You Can’t Use Them Like You Used To: Managing Catch Basin Cleanings and Street Sweepings
By Michael Martin and Jennie Moonan, PE
Keeping municipal streets clean and maintaining the drainage system to reduce flooding are core functions of any public works utility. However, these practices generate quite a bit of waste which can prove difficult to manage. As a result, many municipalities store catch basin cleanings and street sweepings in comingled piles at a public works yard. Sometimes, after a period of storage time, these commingled materials are mixed with compost or other soils and re-used around a municipality as part of roadway and facilities projects. Unfortunately, this practice is prohibited by state regulations without further approvals.
As communities are subject to more regulations, this practice is under more scrutiny than ever before. For example, those municipalities that are subject to EPA’s Small Municipal Separate Storm Sewer System (MS4) General Permit are required to prepare and begin implementing site-specific Stormwater Pollution Prevention Plans (SWPPPs) for maintenance garages, public works yards, transfer stations, and other waste handling facilities where pollutants are exposed to stormwater. Storage and management of these materials must be considered in any SWPPP.
Now that management of these materials is under more scrutiny than ever before, many municipalities are running out of space to store catch basin sweepings and street sweepings at Town facilities. Given the current landfill capacity issues in the Northeast, the disposal of these materials at a landfill has become more difficult and expensive. Tighe & Bond is helping communities develop cost-effective strategies to manage materials in compliance with the regulations.
This does not just affect the public sector. There are institutions (schools, hospitals, etc.), other private entities, and their maintenance contractors that sweep paved areas and maintain their own drainage infrastructure. Many of these entities are subject to similar scrutiny by regulators for pollution prevention and good housekeeping through industrial stormwater permitting and all of them must comply with the requirements to properly store and dispose of catch basin cleanings and street sweepings.
Tighe & Bond works with private facilities on all facets of regulatory compliance, good housekeeping, and pollution prevention.
What are the regulations for managing these materials?
- Catch basin cleanings must be managed in accordance with MassDEP’s solid waste policy. This means they must be sampled and sent to a regulated facility for a significant fee. Alternatively, a Beneficial Use Determination (BUD) approval from MassDEP may be obtained allowing for the most cost-effective reuse of this material. Any materials commingled with the catch basin cleanings must be managed in accordance with this policy.
- Street sweepings can be managed in accordance with MassDEP’s solid waste BUD policy. As described in this policy, management options for street sweeping could include:
- Daily Cover at a Massachusetts landfill in accordance with MassDEP Policy Comm-97-001
- Reuse as fill material in roadways and parking lots
- Reuse as an additive to restricted compost material (i.e., non-residential uses)
- Reused as anti-skid material (street sanding)
- Reused as reclamation material at a quarry, sandpit or gravel pit operating in accordance with MassDEP Policy Comm-15-001
If you follow this policy, you don’t need specific approval from MassDEP. Alternative management options may be considered, but a Beneficial Use Determination (BUD) approval from MassDEP is required. Obtaining a BUD requires additional effort and expense.
I have material stored on my site, what should I do now?
- If you have piles of materials mixed with catch basin cleanings, collect samples in accordance with MassDEP requirements and submit the samples to a certified laboratory.
- Moving forward, sweepings and catch basin cleanings should be stockpiled separately.