Attachment L-3A Environmental Standard Operating Procedures.pdf

CHECK THE MASTER LIST-

VERIFY THAT THIS IS THE CORRECT VERSION BEFORE USE

AS10-OI-053

REVISION: H

EFFECTIVE DATE: December 13, 2023

ORGANIZATIONAL

ISSUANCE

AS10

Management of Chemical

Data

APPROVING

AUTHORITY

NAME TITLE DATE ORG

Manager, Environmental Engineering

& Occupational Health Office 12/13/2023 AS10

Organizational Issuance

Management of Chemical Data AS10-OI-053 Revision H

Date: December 13, 2023 Page 2 of 8

CHECK THE MASTER LIST-VERIFY THAT THIS IS THE CORRECT VERSION BEFORE USE

DOCUMENT HISTORY LOG

Status

(Baseline/

Revision/

Canceled)

Document

Revision

Effective

Date

Description

Baseline

01/22/13

Revision A 11/21/13 Updated to reflect a standardization of inputs.

Revision B 02/02/16 Changed the process to reflect the new inventory system, Chemsafe

Revision C 04/04/19 Changed the process to reflect the new inventory system,HMS Maximo

Revision D 07/02/19 Updated to reflect information on the barcoding process.

Revision E 02/02/22 Edited grammar and information for clarification.

Revision F 10/05/22 Changed 5.4.2.1 instructions regarding percent weight. Added 5.4.2.3 scenario.

Revision G 12/08/22 Edited 5.4 2 1 to reflect original conservative estimation, and 5.4.2.3 and 5.4.2.2 to reflect a more accurate and conservative estimation of various descriptive term(s) and ranges.

Added 5.4.3.1. to address adding official CAS number and checking applicable boxes within HMS Maximo

Edited “HMS Maximo” term throughout OI for consistency.

Revision H 12/13/2023 Updated to reflect correct Maximo instructions in 5,1,5,1 and 5.1.5.2., edited for grammatical changes, and added reference to MWI 8550.5 in 6.3.

Date: December 13, 2023 Page 3 of 8

1. PURPOSE

This instruction establishes the requirements and methodology used by Hazardous Material

Management personnel for inputting data into the Maximo Hazardous Materials System (HMS) and for creating barcodes to help track certain hazardous chemicals.

2. APPLICABILITY

This instruction applies to the management of chemicals at Marshall Space Flight Center

(MSFC).

3. AUTHORITY and APPLICABLE DOCUMENTS

3.1 AUTHORITY

MPR 8500.1, MSFC Environmental Engineering and Occupational Health Program

MWI 8550.5, Hazardous Material Management

3.2 APPLICABLE DOCUMENTS

None.

4. DEFINITIONS

CAS – Chemical Abstract Service

Evap. – Abbreviation for “evaporation”

Haz – Abbreviation for “hazardous”

HMS – Hazardous Material System

MSDS – Material Safety Data Sheet. This acronym is used for out-of-date Hazard

Communication documents prior to 1 June 2015.

Phys – Abbreviation for “physical”

Prod – Abbreviation for “product”

Ref – Abbreviation for “reference”

Sol – Abbreviation for “solubility”

Date: December 13, 2023 Page 4 of 8

SDS – Safety Data Sheet. Term that replaced MSDS.

UOM – Unit of Measure

5. INSTRUCTIONS

When entering data into HMS Maximo for a new product under “SDS,” the following fields shall be entered in the format or from the data source specified:

5.1 SDS Tab

5.1.1 Product Name/SDS: Input the name of the item as displayed on the SDS. The SDS and chemical container name should match in order to comply with OSHA’s Hazard

Communication Standard.

5.1.2 Emergency Phone: Enter in the emergency phone number located on the SDS. If there is no emergency phone number listed, the field may be left blank, as this is strictly for internal use.

5.1.3 Product Type: Select the appropriate categorization for the product (ex:glues are listed as adhesives, oils as lubricants, etc.).

5.1.3.1 If the appropriate product type is not listed, contact the HMS team to request addition of a new product type.

5.1.4 Revision and Issue Dates: Input the date(s) the SDS was revised, updated, and/or issued. The format is MM/DD/YYYY.

5.1.5 Attachments: Attach the associated SDS from the shared drive (sometimes internally referred to as the “S Drive.” Select “Add New Attachments>Add New File.

5.1.5.1 In the “Name the document” field, give the name the same SDS number assigned by

HMS Maximo.

5.1.5.2 When saving a new SDS document in the shared drive, assign the same SDS number

HMS Maximo gave the SDS.

5.2 Physical Properties Tab

5.2.1 pH: Enter the data as it appears on the SDS. Enter “NA” if there is no data available.

5.2.2 Specific Gravity or Relative Density (LIQ): Enter the specific gravity from the SDS.

If the specific gravity is not explicitly listed, follow these rules:

Date: December 13, 2023 Page 5 of 8

5.2.2.1 If the specific gravity is given as a range, input the highest number.

5.2.2.2 If the density is listed in grams per milliliter (g/ml) or grams per cubic centimeter

(g/cm3), these are equivalent to the specific gravity.

5.2.2.3 If the density is listed in pounds per gallon (lbs/gal) or kilograms per liter (kg/l), these values are converted to specific gravity. For lbs/gal, divide the number by 8.34. For kg/l, use the given value.

5.2.2.4 If no specific gravity information is listed on the SDS, enter 1.

5.2.3 Relative To: Select the state of matter the product is relative to regarding its relative density or specific gravity (usually water).

5.2.4 Phys. State: Select the physical state of matter that the product is in from the dropdown list.

5.2.4.1 The physical state of aerosols is liquid.

5.3 Manufacturer Tab

5.3.1 Manufacturer: Input the name of the manufacturer as displayed on the SDS. Click

“New Row,” and select the matching company from the detail menu.

5.3.2 If the manufacturer is not listed, go to the detail menu and click “Go to Companies” and create a new manufacturer.

5.3.3 When creating a new manufacturer, make sure the “Company Type” field is changed from Vendor to Manufacturer.

5.3.3.1 If a product or part number is listed on the SDS, add the part number when adding the

Manufacturer. This step must take place before you select “save.”

5.3.4 Once a new manufacturer has been created, save it and select the “Return with Value” option in the upper right corner.

5.4 Chemical Composition Tab

5.4.1 CAS: Enter the CAS number including the dashes and/or leading zeroes by selecting

“New Row.”

5.4.2 Percent: Enter in the percent weight of the product, as listed on the SDS

5.4.2.1 If the percent weight is not listed for the constituent, input 100%.

Date: December 13, 2023 Page 6 of 8

5.4.2.2 If the percent weight is listed as a range, input the upper bound concentration number.

5.4.2.3 If the concentration is listed as “trace amount” or a similar term, list the concentration as 1% of the total weight.

5.4.3 If the CAS number comes up as “No EPA Name,” or an invalid CAS number is inserted, edit or create the CAS number from the main page of the Start Center.

5.4.3.1 When adding an official CAS number to HMS Maximo, be sure to check the applicable boxes (i.e., “TRI Reportable?,” “Hazardous Air Pollutants?”, etc.) that would be accurately reflected on queried reports.

5.4.4 At least one CAS number must be entered into each SDS for a barcode to print.

5.5 Haz Codes Tab:

5.5.1 Enter in the hazard codes into the “Hazard ID” Field.

5.5.1.2 If the actual code is not listed on the SDS, search for it by selecting the double carrots and clicking “Select Value.”

5.6 Safety Measures Tab

5.6.1 NFPA/HMIS – Input the numbers, if available, from the SDS that correspond to each section; Health, Flammability, and Reactivity.

When entering data into HMS Maximo for a barcode under “Receiving,” the following fields shall be entered in the format or from the data source specified:

5.7 SDS Field

5.7.1 Enter in the SDS number of the desired chemical, which can be found in HMS or the

EEOH Portal Site

5.8 Location Field

5.8.1 This location must include both the building number and the room number with a “/” separating them.

5.9 Quantity Field

5.9.1 This is the number of barcodes that will be printed. Only one barcode is needed per item/container.

Date: December 13, 2023 Page 7 of 8

5.10 Container Size Field

5.10.1 Enter in the size of the container without including the units. For example, enter “10” for a 10kg glass bottle that needs to be barcoded.

5.11 Units Field

5.11.1 Enter the units of the container size. For example, click the magnifying glass to the side and select “KG” from the table for a 10kg glass bottle that needs to be barcoded.

5.12 Container Type Field

5.12.1 Select the magnifying glass to the right of the field and choose the container type.

5.13 Storage Temp Option

5.13.1 Select the temperature of the container: “Above Ambient” if the container must be shipped heated, “Ambient” if the container is shipped at room temperature, and

“Below Ambient” if the container must be kept in a refrigerator or freezer.

5.14 Storage Pressure Option

5.14.1 Select the pressure of the container: “Above Ambient” if the container is pressurized, such as a gas cylinder, “Ambient” if the container is not under any pressure change, and “Below Ambient” if the container is in a vacuum and is under negative pressure.

5.15 Save and Print

5.15.1 Once all fields are completed, select the floppy disk icon to save your receipt.

5.15.2 After saving the receipt, select “Receive Items” on the right of the screen.

5.15.3 Print the barcode(s) to the barcode printer by selecting the sheet of paper icon for the

BIRT report view and printing.

6. NOTES

6.1 All hazardous materials arriving at Building 4631 for receiving shall have a barcode within three business days unless the hazardous material falls into a category on the barcode exemption list described in MWI 8550.5 (Hazardous Materials

Management).

6.2 If the shipment is an Overnight Express package, the required barcodes shall be created within 24 business hours.

Date: December 13, 2023 Page 8 of 8

6.3 Before a barcode can be created for a package containing hazardous material to leave receiving, a proactive procurement must be in place for all hazardous material. Refer to MWI 8550.5 for a list of exemptions.

6.4 If a proactive procurement request cannot be located on the SharePoint site, the user/requestor of the item will be contacted, and a request will need to be submitted before a barcode can be created and the package can leave Receiving.

7. SAFETY PRECAUTIONS AND WARNING NOTES

None

8. APPENDICES, DATA, REPORTS, AND FORMS

9. RECORDS

10. TOOLS, EQUIPMENT, AND MATERIALS

HMS Maximo, Datamax-O'Neil Barcode Label Printer and roll of labels

11. PERSONNEL TRAINING AND CERTIFICATION

12. FLOW DIAGRAM

AS10-OI-054

Revision F

EFFECTIVE DATE: February 20, 2024

HAZARDOUS WASTE

MANAGEMENT

INSPECTIONS

NAME TITLE DATE ORG

& Occupational Health Office 2/20/24 AS10

Organizational Issuance AS10

Hazardous Waste Management Inspections

AS10-OI-054 Revision: F

Date: February 20, 2024 Page 2 of 6

03/18/14

This document establishes standardized work procedures for inspecting the hazardous waste yard and satellite accumulation areas.

Revision A 06/24/15 Updated link in 9.1.

Revision B 07/13/16 Revised nomenclature throughout document relative to “controlled” and “special” waste as well as using “Hazardous Waste Storage Facility”.

Revision C 04/04/17 Editorial changes throughout and moved Form 4071 from 9.0 to 8.0.

Revision D 01/16/2020 Revised with minor changes throughout the document.

Revision E 1/27/2022 Updated records link

Revision F 2/20/24 Updated references from SHEtrak to SafeSuite.

Hazardous Waste Management Inspections

AS10-OI-054 Revision: F

Date: February 20, 2024 Page 3 of 6

The purpose of this document is to provide instructions for inspections of satellite accumulation areas (SAAs) and the Hazardous Waste Storage Facility (HWSF).

This document applies to all civil servant and contractor personnel in AS10 performing these inspections.

MWI 8550.1, Waste Management

MWI 8715.12, Safety, Health, and Environmental-Finding Tracking System (SafeSuite

4.1 Satellite Accumulation Area (SAA) – A place at or near the location where hazardous waste is generated set aside for the containers used to actively collect the waste.

4.2 Hazardous Waste Personnel – The personnel that direct, monitor or otherwise manage the hazardous waste program at Marshall Space Flight Center (MSFC). This may be Environmental

Engineering and Occupational Health Office (EEOH) civil service personnel, the EEOH support contractor or both.

4.3 Hazardous Waste Storage Facility (HWSF) – The area set aside at MSFC as a centralized storage facility for hazardous, universal, and PCB waste containers, empty containers, and special wastes awaiting shipment offsite. Hazardous waste stored in this area is shipped to an

EPA-permitted Treatment, Storage or Disposal facility (TSDF)within 90 days of the material being stored.

5.1 Satellite Accumulation Areas (SAA) are located at user sites throughout MSFC and shall be inspected monthly throughout MSFC by Hazardous Waste personnel for the following:

Hazardous Waste Management Inspections

AS10-OI-054 Revision: F

Date: February 20, 2024 Page 4 of 6

5.1.1 The SAA is located at or near the hazardous waste generation points in their area.

NOTE: When assessing “at or near”, ensure the containers are not so far away from the process generating the waste that moving the waste from the point of generation to the accumulation area poses an increased risk of spillage, that the containers are located in an area that poses no increased risk of spillage or mismanagement (a high-traffic area, for example), and that it be in a location that it is routinely under the control of the operator of the process.

5.1.2 SAA is in the area identified to Hazardous Waste personnel at the time the waste container was issued.

5.1.3 The containers provided for the collection of hazardous, universal or special wastes contain only those materials identified for the waste stream, including those wastes listed as “site-wide waste streams”.

5.1.4 Wastes stored near each other are compatible with each other.

5.1.5 Labels and markings that identify container contents and hazards are not defaced or removed.

5.1.6 The container is in good condition and free from leaks and corrosion.

5.1.7 The container is closed unless adding waste to it.

NOTE: These containers are required by regulation to be closed unless actively adding or removing material from them.

5.1.8 No more than 55 gallons (or 1 quart of acutely hazardous waste) of an individual hazardous waste stream are accumulated at an SAA.

NOTE: More than 55 gallons of a hazardous waste can be accumulated at an SAA as long as they are not the same waste stream. Other conditions such as fire suppression requirements or secondary containment may still apply.

5.1.9 Containers are handled and stored in a manner that prevents rupture or leakage from the container.

5.1.10 Containers that are full have the month, day and year on which the container was filled marked on the label affixed to the container.

NOTE: A container holding liquid is considered “full” if 90% of the container is filled.

Hazardous Waste Management Inspections

AS10-OI-054 Revision: F

Date: February 20, 2024 Page 5 of 6

5.1.11 If full, the container label indicating the material in the container meets the original waste stream profile has been dated.

5.1.12 If full, the Hazardous waste personnel has been contacted to pick up the full container.

5.1.13 Hazardous Waste personnel shall note findings and submit to EEOH hazardous waste manager for submission into the SafeSuite system.

5.1.14 As a reference Hazardous Waste Personnel shall use checklist in MSFC Form 4071 when inspecting SAA.

5.2 The HWSF shall be inspected twice per week by Hazardous Waste personnel for the following:

5.2.1 The containers are in good condition and free from leaks and corrosion.

5.2.2 Labels and/or markings on the containers that identify contents and hazards are not defaced or removed.

5.2.3 The containers are closed/sealed unless actively having waste added to them.

5.2.4 Wastes stored near each other are compatible with each other.

5.2.5 Secondary containment is present for those liquid wastes that are stored.

5.2.5.1 If the secondary containment has any liquids present in it, all containers are checked for leaks.

5.2.5.2 Any liquid found in the secondary containment is removed as soon as possible and disposed of in the appropriate waste stream and liquids are removed from containment sumps.

5.2.6 Record number and types of hazardous waste containers present at the HWSF.

5.2.7 Record hazardous waste containers greater than 60 days from their stored date.

5.2.8 Hazardous Waste personnel shall document Hazardous Waste Storage Yard inspections and any noted discrepancy using MSFC Form 4631 “Hazardous Waste Yard Weekly Inspection

Check sheet” or by a method that contains at a minimum the same elements as found on MSFC

Form 4631.

Hazardous Waste Management Inspections

AS10-OI-054 Revision: F

Date: February 20, 2024 Page 6 of 6

As appropriate for materials comprising the waste stream.

8.1 Findings reported in SafeSuite

9.1 The following records shall be maintained according to the “List of AS10 Environmental

Records” located at the following link: EEOH Records Management

9.1.1 MSFC Form 4631, “Hazardous Waste Yard Weekly Inspection Checksheet”

11.1 All persons conducting this activity are trained to the technician level in accordance with 29

CFR Part 1910.120, “Hazardous Waste Operations and Emergency Response

(HAZWOPER)”.

11.2 All persons conducting this activity shall complete annual hazardous waste training for hazardous waste technicians, in accordance with ADEM Administrative Code R.335-14-3-10, referencing ADEM Administrative Code R.335-14-6-.02.

AS10-OI-055

Revision E

EFFECTIVE DATE: March 10, 2022

WASTE

CHARACTERIZATION and

CONTAINER ISSUANCE

NAME TITLE DATE ORG

_______________ Occupational Health Office 3/10/2022 AS10

Waste Characterization and

Container Issuance AS10-OI-055 Revision: E

Date: March 10, 2022 Page 2 of 9

Establishes instructions for the characterization of waste. Standardizes practices, forms and records for documentation and compliance.

Revision A 06/24/15 Updated form title in 5.1.1 and 9.1.1. Updated link in 9 1.

Revision B 07/13/16 Revised “controlled” to “special” waste and updated section 5 2 1.4 to reflect process change Revision C 04/11/17 Editorial changes throughout for clarification.

Revision D 01/27/2021 Editorial changes throughout for clarification. Updated the web link for Records.

Updated instructions to ensure MSFC Form 4072 is updated every 3 years and old records are destroyed.

Revision E 3/10/2022 Added EEOH Form-001 in Appendix A and revised sections 5.2 and 5.3 to reflect use of Form-001.

Waste Characterization and

Container Issuance AS10-OI-055 Revision: E

Date: March 10, 2022 Page 3 of 9

The purpose of this document is to provide instructions for the characterization of wastes at

Marshall Space Flight Center (MSFC) and the issuance of containers for hazardous, universal and special waste.

2.1 All hazardous, universal, Polychlorinated Biphenyl (PCB), and special wastes generated at

MSFC are subject to this instruction.

40 CFR Part 273 Universal Waste Management

40 CFR Part 761 Polychlorinated Biphenyls (PCBs)

MWI 8715.12, Safety, Health, and Environmental-Finding Tracking System (SHEtrak)

4.1 Characterization – The process of determining the chemicals/materials present in wastes.

This process includes review of the materials being wasted and may include laboratory analysis of the waste stream for constituents or characteristics listed by the United States Environmental

Protection Agency (EPA) as hazardous wastes.

4.2 Special Waste – Waste streams not classified as hazardous or universal (according to regulation) but requiring specific processing, handling, or disposal different from other solid wastes.

4.3 Hazardous Waste – A waste or combination of wastes that can pose a substantial or potential hazard to human health or the environment when not properly managed, possesses at least one of four characteristics (ignitable, corrosive, reactive, or toxic), or appears on special

U.S. EPA lists and includes toxic waste, spilled chemicals, and unused chemicals. When stored

Waste Characterization and

Container Issuance AS10-OI-055 Revision: E

Date: March 10, 2022 Page 4 of 9 at Hazardous Waste Storage Facility (HWSF) hazardous waste must be shipped in 90 days or less.

4.4 Hazardous Waste Personnel – The personnel that operate or manage HWSF or are involved in hazardous waste cleanup activities.

4.5 Representative Sample - A sample of a waste stream which can be expected to exhibit the average properties of the waste stream throughout its life.

4.6 Satellite Accumulation Area (SAA) – A place at or near the location where hazardous waste is generated set aside for the containers used to actively collect the waste.

4.7 Universal Waste – Waste which would otherwise be regulated as hazardous waste (see definition above), but which has been classified as “universal waste” with alternative management standards as defined in 40 CFR Part 273. Examples include batteries, pesticides, mercury-containing equipment, and fluorescent and HID lamps. These wastes are required to be shipped offsite to Universal Waste Handler within one year of date of accumulation.

4.8 Waste Stream – The process or processes contributing to a single waste type. A waste stream results when a product is to be disposed of, when a process generates a material that is no longer needed or useful, or a combination of the above. Multiple processes or products may result in a single waste stream.

4.9 PCB Waste – Polychlorinated Biphenyl Waste. Material found in transformers and capacitors, 40 CFR 761.

5.1 Waste Characterization: The following instructions apply to gathering the data necessary to accurately characterize a waste stream.

5.1.1 Contractor Hazardous Waste Manager shall review the MSFC Form 4072 “Waste Stream

Characterization” and Safety Data Sheets (SDSs) submitted by the user for the waste stream to ensure form is complete and all SDSs for the waste stream are included.

5.1.2 Contractor Hazardous Waste Manager shall ensure that MSFC Form 4072 is signed and dated by the waste stream POC, showing that POC has reviewed the data and concur that the information on the form is correct and representative of the waste stream.

5.1.3 Contractor Hazardous Waste Manager shall annually review MSFC Form 4072s on file and ensure that users update their Form 4072 every 3 years (this ensures compliance with

Records Plan).

Waste Characterization and

Container Issuance AS10-OI-055 Revision: E

Date: March 10, 2022 Page 5 of 9

5.1.4 Contractor Hazardous Waste Manager shall also use other methods of characterization as necessary such as SDS and generator knowledge whenever MSFC Form 4072 is not applicable or required.

5.1.5 Hazardous Waste Personnel shall obtain a sample from the waste stream for analytical characterization as follows:

5.1.5.1 Ensure that personal protective equipment (PPE) appropriate to the waste stream is available and worn during the sampling process. (PPE may include, but is not limited to, impervious gloves, respiratory protection and/or eye and face protection.)

NOTE: If questions arise relative to appropriate PPE for a task, consult with Industrial Hygiene at 256-544-2390.

5.1.5.2 Select the sampling methodology, sampling equipment and PPE necessary to safely obtain a representative sample based upon:

a) Physical form of the waste (solid, liquid, sludge, etc.).

b) Type and size of container.

c) Suspected hazardous materials determined from review of MSFC Form 4072 and SDSs.

5.1.5.3 If needed, contact the laboratory to be used for analysis to request appropriate container and preservative (if necessary) to ensure sample stability and integrity until received at the laboratory.

5.1.6 Once analytical results are received from the lab, Hazardous Waste Personnel shall:

5.1.6.1 Confirm or enter the applicable profile number on the MSFC Form 4072.

5.1.6.2 Identify on MSFC Form 4072 all waste codes associated with the waste.

5.1.6.3 Ensure that the laboratory supplies the standard reference method used for the analysis and note the method(s) on the MSFC Form 4072.

NOTE: This may be done by attaching representative profile characterization analysis to MSFC

Form 4072.

5.1.6.4 Upon completing a waste characterization and generating a profile (or identifying an existing profile under which the waste may be handled), enter the appropriate information into the waste tracking software so that a waste container may be issued.

Waste Characterization and

Container Issuance AS10-OI-055 Revision: E

Date: March 10, 2022 Page 6 of 9

5.1.7 Hazardous Waste Personnel shall re-evaluate waste stream characterization when generating organization submits an updated Form 4072, indicating a change to process has occurred.

5.2 Issuing waste containers: Once a waste stream is characterized, containers for the waste stream are issued. The following instructions pertain to the issuance of containers for the collection of hazardous and universal wastes.

5.2.1 When a container is issued to a user, the Hazardous Waste Personnel shall utilize EEOH

Form-001 (see Appendix A) to record Form-001 data into Maximo:

5.2.2 The Hazardous Waste Personnel shall affix the labels generated by the database to the appropriate containers and deliver them to the user.

5.3 Waste container pick-up: When containers are picked up from users, the Hazardous

Waste Personnel shall:

5.3.1 Utilize EEOH Form-001 (see Appendix A) to record Form-001 data into Maximo.

5.3.2 Weigh the container and record weight in the database.

5.3.3 Place the container in the storage bay appropriate for the hazard class presented by the waste.

EEOH Form-001 “Waste Characterization and Container Issuance Call Log Sheet”

Records” located at the following link:

Waste Characterization and

Container Issuance

Date: March 10, 2022 Page 7 of 9

9.1.1 MSFC Form 4072, Waste Stream Characterization

9.1.2 Sampling and analytical results associated with each MSFC Form 4072.

10.1 Sampling devices and containers necessary to homogenously sample, preserve and ship waste material for characterization.

NOTE: These will vary based on the physical form of the waste, volume of waste to be sampled and chemicals that are to be analyzed.

10.2 Personal protective equipment such as, but not limited to, impervious gloves, splash suits, respirators and eye/face protection as appropriate for the hazards presented by the sampling process.

All persons conducting this activity are trained to the technician level in accordance with 29 CFR

Part 1910.120, Hazardous Waste Operations and Emergency Response (HAZWOPER).

All personnel conducting or managing these activities must receive annual Hazardous Waste

Training in accordance with Alabama Department of Environmental Management 335-14-05.

Waste Characterization and

Container Issuance

Date: March 10, 2022 Page 8 of 9

Appendix A

Confirmation: ______________________ Date: _______________ Time: __________ Issue Turn In

Requestor: _______________________________ Phone: ___________________ Org Code: __________

Location of Waste: _____________________________________________________________________

Control Drum # Replacement

(Date & Time Delivered) POC Change?

(Org/Name of POC)

1)

2)

3)

4)

Comments

Confirmation: ______________________ Date: _______________ Time: __________ Issue Turn In

Requestor: _______________________________ Phone: ___________________ Org Code: __________

Location of Waste: _____________________________________________________________________

Control Drum # Replacement

(Date & Time Delivered) POC Change?

(Org/Name of POC)

1)

2)

3)

4)

Comments

EEOH Form-001 (March 2022) Previous Versions Obsolete

Waste Characterization and Container Issuance

Call Log Sheet

AS10-OI-056

Revision E

EFFECTIVE DATE: April 1, 2021

HAZARDOUS WASTE

CONTAINER

MANAGEMENT and

TRANSPORTATION

PROCEDURES

NAME TITLE DATE ORG

\\Original signed by// & Occupational Health Office 4/1/2021 AS10

Hazardous Waste Container Management and Transportation

Procedures

AS10-OI-056 Revision: E

Date: April 1, 2021 Page 2 of 8

This document establishes standardized work procedures for transportation device inspection and bulk material transfer.

Revision A 06/24/15 Updated link in 9.1.

Revision B 07/13/16 Revised use of “controlled” vs “storage”, updated to consistent nomenclature for

“Hazardous Waste Storage Facility”.

Revision C 04/04/17 Editorial changes throughout for clarification.

Revision D 06/21/17 Overpack was included in 4. Definitions and 5.5 Instructions.

Revision E 04/01/2021 Editorial changes throughout for clarification

Hazardous Waste Container Management and Transportation

Procedures

AS10-OI-056 Revision: E

Date: April 1, 2021 Page 3 of 8

The purpose of this document is to provide instructions for inspections of waste transportation devices such as, but not limited to, bulk tanks, roll-off boxes and semi-trailers and the procedure for transfer of hazardous waste to bulk storage/transport containers.

2.1 This document applies to all personnel in AS10 performing these inspections.

AS10-OI-002, Offsite Compliance Audits for Resource, Conservation and Recovery Act

Treatment, Storage, and Disposal Facilities

40 CFR Part 262 Standards Applicable to Generators of Hazardous Waste

4.1 Bulk Storage Container – Bulk storage containers are those containers with volumes greater than 110 gallons and include items such as, but not limited to, portable tanks and roll-off boxes.

4.2 Special Waste – Waste streams not classified as hazardous (according to regulation) but requiring specific processing, handling, or disposal different from other solid wastes.

4.3 Environmental Engineering and Occupational Health Office (EEOH) Hazardous Waste Point of Contact (POC) – The civil servant responsible for day-to-day monitoring and management of hazardous, universal and special waste activities.

4.4 Hazardous Material Transport Vehicle – The semi-trailer, semi-tanker or other device used to transport bulk and non-bulk packaging of hazardous, special or universal wastes.

4.5 Hazardous Waste - A waste or combination of wastes that can pose a substantial or potential hazard to human health or the environment when not properly managed, possesses at least one of

Hazardous Waste Container Management and Transportation

Procedures

AS10-OI-056 Revision: E

Date: April 1, 2021 Page 4 of 8 four characteristics (ignitable, corrosive, reactive, or toxic), or appears on United States

Environmental Protection Agency (EPA) lists and includes toxic waste, spilled chemicals, and unused chemicals. Hazardous wastes are required to be shipped from MSFC within 90 days of their container being declared full (90% of container capacity).

4.6 Hazardous Waste Personnel – The personnel employed to direct, monitor or otherwise manage the hazardous waste program at MSFC.

4.7 Hazardous Waste Supervisor – The person having responsibility for the management and daily schedule of the personnel who work at the Hazardous Waste Storage Facility (HWSF).

4.8 Hazardous Waste Storage Facility (HWSF) – The area set aside at MSFC as a centralized storage facility for full hazardous waste containers awaiting shipment offsite. Hazardous waste stored in this area is sent to an EPA-permitted transportation, storage or disposal facility within

90 days of the material being received. For the purposes of this Organizational Issuance, any hazardous and universal waste handled through EEOH is to be handled in similar fashion.

4.9 Overpack – Outer packaging used to provide protection in handling of a container (drum).

4.10 Treatment, Storage and/or Disposal Facility (TSDF) – A facility permitted by the U.S. EPA for the treatment, storage, and/or disposal of hazardous/universal waste that has been inspected and approved by EEOH personnel.

4.11 Universal Waste – Waste which would normally be regulated as hazardous waste (see definition above), but which has been classified as “universal waste” with alternative management standards as defined in 40 CFR Part 273. Examples include batteries, pesticides, mercury-containing equipment, and fluorescent and HID lamps. These wastes are required to be disposed of within 1 year from start of accumulation.

5.1 Receiving Containers at the HWSF

5.1.1 Hazardous Waste Personnel shall assess the following prior to receiving a container into the HWSF:

5.1.1.1 Labels and/or markings supplied with the container identifying contents and hazards are not defaced or removed.

5.1.1.2 The container is in good condition and free from leaks and corrosion.

5.1.1.3 The containers are closed/sealed unless actively having waste added to them.

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5.1.1.4 If a container is brought to the HWSF by someone other than Hazardous Waste

Personnel and the container has any noted deficiencies, the container shall be refused for acceptance and the POC for the container, the Hazardous Waste Supervisor and EEOH

Hazardous Waste POC shall be notified by email of the discrepancy.

5.1.2 Weigh and/or estimate volume, as appropriate, for each container and document in the

Hazardous Waste Section Log Book and/or the electronic database management system for hazardous waste.

5.1.3 Ensure the container fill date is entered into the hazardous waste management database.

5.1.4 Store each waste container so each waste is segregated with compatible wastes.

5.2 Managing Hazardous and Universal Waste at the HWSF

5.2.1 All hazardous and universal waste stored in the HWSF shall be transported off site before:

5.2.1.1 Ninety (90) calendar days have elapsed from HWSF accumulation date for hazardous wastes.

5.2.1.2 One year has elapsed from date container entered service for universal wastes.

NOTE: Storage times for hazardous and universal waste may be extended only by written notification from the Alabama Department of Environmental Management (ADEM) and the

EEOH.

5.3 Once per week, a query shall be run from the hazardous waste management database for all containers with the following parameters:

5.3.1 Hazardous waste containers in storage at the Hazardous Waste Yard for 45 days and greater.

5.3.2 Universal waste containers in service for 240 days or greater.

5.4 For hazardous and universal waste approaching their maximum respective holding times, Hazardous Waste Personnel shall make arrangements to have the material removed from the site to a permitted processing facility (approved in accordance with AS10-OI-002) prior to reaching the maximum storage time.

5.4.1 To ship hazardous and universal waste to a TSDF, the Hazardous Waste Personnel shall prepare a list of containers for the shipment.

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5.4.2 Hazardous Waste Supervisor shall contact the TSDF and arrange for waste pickup.

5.4.3 The Hazardous Waste Supervisor ensures that the uniform hazardous waste manifest is prepared and identifies any emergency response guides, labels placards or markings necessary for Department of Transportation (DOT) compliance are provided.

Note: The Hazardous Waste Supervisor is normally responsible for contacting the TSDF, arranging for waste pickup and completing required manifests. The contractor Environmental

Technicians may handle these duties as needed in the absence of the Hazardous Waste

Supervisor.

5.4.4 The uniform hazardous waste manifest and any ancillary documents and/or DOT compliance information are provided to the EEOH Hazardous Waste POC. The Hazardous

Waste Supervisor (or Environmental Technicians) signs the manifests on behalf of NASA, indicating acceptance of information and approval to ship materials.

5.4.5 The hazardous waste manifest, DOT compliance information and any ancillary documentation is supplied to the Hazardous Waste Personnel loading the material for shipment.

5.4.6 Upon arrival of the hazardous material transport vehicle, Hazardous Waste Personnel shall inspect the vehicle and record the inspection on MSFC Form 4632, Hazardous Waste Vehicle

Inspection.

5.4.7 In addition to the inspection, a copy or picture of the transport devices driver’s license shall be made and appended to the form/record showing that the driver has appropriate endorsements for the type of load transported (e.g., hazardous material, tank truck, etc.).

5.5 Upon successful inspection of the transport device, the Hazardous Waste Personnel shall load the device and provide the uniform hazardous waste manifest and any ancillary documentation to the driver. If an unintentional release occurs or threatens to occur from a hazardous material drum being shipped offsite from HWSF, the drum will be placed in an overpack. Overpack will be marked/labeled the same as drum inside it. The hazardous waste transport driver and disposal facility will be advised that overpack is part of shipment. Notation will be entered on manifest that overpack is transported on shipment.

5.6 For each hazardous waste load, if a signed manifest by the TSDF owner/operator is not received from the TSDF within 35 days, the Hazardous Waste Supervisor or EEOH Hazardous

Waste POC contacts the TSDF to determine the reason for the delay.

5.6.1 If a signed manifest by the TSDF owner/operator is not received within 45 days of shipment, the Hazardous Waste Supervisor or contract manager emails the EEOH Hazardous

Waste POC noting the need for an exception report and prepares the report with the following:

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5.6.1.1 A copy of the manifest for which signed manifest was not received.

5.6.1.2 A signed cover letter explaining the efforts taken to locate the hazardous waste and the results of those efforts.

5.6.2 The Hazardous Waste Supervisor provides via email or hard copy to EEOH a copy of the exception report.

Records” located at the following link:

9.1.1 MSFC Form 4632, Hazardous Waste Vehicle Inspection

9.1.2 Exception Report, ADEM 335-14-3

9.1.3 Signed ‘Designated facility to generator’ copy of hazardous waste manifest

10.1 Government supplied hazardous material/waste tracking database

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AS10-OI-061

EFFECTIVE DATE: July 18, 2023

AEROSOL PUNCTURE

PROCEDURE,

OPERATION AND

MAINTENANCE

NAME TITLE DATE ORG

_ Occupational Health Office 7/18/2023 AS10

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Date: July 18, 2023 Page 2 of 8

CHECK THE MASTER LIST-

7/18/2023

Establishes instructions for the assembly, operation and maintenance of Model J-7 aerosol can depressurizing system. Establishes the proper segregation of incompatible waste and proper waste management practices to prevent fires or releases based on 40 CFR 273.13 (e)(4)(ii)

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The purpose of this document is to establish instructions for the assembly, operation and maintenance of the Model J-7 aerosol can depressurizing system used at the Hazardous Waste

Storage Facility. Establishes procedures to properly segregate incompatible waste and waste management practices to prevent fires or releases at Marshall Space Flight Center (MSFC) as required by 40 CFR 273.13 (e)(4)(ii).

This procedure is applicable to all personnel utilizing the aerosol can depressurizing system at the

MSFC Hazardous Waste Storage Facility.

40 CFR Part 273.13(e)(4)(ii) Universal Waste Management Aerosol Cans

40 CFR 262.11 Criteria for Listing Hazardous Waste

4.1 ADEM – Alabama Department of Environmental Management

4.2 Aerosol Container – a non-refillable container holding compressed, liquefied, or dissolved gas and is fitted with a self-closing release device that when pressed expels liquid, past or powder.

4.3 Hazardous Waste Personnel – The personnel that operate or manage HWSF or are involved in hazardous waste cleanup activities.

4.4 Hazardous Waste Storage Facility (HWSF) – The area set aside at MSFC as a centralized storage facility for hazardous, universal, and PCB waste containers, empty containers, and special wastes awaiting shipment offsite.

4.5 Model J-7 Aerosol Can Depressurizing System (A.K.A. Can-Emitor) – Aerosol can puncturing system to allow for depressurizing aerosol cans

4.6 Representative Sample - A sample of a waste stream which can be expected to exhibit the average properties of the waste stream throughout its life.

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4.7 Waste Stream – The process or processes contributing to a single waste type. A waste stream results when a product is to be disposed of, when a process generates a material that is no longer needed or useful, or a combination of the above. Multiple processes or products may result in a single waste stream.

5. INSTRUCTIONS Assembly, Operation, Cleaning, and Maintenance

The following instructions apply to Model J-7 aerosol can depressurizing system (Can-Emitor).

5.1 Assembly, Operations

Follow procedures outlined in Operation Instructions, Appendix A

5.2 Cleaning

5.2.1 If the Can-Emitor needs cleaning, puncture containers with solvents, degreasers and/or lubricants last to help clean the device.

5.2.2 Water can also be used and drained into DOT container holding contents of punctured aerosol cans

5.3 Maintenance

5.3.1 The following components must have a thin coating of lithium grease:

• Inside machined surface of the cover

• “O” ring

• Plunger piercing mechanism

5.3.2 Filter Changes (if used)

• ColorMatic Filter changes from magenta to black – change

• Standard Carbon Filter after 1000 aerosol can punctures – change

5.3.3 Clean the Check Valve Assembly thoroughly inside and out, inspect seals and gaskets replace if needed.

5.4 SEGREGATION OF INCOMPATIBLE AEROSOLS

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5.4.1 Never vent either caustics or pesticides (including insecticides, fungicides or rodenticides) in the same container as paint and lubricants. Also do not mix incompatible liquids together as it could result in an explosion.

5.4.2 Per ADEM do not puncture container with any of these ingredients: ethyl ether (often in starting fluids), chlorinated compounds, pesticides, freons and foamers, oven cleaners and unknowns, these should be lab packed and managed as Hazardous Waste.

5.4.3 Do not puncture intact pesticides and caustic aerosols. These will be segregated, actuators removed, and lab packed into a separate DOT approved 55G drum, characterized and labeled as Hazardous waste for disposal

5.4.4 Aerosols that show evidence of leaking must have actuators removed, packaged in a separate container or overpacked with absorbents thus segregating from intact containers.

Marked/Dated as “Universal Waste – Aerosol cans” or properly labeled as Hazardous Waste

5.5 PICKUP AND DISPOSAL RESPONSIBILTIES AND PROCEDURES

5.5.1 Pickup containers at Aerosol Satellite Accumulation Area when POC calls in for a turn in of container.

5.5.2 Place all waste aerosols cans in a container marked, “Waste Aerosol Cans – Pending

Puncture” in the Hazardous Waste Primary Accumulation Area, with a start date on the container

5.5.3 Place punctured cans into a container labeled “Punctured Aerosol Cans – Scrap Metal”

5.5.4 Container with punctured spray cans will be crushed in the drum crusher and made into a

“puck” and place in scrap metal container.

5.6 CHARACTERIZATION AND WASTE DETERMINATION

5.6.1 Contents of punctured Aerosol cans must be placed in a container or tank that meets the requirements of 40 CFR 262.14, 262.15, 262.16 or 262.17. This will help prevent spills or cause damage

5.6.2 Container will be dated at the first drop of waste and labeled as “Hazardous – pending analysis.”

5.6.3 Conduct a Hazardous Waste Determination on the drained contents of the cans per 40

CFR 262.11.

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5.6.4 When the determination is completed showing the waste as either Hazardous Waste or

Nonhazardous waste, proper labeling will be completed.

7.1 Wear safety goggles while operating Can-Emitor.

7.1.2 Do not use Can-Emitor while smoking or near open flames.

7.1.3 Properly “ground” drum.

7.1.4 Operate in a well-ventilated area.

7.1.5 Fill DOT Hazardous Approved drum or container 75% capacity

7.1.6 Cover of Can-Emitor should be locked during the evacuation process

7.1.7 Allow all contents to drain before opening and removing punctured aerosol cans

7.1.8 Spill Cleanup Kit will be provided

8. PERSONNEL TRAINING AND CERTIFICATION

All persons responsible for picking up, puncturing and/or disposing of waste aerosol cans shall be trained on the procedure

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APPENDIX A

Operating Instructions for Model J-7 Aerosol Can Depressurizing System

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