Environmental Standard Operating Procedure Originating Office MCAS Yuma Environmental Department

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1 Environmental Standard Operating Procedure Originating Office MCAS Yuma Environmental Department Revision: Draft Supersedes: n/a File Name: MCW-ESOP Effective Date: Prepared By: EM-Assist, Inc. Approved By: Fred Daniel Document Owner: C. Kost Title: Mercury Containing Waste 1.0 PURPOSE The purpose of this Environmental Standard Operating Procedure (ESOP) is to provide environmental guidelines for performing maintenance activities involving mercury containing wastes. 2.0 APPLICATION This guidance applies to those individuals who perform daily building maintenance activities wherein mercury containing wastes are handled and discarded at Marine Corps Air Station Yuma, AZ. 3.0 PROCEDURE 3.1 Discussion: Daily operations require the use of devices such as thermostats and sodium containing light bulbs that contain mercury and other hazardous substances. Mercury containing wastes are classified as a low level hazardous waste and therefore, can not be disposed of in regular trash. These wastes must be managed properly to lessen the impacts to human health and the environment. Mercury containing wastes that are generated aboard MCAS Yuma will be turned in to the designated environmental coordinator at the parent unit, or command. The units will notify the Environmental Department to schedule waste for disposal, and the items will be managed at the commands designated hazardous waste storage area until the proper disposal determination is made. The Facilities Maintenance Department (FMD) handles mercury containing wastes only if found discarded at the installation. The individual Marine can turn in mercury containing waste to the unit or to the Universal Waste Collection Center at Bldg 483 each Tuesday from Operational Controls: The following procedures apply: Units Responsibility; the Designated Environmental Coordinator at the Parent Unit: 1. Ensure that MSDSs for common hazardous materials associated with this practice such as mercury, cadmium, and lead are current and available for inspection. For Government Use Only. Page 1 of 8

2 2. Ensure that in guidelines the ECPSOP (StaO g) for universal wastes is followed. 3. Ensure that no mercury containing waste remains in shops and workcenters for more than 14 days. 4. Ensure that proper personal protective equipment (PPE) is used such as eye protection, face shields, personal air monitors, gloves, aprons, steel toe boots, rubber boots, respirators, coveralls, and hearing protection as needed. 5. Ensure that all required permits (if required) are current and available for inspection. 6. Consult Hazardous Material Spill Flow Chart upon identification of a spill. Clean up all spills immediately and report to your supervisor and the Environmental Department. 7. Place used rags in approved containers for recycling or disposal. Contact HWC when used rag containers are full, complete the inventory information sheet for turn-in waste to be assigned a a, and set up for disposal within 30 days after the accumulation start date. 8. Ensure that spills are recorded in a spill log book detailing the spill date, time, product spilled, quantity, location, cleanup actions taken and the name of the person reporting the spill. 9. Ensure all inspection records maintained and available for examination for three years. 10. Ensure that warning signs are clearly visible and legible from a distance of 25 feet in any direction. 11. Ensure that all training records and certifications are maintained current and available for inspection. 12. Ensure that turnover folder information is kept for this practice. 13. Ensure that storage areas are inspected weekly and inspection records maintained for 3 years. Private Party Venture (PPV) 14. Consult the designated PPV housing office for clean up/disposal guidance. FMD: 15. Ensure that mercury containing waste is transferred to DRMO within 60 days but under no circumstances will any mercury containing waste be stored at any site for a timeframe in excess of one year. 16. Consult Hazardous Material Spill Flow Chart upon identification of a spill. Clean up all spills immediately and report to supervisor and AC/S ES. 17. Place used rags in approved containers for recycling or disposal. Contact HWC when used rag containers are full, complete the inventory information sheet for turn-in of waste For Government Use Only. Page 2 of 8

3 so waste can be assigned a DD A, and set up for disposal within 30 days after the accumulation start date. 18. Ensure that spills are recorded in a spill log book detailing the spill date, time, product spilled, quantity, location, cleanup actions taken and the name of the person reporting the spill. Forward spill report to the Environmental Department within 24 hours. 19. Ensure that inspection records are maintained and available for examination for three years. 20. Ensure that records of all required training are current and available for inspection. 21. Ensure that turnover folder information is kept for this practice. If there are any specific situations or other concerns not addressed by this procedure, contact the Environmental Department. 3.3 Documentation and Record Keeping: The following records must be maintained: 1. MSDSs for all materials associated with this practice. 2. Training records for all personnel. 3. Haul log book. 4. Certificate of Recycling. 5. Hazardous waste tracking log. 6. Waste record book. 7. DD a files (maintain for 5 years). 8. Required permits. Unit Spill and Contingency Plan 3.4 Training: All personnel must be trained in this ESOP, to include the following, as applicable: 1. Hazard Communication Training hour Hazardous Waste Operations. 3. Health and Safety Training. 4. On-the-job training. 3.5 Emergency Preparedness and Response Procedures: In the event of an Emergency refer to the MCAS Yuma Emergency Management Plan (EMP). 3.6 Inspection and Corrective Action: The Environmental Protection Specialist (EPS) shall perform or designate personnel to perform inspections. The EPS shall ensure deficiencies noted during the inspections are corrected immediately. Actions taken to correct each deficiency shall be recorded on the inspection sheet. For Government Use Only. Page 3 of 8

4 4.0 REFERENCES 29 CFR 1910 (Code of Federal Regulations) MCO P4790.2C (Marine Corps Order) MCO P5090.2a HWMP (Hazardous Waste Management Plan) For Government Use Only. Page 4 of 8

5 Date: Installation: Inspector s Name: Mercury Containing Waste Inspection Checklist Time: Work Center: Signature: Inspection Items Yes No Comments Units: 1. Are MSDSs for common hazardous materials current and available for inspection? (29 CFR 1910) 2. Is a a form obtained from AC/S ES and filled with the proper information for each mercury waste item? (40 CFR 262, CCR 66262, HWMP) 3. Are all mercury containing waste items removed from the site within 60 days? (40 CFR 262, MCO P5090.2A) 4. Is proper PPE used as needed? (29 CFR 1910, MCO P5090.2A) 5. Are all required permits current and available for inspection? 6. Is the Hazardous Material Spill Flow Chart consulted upon identification of a spill, and are all spills cleaned immediately and reported to supervisor and AC/S ES? 7. Are used rags in placed in approved containers for recycling or disposal? Is the HWC contacted when used rag containers are full and is a completed inventory information sheet assigned a a, and set up for disposal within 30 days after the accumulation start date? 8. Are spills recorded in a spill log book detailing the spill date, time, product spilled, quantity, location, cleanup actions taken and the name of the person reporting the spill? 9. Are all inspection records maintained and available for examination (for three years)? 10. Is turnover information kept for this practice? (MCO P4790.2C) For Government Use Only. Page 5 of 8

6 11. Are warning signs clearly visible and legible from a distance of 25 feet in any direction? 12. Are all training records and certifications maintained current and available? 13. Are storage areas inspected weekly and inspection records maintained for 3 years? PPV: 14. Is mercury containing waste transferred to DRMO within 60 days, but never to exceed a timeframe in excess of one year?? 15. Is the Hazardous Material Spill Flow Chart consulted upon identification of a spill, and are all spills cleaned immediately and reported to supervisor and AC/S ES? 16. Are used rags in placed in approved containers for recycling or disposal? Is the HWC contacted when used rag containers are full and is a completed inventory information sheet assigned a DD A, and set up for disposal within 30 days after the accumulation start date? 17. Are spills recorded in a spill log book detailing the spill date, time, product spilled, quantity, location, cleanup actions taken and the name of the person reporting the spill? (40 CFR 262) 18. Are all inspection records maintained and available for examination (for three years)? FMD: 19. Is mercury containing waste transferred to DRMO within 60 days, but never to exceed a timeframe in excess of one year? (MCO P5090.2A; HWMP) 20. Is the Hazardous Material Spill Flow Chart consulted upon identification of a spill, and are all spills cleaned immediately and reported to supervisor and AC/S ES? (40 CFR 262, 21. Are used rags in placed in approved containers for recycling or disposal? Is the HWC contacted when used rag containers are full and is a completed For Government Use Only. Page 6 of 8

7 inventory information sheet assigned a a, and set up for disposal within 30 days after the accumulation start date? 22. Are spills recorded in a spill log book detailing the spill date, time, product spilled, quantity, location, cleanup actions taken and the name of the person reporting the spill? (40 CFR Are all inspection records maintained and available for examination (for three years)? 24. Are all training records and certifications maintained current and available? 25. Is turnover folder information kept for this practice? (MCO P4790.2C) For Government Use Only. Page 7 of 8

8 ADDITIONAL COMMENTS: CORRECTIVE ACTION TAKEN: Environmental Protection Specialist: Name: Signature: Date: For Government Use Only. Page 8 of 8