CONTINENTAL MARITIME of SAN DIEGO
Subject:
PROCEDURE
Environmental Requirements (General)
DOC NO.
EC-001 Rev. H
PAGE
1 of 14
DATE
3/6/2014
SUPERSEDES
EC-001 Rev. G
AUTHORIZED DOCUMENTS ARE PUBLISHED ONLINE ONLY.
VERIFY ANY COPY AGAINST THE ONLINE SYSTEM BEFORE USE.
1
Addition of a reference
PURPOSE:
1.1
2
REVISION
To ensure the health and safety of workers, protect the environment, and ensure
that all pertinent regulatory ordinances, statutes, laws, rules and regulations are
adhered to
RESPONSIBILITY/AUTHORITY:
2.1
The following organizations are affected by this document:
A.
2.2
All Departments
The Environmental, Health & Safety Department has primary responsibility and
accountability for the process and for its implementation.
A.
The Training Department is responsible for initial training of this
instruction.
3
THE MANAGER, ENVIRONMENTAL, HEALTH AND SAFETY IS RESPONSIBLE FOR
AUTHORIZING AND APPROVING THIS DOCUMENT
4
REFERENCES:
4.1
4.2
Federal
A.
Code of Federal Regulations (CFR)
1)
40 CFR - Protection of Environment
2)
49 CFR – Transportation
B.
Clean Water Act
C.
Resource Conservation and Recovery Act (RCRA)
D.
All other applicable federal laws
State
A.
California Code of Regulations
1)
Title 22; Social Security
a)
Division 4.0; Environmental Health
b)
Division 4.5; Environmental Health Standards for Management
of Hazardous Waste
c)
Title 29; Labor
2)
Health and Safety Code
CMSD Company Private. This document contains information proprietary or sensitive in nature and may be used only for
performance of related contract work. This document may not be used or reproduced for any other purpose without the specific
written permission of the CMSD ISO Representative.
Huntington Ingalls Industries Private/Proprietary Level 1
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DOC NO. EC-001 Rev. H
Date:3/6/2014
Page 2 of 14
a)
B.
4.3
Division 20
(a) Chapter 6.5; Hazardous Waste Control Laws
(b) Chapter 6.6; Safe Drinking Water and Toxic Enforcement
Act of 1986
3)
National Pollutant Discharge Elimination System (NPDES Permit)
a)
Order Number R9-2008-0049
b)
NPDES Number CA0109142
All other applicable state laws
Local
A.
B.
San
1)
2)
3)
4)
Additional References
1)
5
Diego Air Pollution Control District (APCD)
APCD Rules and Regulations
County of San Diego, Environmental Health Services
Supervisor of Shipbuilding, Environmental Handbook
All other applicable laws
NAVSEA
a)
Applicable Standard Items
4.4
No work will be allowed at Contractor’s facilities until the above mentioned
references are adhered to by all responsible parties, including their visitors,
subcontractors/vendors, and SIMA or Third Party Personnel.
4.5
(CP A1) Management Principles
4.6
(CP A14) Enterprise Risk Management
4.7
NN 01-231Environmenal, Health and Safety
DEFINITIONS:
5.1
National Pollutant Discharge Elimination System (NPDES): As authorized
by the Clean Water Act, the National Pollutant Discharge Elimination System
(NPDES) permit program controls water pollution by regulating point sources
that discharge pollutants into waters of the United States.
5.2
Hazardous Material: Any material having the potential to present a hazard to
human health, the environment, or property, including hazardous waste.
5.3
Volatile Organic Compound (VOC): Any compound of carbon, which may be
emitted to the atmosphere during application of and/or subsequent drying or
curing of coatings or compounds subject to Air Pollution Control District Rule
67.18, except methane, carbon monoxide, carbon dioxide, carbonic acid, metallic
CMSD Company Private. This document contains information proprietary or sensitive in nature and may be used only for
performance of related contract work. This document may not be used or reproduced for any other purpose without the specific
written permission of the CMSD ISO Representative.
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DOC NO. EC-001 Rev. H
Date:3/6/2014
Page 3 of 14
carbides or carbonates, ammonium carbonate and exempt compounds in grams
of VOC content per liter of coating minus water and exempt compound.
A.
6
Note: VOC Unit of Measurement = grams/liters (g/l) or pounds/gallon
(lbs/gal). Conversion: grams/liter to pounds/gallon divides by 120.
5.4
Industrial Waste Water Discharge: Industrial waste is defined as those
effluents that are generated during the course of some industrial activity (i.e.,
hydrostatic testing, treated bilge water, boiler blow down, etc.).
5.5
Environmental Protection Agency: A federal agency established to
coordinate programs aimed at reducing pollution and protecting the
environment.
5.6
RCRA: (Resource Conservation & Recovery Act of 1976) the principal federal law
in the United States governing the disposal of solid waste and hazardous waste.
5.7
SIMA: (Shore Intermediate Maintenance Activity) the primary maintenance
facilities that proved shore support.
5.8
SWRMC: (Southwest Regional Maintenance Center) provide ship maintenance,
modernization and technical support to the ships in the pacific fleet.
5.9
Department of Transportation: United States federal department that
institutes and coordinates national transportation programs. The DOT regulates
the transportation of hazardous & non-hazardous materials.
PROCEDURE:
6.1
No hazardous material/substance/waste or miscellaneous debris or any
processes, which will alter the physical state of water quality, are allowed in San
Diego Bay.
A.
Continental Maritime of San Diego (CMSD) is a zero discharge facility, per
reference 4.2 (a) (3).
B.
Please be advised that CMSD is under strict regulations by Coast Guard,
EPA, Department of Environmental Health (DEH), Department of Fish &
Game, and the Regional Water Quality Control Board concerning water
pollution. CMSD will shut down any operation that violates these
prohibitions and/or discharge specifications.
C.
In accordance with CMSD Best Management Practices (BMP’s) all vessels
shall be boomed by the company responsible for the maintenance
operation to contain possible spills while performing any over the water
pumping operation, including but not limited to ballast and bilge water
during normal maintain operations.
D.
All concerned party and their employees or any subcontractors are subject
to the penalties, fines, civil and/ or criminal actions from any or allregulatory agencies arising from negligence by your employees or
subcontractors.
CMSD Company Private. This document contains information proprietary or sensitive in nature and may be used only for
performance of related contract work. This document may not be used or reproduced for any other purpose without the specific
written permission of the CMSD ISO Representative.
Huntington Ingalls Industries Private/Proprietary Level 1
AUTHORIZED DOCUMENTS ARE PUBLISHED ONLINE ONLY.
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E.
6.2
6.3
6.4
DOC NO. EC-001 Rev. H
Date:3/6/2014
Page 4 of 14
If you feel your work process might violate these regulations in any
manner, please contact the Environmental Health and Safety Department
so that solutions may be found before violations occur.
INDUSTRIAL STORMWATER PERMIT
A.
Continental Maritime’s Best Management Practices (BMP) governing the
Storm water Pollution Prevention Plan (SWPP) (EC-002) require that all
materials/areas which have the potential of contaminating storm water
runoff be managed in such a way that eliminates contaminates from
entering the storm water conveyance system.
B.
Good BMPs are the result of efforts by all concerned party and their
employees and their subcontractors/vendors. Paramount in the application
of storm water pollution prevention is housekeeping:
1)
All oil sorbent materials must be picked up by close of business
and/or before it rains.
2)
Check all storm drains/pier scuppers in your work area for trash and
other debris.
3)
Notify Environmental Health and Safety if you see anything that may
need to be investigated.
SAFETY DATA SHEETS
A.
29 CFR 1910.1200(e) (iii) requires that CMSD to keep readily available all
Safety Data Sheets (SDSs) for chemicals that any employee may be
exposed to during work activities at our facilities.
B.
This federal regulation requires that you provide SDSs on all hazardous
materials you will be using during the course of work activities, and that
your employees have been trained to understand them.
C.
For SDS information, contact CMSD Environmental, Health and Safety
Department.
ENVIRONMENTAL PROTECTION AGENCY IDENTIFICATION NUMBERS
(EPA ID NUMBERS)
A.
ALL concerned Party and their subcontractors, SIMA and Third Party
generating hazardous waste must obtain an EPA ID Number (site specific)
unless other arrangements have been approved by CMSD Environmental
Health and Safety Department.
B.
EPA ID Number can be obtained by calling the following agencies:
1)
RCRA Waste: EPA, (415)-495-8895
CMSD Company Private. This document contains information proprietary or sensitive in nature and may be used only for
performance of related contract work. This document may not be used or reproduced for any other purpose without the specific
written permission of the CMSD ISO Representative.
Huntington Ingalls Industries Private/Proprietary Level 1
AUTHORIZED DOCUMENTS ARE PUBLISHED ONLINE ONLY.
VERIFY ANY COPY AGAINST THE ONLINE SYSTEM BEFORE USE.
DOC NO. EC-001 Rev. H
Date:3/6/2014
Page 5 of 14
RCRA hazardous waste, as defined in 22 CCR, means all waste identified as
hazardous waste in Part 261 (commencing with Section 26.1) of
subchapter 1 of chapter 1, of Title 40 of the Code of Federal Regulations
and appendices thereto.
C.
Non-RCRA Waste: Department of Toxic Substances Control, (916) 3241790.
Non-RCRA hazardous waste, as defined in 22 CCR, means all hazardous
waste regulated in the state, other than RCRA hazardous waste as defined
in this section. A hazardous waste is presumed to be a RCRA hazardous
waste, unless it is determined pursuant to Section 66261.101 that the
hazardous waste is a non-RCRA hazardous waste.
6.5
6.6
EQUIPMENT/OPERATING PERMITS
A.
All personnel working with equipment and/or processes, which are
governed by specific permit requirements in addition to regulation, must be
thoroughly familiar with the requirements of that permit. Review the
permit before operating equipment.
1)
All contractors working under any regulatory permit must be familiar
with and follow all permit conditions.
B.
If your work process or equipment requires permits from any local, state.
Or federal agency, copies of these permits must be provided to the CMSD
Environmental Health and Safety Department prior to the start of work.
MARINE COATING AND WELDING OPERATIONS
A.
Any contractor performing Marine Coating Operations, including touch-up
paint, must use paints compliant with APCD rules and regulations.
B.
CMSD Employees using the Daily Volatile Organic Compound (VOC)
emissions log must submit the log to the CMSD Environmental Health and
Safety Department daily.
1)
Contractors reporting Volatile Organic Compound (VOC) emissions
data must maintain daily records and submit the records to the
CMSD Environmental Health and Safety Department no later than the
10th of each month, for the previous month.
C.
To obtain a VOC Log, contact CMSD Environmental, Health and Safety
Department.
D.
CMSD employees that conduct welding operations must report weld rod
usage through the weld rod locker and return unused weld rod to the weld
rod locker.
1)
Contractors generating welding emissions in the CMSD facility must
maintain daily records and submit the records to the CMSD
CMSD Company Private. This document contains information proprietary or sensitive in nature and may be used only for
performance of related contract work. This document may not be used or reproduced for any other purpose without the specific
written permission of the CMSD ISO Representative.
Huntington Ingalls Industries Private/Proprietary Level 1
AUTHORIZED DOCUMENTS ARE PUBLISHED ONLINE ONLY.
VERIFY ANY COPY AGAINST THE ONLINE SYSTEM BEFORE USE.
DOC NO. EC-001 Rev. H
Date:3/6/2014
Page 6 of 14
Environmental Health and Safety Department no later than the 10th
of each month, for the previous month.
Note: Due to significant environmental compliance and permit constraints, Third
Party Personnel are not authorized to perform Marine Coating Applications or
welding at CMSD facility.
6.7
6.8
IDENTIFICATION AND LABELING
A.
All labels must be legible and written with permanent marker.
B.
Hazardous Material/Substance.
1)
All containers must be labeled with company name.
C.
Hazardous Waste
D.
All containers must be labeled with the following information:
1)
The words, “Hazardous Waste”
2)
The contents, composition, and physical state of the waste
3)
The hazardous properties of the waste
4)
The accumulation start date
5)
The name and address of the generator
6)
The generator’s EPA ID Number (site specific).
E.
Before transporting or offering hazardous waste for transportation, each
container must be labeled in accordance with 49 CFE172.
TRANSPORTATION
A.
Hazardous Materials/Substances- Within CMSD when transporting
paint/solvent materials containing VOCs or other chemicals from ship-tolocker/locker-to-ship or from area-to-area, all containers must have tightly
sealed lids.
B.
Hazardous waste cannot be transported back to a subcontractor’s facility
for consolidation unless all requirements under 22 CCR, Chapter 13, Article
4, have been met. This information must be submitted to CMSD
Environmental Health and Safety Department.
C.
For disposal of “Navy generated” waste, not included in contractor work
package, contact NAVFAC, SWRMC Code 106, Environmental Department,
and/or SUPSHIP Environmental.
Note: SWRMC Code 106 pickup/inspections must be coordinated with
CMSD Environmental Health & Safety and Security Departments.
D.
Motor vehicles entering or leaving CMSD must not have the potential for
contaminating air/land/water with a hazardous material/substance/waste.
CMSD Company Private. This document contains information proprietary or sensitive in nature and may be used only for
performance of related contract work. This document may not be used or reproduced for any other purpose without the specific
written permission of the CMSD ISO Representative.
Huntington Ingalls Industries Private/Proprietary Level 1
AUTHORIZED DOCUMENTS ARE PUBLISHED ONLINE ONLY.
VERIFY ANY COPY AGAINST THE ONLINE SYSTEM BEFORE USE.
DOC NO. EC-001 Rev. H
Date:3/6/2014
Page 7 of 14
Example: Loose sandblast abrasive found on equipment or truck bedcarrying equipment.
6.9
STORAGE
Unless specifically identified in the contract, no storage facilities will be provided
for ship’s force hazardous materials or waste. When storage facilities are
provided, no mixing, dispensing, using, or consolidating activities shall be
performed within the storage area.
A.
Hazardous Material/Substances
1)
Containers are placed in appropriate storage (i.e., flammable storage
cabinets, etc.) at the end of each shift.
2)
Containers must have tightly sealed lids.
Note: All hazardous materials/substances/waste used, handled, or stored
by SIMA and Third Party personnel must be stored aboard naval vessels.
B.
“Incompatible” Hazardous Materials
1)
Segregate incompatible hazardous materials by a distance of not less
than 20 feet.
2)
Isolate incompatible hazardous materials storage by a noncombustible partition extending not less than 20 inches above and to
the sides of the stored materials.
3)
Store in hazardous materials storage cabinets or gas cabinets.
Materials that are incompatible are not stored within the same
cabinet.
C.
Hazardous Waste
1)
Ship’s Force
a)
All hazardous waste must be stored in the proper designated
area, unless Environmental grants specific permission (with
SWRMC Environmental Agreement). This designated area will
be used only as a temporary lay down area prior to a
schedule pickup.
b)
If permission is granted, hazardous waste must be stored in
Department of Transportation (DOT) approved packages.
2)
Hazardous waste cannot be stored on CMSD premises for more than
90 days.
3)
Containers holding "hazardous waste" must be:
a)
In good condition - If a container is severely rusted, leaks, or
has apparent structural defects, the waste is transferred to a
container in good condition.
CMSD Company Private. This document contains information proprietary or sensitive in nature and may be used only for
performance of related contract work. This document may not be used or reproduced for any other purpose without the specific
written permission of the CMSD ISO Representative.
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DOC NO. EC-001 Rev. H
Date:3/6/2014
Page 8 of 14
b)
4)
5)
D.
6.10
Made of or lined with materials that do not react with, and are
otherwise compatible with, the hazardous waste to be stored,
so that the ability of the container to contain the waste is not
impaired.
c)
Closed during transfer or storage, unless waste is being added
or removed in addition, the container must not be opened,
handled, or stored in a manner that would rupture the
container or cause it to leak.
d)
Labeled
e)
Are inspected, at least weekly, looking for leaks and for
deterioration caused by corrosion or other factors.
“Incompatible” Hazardous Waste
a)
Incompatible waste or incompatible materials are not placed in
the same container.
b)
Hazardous waste is not placed in an unwashed container that
previously held an incompatible waste or material.
c)
A storage container holding a hazardous waste that is
incompatible with any waste or materials stored nearby in
other containers, piles and open tanks are separated from the
other materials or protected from them by means of a dike
berm, or other device.
Notify Environmental Health and Safety if you see anything that may
need to be investigated.
Flammable Storage Lockers – Ship’s Force
a)
These lockers are for storage only.
b)
All chemicals stored in the provided locker must have tightly
sealed lids.
c)
For additional information, contact SWRMC Code 106
Environmental.
CONTAINMENT REQUIREMENTS
A.
Removal Operations
1)
Most paint aboard U.S. naval vessels contains lead. Comparative
analysis has shown that airborne concentrations cannot be accurately
determined by analysis of paint chips samples. Therefore, it must be
demonstrated through bulk air samples that persons will not be
subjected to lead exposure above the action level (30ug/kg) when
performing paint removal operations.
2)
During the removal of outside deck paint, paint chips and/or dust
must be contained to prevent discharge to the bay.
3)
Use visqueen secured with duct tape, to establish adequate
CMSD Company Private. This document contains information proprietary or sensitive in nature and may be used only for
performance of related contract work. This document may not be used or reproduced for any other purpose without the specific
written permission of the CMSD ISO Representative.
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4)
5)
6.11
DOC NO. EC-001 Rev. H
Date:3/6/2014
Page 9 of 14
containment
All scuppers and/or drains located within work area are sealed.
Work areas must be swept/vacuumed at the end of each shift and
before it rains.
B.
Mixing Decking Materials
1)
Any mixing of decking materials must be in a secondary containment
with minimum of 4-inch lip guard, or equivalent containment.
2)
In addition, work areas are swept/vacuumed at the end of each shift
and/or before it rains.
Note: SIMA and Third Party are not permitted to do mixing of decking
materials on CMSD premises.
C.
Mixing or Dispensing Paint and/or Cleaning Paint Equipment
1)
The materials are mixed, dispensed or equipment cleaned in a
skidpan with a lip guard or another type of containment system,
which holds the contents of the largest container if a spill occurs.
2)
All materials are mixed away from HEAT, FLAME, and SPARKS OR
OTHER SOURCES OF IGNITION.
3)
When mixing paint, an open container is under observation at all
times and not left unattended. THIS MEANS ALL PERSONS MIXING,
DISPENSING, OR CLEANING EQUIPMENT USING PAINT MUST BE IN
THE IMMEDIATE AREA.
D.
Temporary Treatment Units (TTUs) and Holding Tanks
1)
Temporary Treatment Units (TTUs) must be managed in accordance
with 22 CCR, Division 4.5, and Chapter 45.
2)
Holding tanks must be properly bermed/diked. Visqueen and
sandbags are acceptable for short periods of time.
E.
Sandblast Abrasive
1)
Sandblast abrasive must be contained to prevent fugitive emission
from being discharged to air/land/water.
F.
Welding Slag
1)
Welding slag must be contained to prevent discharge to the Bay.
DISPOSAL GUIDELINES
A.
No Hazardous Materials/Substances/Wastes are permitted in dumpsters.
B.
Aerosol Containers
1)
Spent aerosol containers must be emptied and completely off-gassed
to atmospheric pressure prior to disposal.
2)
If nozzle is missing and/or cannot be off-gassed or it is reactive (i.e.
CMSD Company Private. This document contains information proprietary or sensitive in nature and may be used only for
performance of related contract work. This document may not be used or reproduced for any other purpose without the specific
written permission of the CMSD ISO Representative.
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DOC NO. EC-001 Rev. H
Date:3/6/2014
Page 10 of 14
where the container may explode), the can is considered “hazardous
waste.”
6.12
C.
Ablative Tile
1)
Ablative tile must be treated as “hazardous waste” until a
determination is made otherwise.
D.
Compressed Gas Cylinders
1)
Spent gas cylinders must be emptied (completely off-gassed to
atmospheric pressure) and valve stem removed prior to disposal.
2)
If the cylinder cannot be off-gassed, it must be managed as
"hazardous waste."
3)
For SUPSHIP, compressed gas cylinders are returned to the Naval
Supply Center for recycle or reuse.
E.
Cooking Grease/Grease Trap Debris – Ship’s Force
1)
Cooking grease must not be placed into CMSD dumpster.
a)
SUPSHIP Environmental has provided a collection receptacle on
each pier.
b)
Any additional questions, contact SUPSHIP Environmental
2)
No grease trap debris can be placed in any of CMSD dumpsters prior
to pickup.
a)
Grease trap debris must not contain free liquids.
b)
Any liquid residual must be absorbed with kitty litter or
absorbent floor sweeping compound.
c)
Absorbed grease residual and debris must be placed in
waterproof containers with tight fitting lids (non-leaking).
Note: If more than one ship is berthed at a pier, a disposal schedule
must be coordinated between both ships.
F.
"Empty" Containers
Containers of 5 gallons or less in capacity or inner liner removed from a
container of 5 gallons or less in capacity are considered hazardous waste until all
of the following provisions are met:
a)
The container or inner liner must be emptied and dry;
absolutely no free liquid.
Note: Containers which held a listed extremely hazardous material
must be managed as a hazardous waste.
b)
No hazardous material remains in or on the container or inner
liner that can feasibly be removed by physical methods.
c)
When deemed "empty" the container or inner liner must be
punctured and/or crushed and lids removed.
CMSD Company Private. This document contains information proprietary or sensitive in nature and may be used only for
performance of related contract work. This document may not be used or reproduced for any other purpose without the specific
written permission of the CMSD ISO Representative.
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DOC NO. EC-001 Rev. H
Date:3/6/2014
Page 11 of 14
d)
2)
The containers must be free of any flammable vapors prior to
disposal.
Containers greater than 5 gallons in capacity:
a)
Containers with a capacity of greater than 5 gallons must not
be placed in CMSD trash dumpsters.
b)
Refer to 22 CCR, Chapter 11, Section 66261.7, and/or contact
County of San Diego, Hazardous Materials Management
Division.
B.
Fiberglass, Thermo-Insulation and Calcium Silicate
1)
Materials must be double bagged prior to removal from ship and
bags taped shut (minimum thickness of bag - 6 mils).
2)
Bags can then be placed in dumpsters labeled, "LAGGING ONLY."
C.
Fluorescent Light Tubes
1)
To discard fluorescent light tubes, approval must be given by CMSD
Environmental Health and Safety Department. No fluorescent tubes
shall be allowed in CMSD trash.
2)
All lighting ballasts are considered to contain PCBs unless stamped
"Non-PCB." Only these ballasts will be allowed in the trash.
3)
If there are any questions, contact CMSD Environmental Health and
Safety Department.
4)
Fluorescent light tubes are categorized as universal waste.
D.
Medical Waste (Biohazard/Biomedical/Infectious/Solid) – Ship’s Force
1)
No contaminated dressings, needles/sharps/drugs or any materials
pretreated by autoclave are permitted in CMSD dumpster.
2)
In most cases, “Medical Solid Waste” disposal services are provided
by the contract. Notify SWRMC Code 106 Environmental to dispose
of medical waste, and to handle autoclaved or non-autoclaved
sharps.
3)
Any additional questions, contact SWRMC Code 106 Environmental.
E.
Paint Chips
1)
No paint chips are permitted in dumpsters.
2)
Paint chips are to be treated as hazardous waste until proven "non
hazardous" (TTLC Test Method).
3)
If paint chips are determined "non hazardous," a copy of the analysis
along with written authorization (site specific) from the City of San
Diego, must be provided to CMSD Environmental Health and Safety
Department.
CMSD Company Private. This document contains information proprietary or sensitive in nature and may be used only for
performance of related contract work. This document may not be used or reproduced for any other purpose without the specific
written permission of the CMSD ISO Representative.
Huntington Ingalls Industries Private/Proprietary Level 1
AUTHORIZED DOCUMENTS ARE PUBLISHED ONLINE ONLY.
VERIFY ANY COPY AGAINST THE ONLINE SYSTEM BEFORE USE.
6.13
DOC NO. EC-001 Rev. H
Date:3/6/2014
Page 12 of 14
F.
Rags and miscellaneous debris contaminated with a hazardous material
(common industrial waste oil, grease, fuel, paint, or solvent) are a
hazardous waste unless all of the following conditions are met:
1)
If the rags and/or debris:
a)
Do not exceed any criteria pursuant to 22 CCR, Chapter 11.
b)
Are not contaminated with a solvent listed as a hazardous
waste pursuant to 40 CFR 261.31
2)
The rags or debris must be dry and free of any flammable vapors
prior to disposal.
G.
Sandblast Abrasive (Copper Slag, Garnet, Glass Beads, Silica, Steel Shot,
etc.)
1)
Spent abrasive is a "Hazardous Waste" unless managed as an
"Excluded Recyclable Material" in accordance with Health and Safety
Code (25143.9. In no case shall abrasive be handled in any other
manner).
2)
Abrasive material will not be discarded into CMSD dumpsters and/or
discarded to air/land/water.
3)
Spent abrasive material must be swept up at the end of each shift
and/or before it rains, and placed into containers labeled "Excluded
Recyclable Material
H.
Wood/Scrap Metal/Cardboard
1)
Wood/scrap metal/cardboard will not be placed in CMSD trash
dumpsters.
2)
Specific dumpsters designated for recycling have been set up for
these materials.
3)
Contact CMSD Facilities Maintenance for guidance and location.
VOLATILE ORGANIC COMPOUND (VOC) CONTAINING MATERIALS
A.
APCD Rule 67.18: Marine Coating Operations/Other Non-Permitted
Applications
1)
All personnel using VOC containing material submit daily usage logs
to CMSD Environmental Health and Safety Department.
2)
The daily records include but are not limited to the type of substrate
coated (metal parts, plastic, etc.), the type of coatings applied (base
coat, hardener, thinner, cleanup, etc., including the manufacturer’s
identification number), mix ratios, volumes, volatile organic
compounds (VOC) content to each material containing VOC used,
and the name and address of subcontractors of CMSD, and VOC
emissions from the stationary source in pounds per day.
3)
Thinning of paint is not allowed.
CMSD Company Private. This document contains information proprietary or sensitive in nature and may be used only for
performance of related contract work. This document may not be used or reproduced for any other purpose without the specific
written permission of the CMSD ISO Representative.
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AUTHORIZED DOCUMENTS ARE PUBLISHED ONLINE ONLY.
VERIFY ANY COPY AGAINST THE ONLINE SYSTEM BEFORE USE.
6.14
DOC NO. EC-001 Rev. H
Date:3/6/2014
Page 13 of 14
B.
APCD Rule 67.17: Storage of Materials Containing Volatile Organic
Compounds
1)
Terms defined by APCD:
a)
“IN USE” means:
(a) being accessed, or
(b) being filled or emptied, or
(c) being cleaned, maintained or repaired.
b) “CLOSED” means:
(a) Having in place an apparatus or cover which covers the
container and which is designed to retard VOC emissions,
but not necessarily provide a vapor tight seal, and having
no visible holes, breaks, openings or separations between
adjoining components of the container or container cover.
Plastic squeeze bottles, wash bottles, spray bottles,
dispensing plunger cans and dispensers with press down
caps and/or with narrow tips constitute closed containers.
(b) “CONTAINER” means: a receptacle used for storing
volatile organic compounds included, but not limited to,
cans, drums, pails, bottles or jars. This definition does
not include drip pans or reservoirs used for collecting
cutting and lubricating oils in machining equipment.
(c) “EMPTY” means: containing no material that can be
further drained or removed by gravity (refer to Section
10.1.5).
(d) “WASTE” means: a material that is intended to be
discarded, is marked for disposal, or is no longer usable.
C.
The “standards” of storing VOC containers as defined by APCD are as
follows:
1)
All containers used to store, transfer, apply or otherwise employ
materials containing VOC are closed when not in use.
2)
All containers used to store or transfer wastes containing VOC are
closed except when being accessed or when emptied.
3)
Containers specified above may be equipped with vents, provided
such vents are necessary to comply with applicable fire and safety
codes.
4)
All Waste containing VOC (including paper or cloth impregnated with
VOC) is stored in closed containers.
LEAD IN PAINT ABOARD U.S. NAVY SHIPS
A.
Background: The shipbuilding and repairing industry has identified the
potential of lead exposure to shipyard workers as an exigent matter. This
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performance of related contract work. This document may not be used or reproduced for any other purpose without the specific
written permission of the CMSD ISO Representative.
Huntington Ingalls Industries Private/Proprietary Level 1
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DOC NO. EC-001 Rev. H
Date:3/6/2014
Page 14 of 14
issue has been brought into sharp focus by the recent actions of Federal
OSHA in promulgating the Lead Exposure in Construction; Interim Final
Rule, (29 CFR 1926.62) in May of 1993, the addition of 29 CFR 1915
Subpart Z (toxic and hazardous substances) in July of 1993, and the new
specification in U.S. Navy Ship repair contracts to sample and analyze
paints to determine if lead and other heavy metals are present. As many
marine coating systems, which have been extensively applied to ships,
contain lead or other metals as a corrosion preventive, pigment or merely a
trace contamination, full implementation of the OSHA lead standard has a
far-reaching impact on almost all shipyard production and administration
activities. Impacted activities include, but are not limited to; safety,
medical, industrial hygiene, environmental, ship fitting/pipefitting,
electrical, sheet metal, lagging, estimating/proposals and contracts.
B.
6.15
7
Comparative analysis has shown that airborne concentrations can be
accurately determined by analysis of paint chip samples. Therefore, it
must be demonstrated through bulk air samples that persons are not
subject to lead exposure above the action level (30ug/kg) when performing
paint removal operations.
1)
These factors require CMSD to perform certain identification,
evaluation and sampling procedures prior to removal of paint aboard
Navy ships. These functions are performed by the Health and Safety
Department. Only upon clearance from the Health and Safety
Department does any person proceed with production tasks that
produce fumes or particulates from painted surfaces.
INDUSTRIAL WASTE WATER DISCHARGE
A.
Continental Maritime maintains an Industrial User Discharge Permit that
specifically identifies all authorized discharges to the sewer system. For
information regarding these authorized discharges please refer to CMSDs
Industrial Waste Water Management Plan (EC-003). NO person may
discharge any industrial waste without first consulting CMSD Environmental
Health and Safety Department.
B.
No discharge to the sewer or oily waste system of any effluents generated
by SIMA or Third Party personnel or their subcontractors is authorized at
CMSD.
RECORDS AND ATTACHMENTS
7.1
The following Records are required by this instruction:
A.
None
7.2
The following Attachments are incorporated as part of this instruction:
A.
None
CMSD Company Private. This document contains information proprietary or sensitive in nature and may be used only for
performance of related contract work. This document may not be used or reproduced for any other purpose without the specific
written permission of the CMSD ISO Representative.
Huntington Ingalls Industries Private/Proprietary Level 1