Environmental Standard Operating Procedure Originating Office: MCAS Yuma Environment Department

Transcription

1 Environmental Standard Operating Procedure Originating Office: MCAS Yuma Environment Department Revision: Draft Supersedes: n/a Prepared By: EM-Assist, Inc. Approved By: File Name: CTC-ESOP Effective Date: Document Owner: C. Kost Title: Cooling Tower Corrosion Control 1.0 PURPOSE The purpose of this Environmental Standard Operating Procedure (ESOP) is to provide environmental guidelines for managing hazardous materials and hazardous waste generated by Cooling Tower Corrosion Control (CTC) activities. 2.0 APPLICATION This guidance applies to those individuals who perform daily operations and maintenance on CTC. 3.0 PROCEDURE 3.1 Discussion: CTC consists of cleaning and sanitizing water chiller cooling towers, associated with air conditioning systems for barracks, to prevent algae growth and buildup of scale. Cooling towers are periodically drained and sprayed out with a power washer using a pre formulated solution to clean, disinfect and keep the system running smoothly. The copper tubing of the cooling towers is lined daily with a growth inhibitor. CTC operations require the use of hazardous materials such as growth inhibitors, biocide (chlorine tablets) and sulfamic acid (mild acid used for annual cleaning and maintenance). These materials must be managed properly to avoid impacts to human health and the environment. All hazardous materials must be stored in appropriate, approved containers. Units are equipped with approved containers and aboveground storage tanks (ASTs), as necessary. Units should contact the Environmental Department for replacement of or to request additional containers. 3.2 Operational Controls: The following procedures apply: 1. Ensure that Material Safety Data Sheets (MSDSs) for growth inhibitors, biocide, sulfamic acid and all materials associated with this practice are current and available for inspection. 2. Operation Manual is available and is in a designated location. 3. Maintain required current training and certifications for all staffs. For Government Use Only. Page 1 of 6

2 4. Wear appropriate Personal Protective Equipment (PPE) including goggles, safety glasses, face shields, hearing protection, aprons, gloves, and steel-toed boots as appropriate. 5. Use secondary containment around 5 gallon bucket of sulfamic acid solution during mixing and power washing operations. 6. Test chemical level of inhibitor tanks daily using test kits to ensure proper functioning of chemical monitoring system. 7. Maintain a fully stocked spill kit nearby in a designated location. 8. Properly clean up all spills as soon as they are identified and report the spill to the supervisor and EMD. 9. Record all spills 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 and ensure that a spill report containing this information is submitted to the EMD. 10. Notify Environmental Department if extended generator use is intended, to ensure that total annual cumulative generator run time is within regulatory limits (Environmental checks hours). 11. Ensure that generator engine run time is recorded using a non-resettable run time recording device on the engine. 12. Ensure that the fuel supply truck or fuel container is grounded during refueling of generators. 13. Conduct periodic maintenance as recommended by manufacturer. 14. Inspect tanks, secondary containment and drainage valves to ensure they are free of leaks and in the fully closed position. 15. Document periodic inspections of tanks and storage areas. 16. Ensure that all inspection records are maintained and available for examination for up to three years. 17. If there are any specific situations or other concerns not addressed by this procedure, contact the Environmental Management 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 and certifications for personnel. 3. Operation manuals. 4. Daily log book containing dates and times of operation, total cumulative hours of operation. For Government Use Only. Page 2 of 6

3 5. Hazardous materials inventory (must match Authorized Usage List). 6. Hazardous waste log book. 7. Spill log book. 8. Scheduled maintenance log book. 9. Required permits. 3.4 Training: All personnel must be trained in this ESOP, to include the following, as applicable: 1. Hazard Communication (HazCom) Training hour Hazardous Waste Operations and Emergency Response Training (initial/annual). 3. First Responder Operations (FRO) Training (initial and refresher). 4. Preventative Maintenance Training (MRC). 5. On-the-job training. 3.5 Emergency Preparedness and Response Procedures: Refer to Marine Corps Order (MCO) P5090.2A, Subject: Oil/Hazardous Substance Spills (OHSS) and Spill Prevention Containment & Countermeasures (SPCC) for MCAS Yuma. 3.6 Inspection and Corrective Action: The Hazardous Waste Coordinator (HWC) shall perform or designate personnel to perform inspections. The HWC shall ensure deficiencies noted during the inspections are corrected immediately. Actions taken to correct each deficiency shall be recorded on the inspection sheet. 4.0 REFERENCES 40 CFR 262 (Code of Federal Regulations) 29 CFR 1910 MCO P5090.2A (Marine Corps Order) BO (Base Order) ICAPCD Rules (Imperial County Air Pollution Control District) ICAPCD Permits to Operate NPDES General Permit CAS Section A (10)(a) (National Pollutant Discharge Elimination System) For Government Use Only. Page 3 of 6

4 Cooling Tower Corrosion Control Inspection Checklist Date: Time: Installation: Work Center: Inspector s Name: Signature: Inspection Items Yes No Comments 1. Are MSDSs current and available for inspection? (29 FR 1910) 2. Is an operation manual for the AAG engine available and in a designated location? 3. Are required current training and certifications maintained for all staffs? 4. Is appropriate Personal Protective Equipment (PPE) worn, including eye protection, hearing protection, aprons, gloves, and steel-toed boots as appropriate? (29 FR 1910) 5. Is secondary containment used around 5 gallon bucket of sulfamic acid solution during mixing and power washing operations? (40 FR, 29 CFR, MCO P5090.2A) 6. Is the chemical level of inhibitor tanks tested daily using test kits to ensure proper functioning of chemical monitoring system? 7. Is a fully stocked spill kit kept nearby in a designated location? (40 CFR 262, 29 CFR 1910) 8. Are spills properly cleaned up as soon as they are identified and reported to the supervisor and EMD? (40 CFR 262, 29 CFR 1910) 9. Are all 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 and a spill report containing this information submitted to the EMD? (40 CFR 262, 29 CFR 1910) 10. Is the Environmental Department notified if extended generator use is intended? 11. Is generator engine run time recorded using a nonresettable run time recording device on the engine? 12. Is the fuel supply truck or fuel container grounded during the refueling of generators? For Government Use Only. Page 4 of 6

5 Inspection Items Yes No Comments 13. Is periodic maintenance conducted as recommended by manufacturers at least once a year? 14. Are tanks secondary containment and drainage valves inspected to ensure they are free of leaks and maintained in the closed position? 15. Are periodic inspections of tanks and storage areas documented? (40 CFR 262) 16. Are inspection records current and available for examination for up to three years? For Government Use Only. Page 5 of 6

6 ADDITIONAL COMMENTS: CORRECTIVE ACTION TAKEN: Hazardous Waste Coordinator Name: Signature: Date: For Government Use Only. Page 6 of 6