Environmental Standard Operating Procedures (ESOP) Hazardous Waste Satellite Accumulation Area (SAA) Environmental Affairs (EA): Hazardous Waste Management Branch (HWMB) (760) 830-7244 Revised: 17 May 18 Subj: HAZARDOUS WASTE SATELLITE ACCUMULATION AREA Ref: (a) CCO 5090.5D, Integrated Contingency and Operations Plan (b) Hazardous Waste Operations Manual, MCAGCC 1. Purpose. This document provides environmental protection guidelines for the management of the SAA. 2. Application. This guidance applies to those personnel who are involved with hazardous waste (HW) SAA s aboard Marine Air Ground Task Force Training Command (MAGTFTC), Marine Corps Air Ground Combat Center (MCAGCC) Twentynine Palms. For further references to MAGTFTC, MCAGCC in this document, the term installation will be used. 3. Procedures. The SAA is a site for the temporary accumulation of HW at or near the point of generation. A SAA consist of the following: a portable or permanent secondary containment area, containers for the storage of hazardous waste, and bulk waste storage containers. The improper accumulation and storage of hazardous waste is the most recurring violation issues by regulatory agencies. Individual units and EA Division HWMB, must work together to ensure that SAA regulatory requirements are met. a. Units aboard the installation accumulate HW and temporarily store them in SAA or a designated waste storage location. Individual units are responsible for overall site cleanliness and for ensuring that HW is placed in the correct HW containers. The HWMB is responsible for ensuring that HW storage containers are serviceable, functional, labeled, and are annotated in accordance with regulatory requirements. b. The HWMB shall ensure that HW at the SAA s are collected according to regulations. The HWMB and unit are responsible for the completion of the required operational and weekly site inspections. The HWMB shall assist individual units in designating SAA site locations. For information on requesting and establishing a SAA, refer to reference (a) and (b). 4. Operational Controls. The following procedures apply for HW SAA. a. References (a) and (b). 5. Documentation and Record Keeping. The following records must be maintained for this document: a. Safety Data Sheets for all HM being stored. b. Inspection records must be maintained for 3 years.
Subj: HAZARDOUS WASTE SATELLITE ACCUMULATION AREA 6. Training. All affected personnel must be trained in this document and the following: a. General Environmental Awareness training. b. Reference (b). c. Globally Harmonized System training. d. 40-hour Hazardous Waste Operations and Emergency Response course. 7. Emergency Preparedness and Response Procedures. Refer to reference (a) and the spill response procedures listed in the Abatement ESOP. 8. Inspection and Corrective Action. The Environmental Compliance Coordinator (ECC) and HWMB shall designate personnel to perform operational and weekly inspections respectively. The supervisor of HWMB has the overall responsibility to ensure that the mandated weekly inspection requirement are met. The ECC and HWMB shall ensure deficiencies noted during the inspections are corrected immediately. Actions taken to correct each deficiency shall be recorded on the inspection sheet. Refer to reference (b), for inspection sheets and guidelines. (a) Site operational inspections shall be conducted upon arrival at an SAA site and prior to servicing by HWMB personnel. (b) Weekly compliance inspection to include drums and above ground storage tanks shall be performed by HWMB and unit s designated personnel. The weekly inspection sheet to include discrepancies shall be maintained in the SAA folder.
Hazardous Waste Satellite Accumulation Area-Inspection Checklist Unit s Responsibilities Date: Time: Unit: Work Center: Inspector s Name: Signature: Inspection Items Yes No Comments Administrative 1. Have personnel received the appropriate level of training? 2. Are No Smoking signs posted? 3. Is there a compatible fire extinguishers nearby and is it maintained in a serviceable condition? 4. Is there an adequate spill kit nearby? That contains PPE 5. Are there no evidence of spills, leaks, or unauthorized dumping present? 6. Are incidental releases properly cleaned up? 7. Are drums and containers not leaking, damaged, misused, or missing from the SAA? 8. Are wastes in their proper compatible containers and not mixed? 9. Are lead acid batteries marked and fill caps and post taped? Eye Wash for sites with corrosive materials with proper corrosive spill kit 10. Are non-intact Lead Acid Batteries (missing caps, leaking or cracked), packaged in an open-top polyethylene drums for turn-in to the HWMB? 11. Are empty containers marked with the date they became empty, the word empty and the last known contents? 12. Are secondary containments and SAA area free of excess dirt and debris? 13. Is the drain on the secondary containment closed? 14. Are hoses, couplings, vent caps, and fill caps free of leaks, cracks, or breaks for bulk waste AST s? 15. Is the interstitial space monitoring device on bulk waste containers serviceable and reading non-detect? 16. Are all HWs placed in the SAA area? 17. Are transfer containers properly managed? 18. Are training and inspection records maintained and available for inspection?
Additional Comments: Corrective Action Taken: Unit Inspector: Name: Signature:
Hazardous Waste Satellite Accumulation Area-Inspection Checklist HWMB s Responsibilities Date: Time: Unit: Work Center: Inspector s Name: Signature: Inspection Items Yes No Comments Administrative 1. Have personnel received the appropriate level of training? 2. Are records available of all required inspections (i.e., operational, weekly, and quarterly) and action taken to correct noted deficiencies? 3. Is there an adequate spill kit located near the SAA? 4. Is the area free of spills, leaks, and debris? 5. Are SAA s temporary or permanent secondary containment serviceable? 6. Are all liquid HW in a secondary containment? 7. Are all solid HW that do not have primary containment (ammo boxes, fuel bladders, etc) in a covered primary containment container? 8. Are containers and bulk storage containers in good condition (free of dents and corrosion, not bulging, or otherwise deteriorating)? 9. Are containers missing or being misused per design? 10. Are contents compatible with the container? 11. Are containers tops free of spillage? 12. Are containers properly closed? 13. Are markings and labels on all containers and bulk storage units present, legible, and the words Hazardous Waste and content on the container? 14. Is the proper Initial Date of Accumulation (IDOA) marked on each HW container and bulk storage units? Containment Areas 15. Are empty containers marked with the date they became empty, and last known contents? 16. Are lead acid batteries caps and posts taped and stored in a manner to prevent leakage? 17. For bulk waste containers are hoses, coupling, vent cap, and fill caps free of leaks, cracks, and breaks?
18. Is the interstitial space monitoring device on bulk waste containers serviceable and is reading non-detect? Additional Comments: Corrective Action Taken: Unit Inspector: Name: Signature: