Environmental Standard Operating Procedure Originating Office: MCAS Yuma Environmental Department
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1 Environmental Standard Operating Procedure Originating Office: MCAS Yuma Environmental Department Revision: Draft Supersedes: n/a Prepared By: EM-Assist, Inc. Approved By: File Name: BRR-ESOP Effective Date: Document Owner: Title: Brake Replacement 1.0 PURPOSE The purpose of this Environmental Standard Operating Procedure (ESOP) is to provide guidelines for managing brake replacement operations and maintenance (O&M) activities. 2.0 APPLICATION This guidance applies to those individuals who perform brake replacement O&M aboard Marine Corps Air Station (MCAS) Yuma. 3.0 PROCEDURE 3.1 Discussion: Brake replacement O&M requires checking asbestos brake pads for periodic wear and tear, cleaning dust from brakes, and performing brake replacement. Brake O&M utilizes hazardous materials such as asbestos containing brake pads, brake cleaner and brake fluid. Replacement activities generate hazardous waste such as asbestos containing brake pads, asbestos contaminated rags, and waste fluids, which must be managed properly to avoid impacts to human health and the environment. All hazardous materials must be stored in approved containers. Units are equipped with approved containers and 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 (MSDS) for all hazardous materials associated with this practice are current available for inspection. 2. Ensure that all required permits are current and available for inspection. 3. Maintain current technical orders, rebuilding instructions and maintenance manuals in a designated location. 4. Ensure that training records and certifications are current and available for inspection. 5. Ensure that turnover folder or desktop procedures is kept for this practice. For Government Use Only. Page 1 of 6
2 6. Wear appropriate personal protective equipment (PPE) including eye protection, face shields, gloves, aprons, steel-toed boots, respirators and bump hats as necessary. 7. Maintain a fully stocked spill kit and a fire extinguisher nearby in designated locations. 8. Conduct maintenance as recommended by manufacturer and retain maintenance records including maintenance cycles on electronic database 9. Store all usable hazardous materials in the hazardous materials (HAZMAT) locker. 10. Do not use compressed air to clean dust from brakes and assemblies. 11. Place drip pans underneath wheel assembly and master cylinder when working on brake assemblies. 12. Properly seal all waste asbestos containing material (ACM) in approved ACM bags or containers and label with approved warning signs. 13. Maintain a waste log that includes container type (e.g., ACM, aerosol cans, etc.), accumulation start date, accumulation end date, and dates containers are taken to the 90 day storage area. 14. Report all spills immediately to supervisor and the Environmental Department. 15. Ensure that a spill report is submitted to the Environmental Department detailing the spill date, time, product spilled, quantity, location, cleanup actions taken, name of the person reporting the spill, etc. 16. Place used rags in approved foreign object and debris (FOD) buckets for recycling or disposal. Have used rag containers picked up by contractor and obtain an empty container. 17. Conduct daily inspections of storage areas and secondary containment. Maintain all inspection records in record jackets for at least six months, with the office of the Collateral Duty Inspector (CDI) and Production Control (PC). 18. Ensure that warning signs, such as No Smoking and Flammable Materials are clearly visible from a distance of 25 in any direction. 19. If there are any specific situations or other concerns not addressed by this procedure, contact the Environmental Department. 3.3 Documentation and Record Keeping: The following records must be maintained: 1. MSDSs for all materials associated with this practice. 2. Required permits. 3. Operation and maintenance manuals. For Government Use Only. Page 2 of 6
3 4. Technical Orders. 5. Training records and certifications for personnel. 6. Hazardous materials inventory (must match Authorized Usage List). 7. Hazardous waste log. 8. Scheduled maintenance log. 9. Brake log (brake test results for ACM). 10. Quality Procedure Local (QPL). 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. 3. Standard operating procedure incorporating QPL. 4. First Responder Awareness (FRA) training. 5. Ground support equipment school. 6. Preventative Maintenance. 7. 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 Arizona Department of Environmental Quality Hazardous Waste Permit MCO P4790.2C (Marine Corps Order) MCO P5090.2A MCO P5100.8F Quality Procedure Local (MCAS Yuma Quality Assurance Department) Hazardous Waste Management Plan (HWMP) For Government Use Only. Page 3 of 6
4 Date: Installation: Inspector s Name: Brake Replacement Inspection Checklist Time: Work Center: Signature: Inspection Items Yes No Comments 1. Are MSDSs current and available for inspection? (29 CFR 1910, MCO P5100.8F) 2. Are all required permits current and available for inspection? (ADEQ Permit, MCO P5090.2A) 3. Are current technical orders, rebuilding instructions and maintenance manuals maintained in a designated location? 4. Are required current training records and certifications maintained at training department for all personnel? (22 CCR 66265, MCO P5090.2A) 5. Is turnover folder or desktop procedure kept for this practice? (MCO P4790.2C) 6. Is appropriate PPE worn as necessary? (29 CFR 1910, MCO P5100.8F)) 7. Are fire extinguishers and spill kits maintained nearby in designated locations known to unit personnel? (29 CFR 1910, MCO P5100.8F) 8. Is periodic maintenance conducted as recommended by the manufacturer and maintenance records kept? 9. Are all usable hazardous materials (dry solvent, brake fluid) stored in the hazardous materials (HAZMAT) locker? 10. Is compressed air used to clean dust from brakes and brakes assemblies? (29 CFR 1910, MCO P5090.2A) 11. Are drip pans placed underneath wheel assembly and master cylinder when working on these parts? (40 CFR 262, MCO P5100.8F) 12. Are sufficient amounts of absorbent material (clay) maintained to absorb any leaks or spills? (40 CFR 262, HWMP) 13. Is all waste ACM properly sealed in approved ACM bags or containers and labeled with approved For Government Use Only. Page 4 of 6
5 Inspection Items Yes No Comments warning signs? (40 CFR 262) 14. Is a waste log maintained that includes container type, accumulation start and end dates, and date taken to 90 day storage area? (40 CFR 262, MCO P5090.2A) 15. Are all spills reported to the supervisor and the Environmental Department? (MCO P5090.2A, HWMP) 16. Is a spill report submitted to the Environmental Department detailing the spill date, time, product spilled, quantity, location, cleanup actions taken, and name of the person reporting the spill? (MCO P5090.2A, HWMP) 17. Are used rags placed in approved FOD buckets for recycling or disposal? 18. Are daily inspections of storage areas and secondary containment conducted? Are all inspection records maintained in record jackets for at least six months with the office of the CDI and PC? 19. Are warning signs, such as No Smoking and Flammable Materials clearly visible and legible from a distance of 25 in any direction? (40 CFR 265) 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
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