directive 003.1 (Trash Disposal and Recycling at BWI Marshall) provides detail on proper disposal of trash at BWI Marshall Airport to prevent littering and prevent aircraft foreign object damage (FOD) as well as to promote recycling.
Tenant staff should follow all BWI and MTN SWPPP best management practices, including:
- Do not overfill dumpsters.
- Close lids tightly.
- Place cigarette butts in proper receptacles to keep them from being washed into storm drains.
- Good housekeeping measures must include a schedule for regular pickup and disposal of garbage and waste materials.
- Perform regular housekeeping to maintain waste storage areas in a clean and orderly condition.
- Recycle materials whenever possible.
- Inspect waste management areas for spills and waste management containers for leaks.
- Ensure that sediments and wastes are prevented from being washed, leached, or otherwise carried off-site.
- Completely drain containers (e.g., quart oil cans) prior to disposal in trash receptacles.
- Eliminate waste collection piles (i.e., “boneyards”).
- Schedule waste pickup as frequently as necessary to keep storage of waste to a minimum and to avoid overloaded/overfilled disposal containers.
- Minimize spills and fugitive losses such as dust or mist from loading areas.
- Maintain a minimal inventory of required chemicals to reduce the magnitude of potential spills and limit waste generation.
- Track waste generation:
- Characterize waste streams.
- Evaluate the process generating the waste for pollution prevention opportunities.
- Maintain accurate information on waste streams using: manifests, bills of lading, biennial reports, permits, environmental audits, SARA Title III reports, emission reports. Safety Data Sheets (SDS), NPDES discharge monitoring reports, inventory reports, data on chemical spills, and emissions data.
- Find substitutes for harmful chemicals.
- Properly dispose of unusable chemical inventory.
Physical Site Usage
- Segregate and separate wastes.
- Avoid locating waste handling and storage in areas with storm drain inlets/catch basins.
- Locate waste storage areas beneath existing cover, if possible.
Garbage Collection Areas
- Use covered dumpsters and keep them closed and locked.
- Use only dumpsters with plugged drain holes to prevent leaks from waste materials.
- Do not dispose of liquid wastes such as oils or hazardous materials into dumpsters.
- Completely drain liquid waste containers prior to disposal.
- Perform dumpster cleaning in designated areas that are bermed to contain wash water for a subsequent disposal or discharge to the sanitary sewer. Ramp scrubbers are effective.
- Maintain adequate supplies of spill response equipment and materials in accessible locations near areas where spills may be likely to occur.
- Equip waste transport vehicles with spill containment equipment.
Inspection and Training
- Provide the appropriate level of employee training in the following areas: spill response and prevention, storm water pollution prevention education, right-to-know awareness training, and hazardous materials management.
- Perform and document in a log-book periodic inspections of hazardous and non-hazardous waste storage areas.
- Inspection items should include the following:
- Check containers for external corrosion and structural failure.
- Check for spills and overfills due to operator failure.
- Check for failure of piping system (pipes, pumps, flanges, couplings, hoses, and valves).
- Check for leaks or spills during pumping of liquids or gases.
- Visually inspect new tanks or containers for loose fittings, poor welds, and improper or poorly fitted gaskets.
- Inspect tank foundations and storage area coatings.
- Inspect dumpster areas for signs of leakage.
One of the requirements of tenant leases is that tenants must adhere to the requirements of the applicable tenant directives and associated regulations. Not adhering to these requirements can impact the standing of the tenant lease.
Additionally, many of the best management practices identified above are those included in the Stormwater Pollution Prevention Plan, which is applicable to both the MAA and tenants at the airport. Not implementing best management practices in association with tenant activities may result in the contamination of stormwater at the airport. As a result, the MAA and tenants may face civil or criminal penalties (see Part II.C.15 and 16 of of the NPDES Permit available on the Resource Documents page for more details).