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21 horns, mirrors, floors, and other safety-related equipment. In maintenance operations have two sources of air pollutants: addition to being an essential resource when developing mobile (i.e., vehicles) and stationary (i.e., facilities). bus specifications, Part 393 is also useful when writing bus inspection practices because it includes specific instructions for checking lighting, braking systems, brake hoses, exhaust Vehicles systems, door width and height, mirrors, and other bus equip- It is the OEM's responsibility to certify that vehicles com- ment. Affected equipment has a specific requirement that the ply with all EPA exhaust emissions regulations applicable at inspector must verify when performing PMIs. the date of manufacture. In some jurisdictions, however, sep- Suggestion: Use CFR 49 Part 393 as a guide when develop- arate state and local regulations may also apply. For exam- ing practices because it provides proper inspection criteria ple, some localities require opacity tests or other verification for specific bus equipment and contains information on that the engine continues to function within the compliance developing inspection forms. criteria. Due to the various requirements, agencies are urged to contact their local EPA office to determine which require- CFR--Record-Keeping Requirements ments apply to their operation and to make certain that their practices comply. CFR 49 Part 396 outlines PMI record-keeping require- Suggestion: PMI programs should incorporate verification ments. It also establishes pre-trip inspection requirements that all emissions-related equipment is operating according and provides essential guidance for developing maintenance to the vehicle OEM's specifications. Under no circumstances practices and training programs. should a maintenance practice modify or render any emis- Under Part 396, records must substantiate that the sions equipment inoperative. mechanic or inspector carrying out the PMI has proper train- ing, knowledge, and experience to perform the required Facilities tasks. In addition, all inspections must be documented to show that identified defects have been repaired. Clean Water Act Suggestion: Use Part 396 as guide when developing PMIs because it includes record-keeping requirements, inspection The Clean Water Act (CWA) provides the national frame- criteria, and inspection frequency details. It also identifies the work for water pollution control and water quality manage- safety items that must be inspected. ment. Maintenance facilities and fleet operations generate wastewater from a variety of sources and activities such as steam cleaning, vehicle and facility washing, and water Federal Motor Vehicle Safety runoff into drains from vehicle parking areas, refueling, and Standards (FMVSS) maintenance repair areas. FMVSS are safety standards that all vehicle manufactur- Suggestion: Become familiar with all CWA requirements ers must comply with. Although initial compliance with summarized below and develop practices that are consistent FMVSS is the responsibility of the bus OEM, agencies must with them. have an understanding of these requirements to make certain that the requirements are not violated during maintenance Underground Storage Tanks.The CWA requires that all and repair activities. In particular, agencies must ensure that underground storage tanks (USTs) be registered with the the replacement of any FMVSS-certified part or component local environmental agency, health agency, or fire depart- continues to meet original certification criteria. ment. Requirements for USTs include double-walled con- struction for underground tanks and piping. Regulations also Suggestion: Refer to FMVSS when developing practices to make certain that all after-market parts and components used require the tank owner (i.e., transit agency) to have certified in repairs continue to meet safety requirements. Mainte- tank testers perform periodic tests on all USTs and piping nance personnel are not allowed to substitute or compromise and to document the test results. Tank owners must also mon- any system or component with noncertified parts. An under- itor for leaks by using leak-detection equipment and product standing of FMVSS also allows you to develop in-plant inventory reconciling. Failure to comply can result in cita- inspection practices for new buses to verify that these impor- tant safety requirements are being met by the OEMs. tions, facility closure, or permit revocation. Storm Water Runoff. The CWA regulates contaminants ENVIRONMENTAL PROTECTION that become part of storm water runoff as the storm water AGENCY (EPA) washes over the facility grounds. Contaminants include hydrocarbons from fuel and oil, battery acid, dirt, trash, Several EPA regulations are intended to protect human grease, antifreeze, and other substances that mingle with health and safeguard the natural environment. Typical bus storm water. Each contaminant has specific thresholds that

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22 typically require periodic sampling. Since each jurisdiction be operated by a licensed employee. The refrigerant (includ- has different requirements, agencies are urged to check with ing 134a) added to any AC system must be tracked and their local water resources authority or environmental/health inventoried to substantiate that no product was intentionally agency. Some jurisdictions, for example, require agencies to vented into the atmosphere. take storm water samples from the runoff within the first Suggestion: Practices involving refrigerant-based AC half-hour of a storm that exceeds one-quarter inch of rainfall. systems should include procedures for logging refrigerant With few exceptions, agencies are required to inspect their use and verification that certified equipment is operating facilities for possible contaminants on a scheduled basis and properly and employees have proper licensing. to document the findings. Paint and Body Repair. Paint and body repairs generate Sewer Systems. Maintenance operations generate sludge several emissions regulated by the CAA. The most common and contaminated water from their bus-washing activities, are volatile organic compounds (VOCs) contained in most and the sludge and contaminated water eventually enter the paints. Many jurisdictions also require VOC users to track city sewer system. Separators are typically required to the paint usage and the type of paint coatings applied. trap unacceptable hazardous materials on site. Agencies These requirements may exceed federal CAA requirements. must also have the separated sludge and oils pumped, Agencies that use large quantities of paint are typically sampled, and disposed of in compliance with EPA and local required by the CAA to use certified paint booths that include regulations. various VOC emission-reduction equipment. Body repairs also generate dust and particulate matter (PM), also regulated under the CAA as a hazard to humans. Agen- Clean Air Act cies are required to have proper breathing apparatuses and ventilation for employees who sand or paint vehicles. The EPA's Clean Air Act (CAA) addresses conventional Suggestion: Check with your local health agency for regula- air pollutants (i.e., those that are naturally part of the tions governing use of paints and thinners, and develop environment) and regulated air pollutants (i.e., manufactured practices that include a process for maintaining paint logs, pollutants). The CAA affects maintenance facility operations using personal protective equipment, and keeping the equip- and is typically regulated by local authorities. Local regula- ment in good working order. The type of spray gun used for painting can significantly reduce VOC emissions. tions are sometimes more restrictive than the CAA require- ments and often require permits. Fueling Facilities. Fueling facilities that dispense diesel, Pollution Prevention Act of 1990 gasoline, and alternate fuels are typically regulated to prevent spillage and hydrocarbon or methane vapors from entering The Pollution Prevention Act of 1990 (P2) is also regu- the atmosphere. lated by the EPA and is intended to control waste by keeping harmful products from migrating into the food chain and Suggestion: Develop practices for preventing leakage and from contaminating humans. Since most maintenance facili- spillage. Include procedures for using and maintaining pumping systems, hoses, nozzles, and related dispensing ties generate hazardous waste, P2 applies to these facilities equipment. Also develop cleanup procedure practices for as well. An important element of this regulation is that it spills. requires agencies to have a documented hazardous commu- nications program in place that includes: Auxiliary Generators. Many agencies have a back-up gen- erator to support normal operations during an electrical A current materials safety data sheet (MSDS), which power outage. The manufacturer requires that these units must be updated as new products are purchased, for receive periodic exercising, load testing, and PMIs. Some each hazardous chemical in the workplace; jurisdictions also require permits and the monitoring of Labels and other forms of warning graphics on all exhaust emissions from auxiliary generators. chemical containers used in the workplace; Warning signs posted in conspicuous locations; and Suggestion: Develop a PMI practice with scheduled intervals for generators. Include instructions for load testing and keep- Documented employee training programs regarding the ing equipment in good running order according to the OEM's use, handling, and management of hazardous chemicals. recommendations. The P2 program makes certain that employees are Refrigerant Use. The CAA regulates the refrigerant used in informed of hazardous products and receive documented air conditioning (AC) systems for vehicles and buildings. It training in proper use and disposal. (See the section requires that the refrigerant removed from any AC system be on OSHA below, which also regulates personnel safety captured and recycled using a certified recovery system and while performing work tasks.) Facility and worker safety