NASA Ames Research Center Environmental Work Instructions ... · NASA Ames Research Center ! Environmental Work Instructions (EWI) 5-1 Hazardous Materials Management ! 1!! Responsible

NASA Ames Research Center Environmental Work Instructions (EWI) 5-1 Hazardous Materials Management

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Responsible Office: Code JQ/Environmental Management Division/Ext. 4-5602/Mail Stop 237-14 Approval Signatures Name of Approver (original signature on file)

Title of Approver Date Approved

Dr. Ann Clarke Division Chief June 20, 2011 Document History Log Status (Baseline/Revision/Cancelled)

Document Revision

Effective Date

Description

Baseline

0 June 20, 2011

Replaces APR 8800.3 Chapter 3

TABLE OF CONTENTS

Preface: P.1 Purpose P.2 Applicability P.3 Authority P.4 Applicable Documents P.5 Measurement Verification P.6 Cancellation Chapter 1: Responsibilities 1.1 Ames Research Center 1.2 Ames Hazardous Materials Users 1.3 Resident Agency Liaison, NASA Research Park Development Office, Airfield Operations, and Principal Investigators 1.4 Environmental Management Division (EMD) 1.5 Safety, Health, and Medical Services Division 1.6 Line Management and Contracting Officers Technical Representatives Chapter 2: Requirements for Hazardous Material Handlers/Users, all Hazmat Sites 2.1 General Requirements 2.2 Secondary Containment 2.3 Segregation 2.4 Labeling 2.5 Spill Cleanup, Fire Protection and Personal Protective Equipment 2.6 Inspections 2.7 Inventory Reporting 2.8 Training Requirements

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Chapter 3: Records Appendix A: Definitions Appendix B: Acronyms Appendix C: Reports Appendix D: Marking requirements and guidelines for hazardous materials and wastes Appendix E: NASA Ames Hazardous Material Management System: Frequently Asked Questions

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Preface: P.1 PURPOSE This Work Instruction sets forth procedure requirements for the environmental management of hazardous materials to ensure compliance with applicable Federal, State, and local laws, regulations and executive orders and NASA policies and procedures. P.2 APPLICABILITY a. This instruction applies to NASA Ames Research Center and component facilities for NASA civil servants, onsite support service contractors and to the extent determined by their agreements with NASA regarding their tenancy to resident agency personnel and partners. b. A requirement is identified by “shall,” a good practice by “should,” permission by “may” or “can,” expected outcome or action by “will,” and descriptive material by “is” or “are” (or another verb form of “to be”). P.3 AUTHORITY The major authorities include: a. Resource Conservation and Recovery Act (RCRA), as amended. b. Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980, as amended (42 U.S.C. 9601 et seq.), including the Superfund Amendments and Reauthorization Act of 1986 (42 U.S.C. 11001 et seq.). c. Toxic Substances Control Act (TSCA) of 1976, as amended (15 U.S.C. 2701 et seq.). c. Executive Order 12088 amended by Executive Order 12580, Federal Compliance with Pollution Control Standards. d. Executive Order 13423, Strengthening Federal Environmental, Energy, and Transportation Management, signed January 24, 2007. e. Executive Order 13514, Federal Leadership in Environmental, Energy, and Economic Performance, signed October 5, 2009. f. California Code of Regulations, Title 19, Office of Emergency Services. g. California Code of Regulations, Title 23, Water. h. California Code of Regulations, Title 26, Toxics.

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i. California Health and Safety Code, Chapter 6.95. j. Santa Clara County Code, Division B11, Chapter III, Hazardous Material Storage Ordinance. k. Santa Clara County Code, Division B11, Chapter XIV. Toxic Gas Ordinance. l. Uniform Fire Code and National Fire Protection Association Standards. P.4 APPLICABLE DOCUMENTS a. NPD 8500.1, NASA Environmental Management. b. NPR 8553.1, NASA Environmental Management System. c. APD 8500.1, Ames Environmental Policy. d. APR 8500.1, Ames Environmental Procedural Requirements. e. APR 8553.1, Ames Environmental Management System. f. NASA Strategic Sustainability Performance Plan (SSPP). P.5 MEASUREMENT/VERIFICATION a. On a three year cycle, hazardous materials management will be audited as follows. During years one and two, the Environmental Management Division (EMD) will perform an internal audit of compliance. During year three, NASA HQ will perform the audit of compliance as part of the NASA HQ Environmental Functional Review. b. Metrics will be tracked in Center Level Management Objectives (CLeMO) and Metrics and Safety and Mission Assurance Operating Agreements. Other metrics may also be tracked as required. Once per calendar year, the hazardous materials inventory is compared to the hazardous materials storage permits. An evaluation is made to verify that all facilities, including equipment, storing hazardous materials have hazardous materials storage permits and that the permits are for the correct hazard classes and quantities (storage range). P.6 CANCELLATION a. Replaces APR 8800.3 Chapter 3. Chapter 1: Responsibility 1.1 Ames Research Center 1.1.1 The Hazardous Materials Management Program at Ames is managed in the Operations Directorate with specific responsibilities assigned to the EMD.

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1.2 Ames Hazardous Materials Users Ames Hazardous Materials Users shall: 1.2.1 Conduct operations, including required inspections and maintenance of inspection logs of use and storage areas, applicable monitoring and training records, and proper labeling, in compliance with all applicable regulations, requirements, and permit terms and conditions. 1.2.2 Maintain file of Material Safety Data Sheets (MSDS) for chemicals in current inventory. 1.2.3 Maintain and make required records, e.g., inspection logs, spill logs, training records, MSDSs, available upon request to EMD RCRA Program Manager, Safety, Health, and Medical Services Division, the Fire Department, auditors, and regulatory agencies. 1.2.4 Maintain an accurate hazardous material inventory in EMD-provided chemical data management system application, including aboveground and underground tanks and all compressed gases. See Appendix E for procedures. 1.2.5 Assure data are updated in EMD-provided chemical data management system when inventory changes or storage area locations change. See Appendix E for procedures. 1.2.6 Notify EMD of intended closure of hazardous material storage areas. Thirty-day advance notice is required to allow for notification, review and possible inspection by Santa Clara County as well as to assure the inventory is updated to reflect transfer of chemicals to other user or are properly disposed of. 1.2.7 Cooperate in providing input to EMD to facilitate NASA’s timely submission of plans and reports. 1.2.8 Maintain storage areas clean of debris and free of rainwater. Designate storage areas of either hazardous materials or hazardous wastes with posted emergency signs and provide designated spill kit. 1.2.9 Provide point of contact and access to facilities for inspections, assessments, and audits by the EMD, Safety, Health, and Medical Services Division, the Fire Department, auditors, and regulatory agencies. 1.2.10 Implement corrective actions and notify supervisor of action. If the finding is listed in “Environmental Findings” at https://share.nasa.gov/teams/arc/j/jq/ems/default.aspx, request supervisor enter interim and closure actions. 1.2.11 Attend training as required. Maintain training records and provide copies upon request to the EMD, Safety, Health and Medical Services Division, the Fire Department, auditors, and regulatory agencies of any applicable non-Ames training.

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1.2.12 Comply with Toxic Substances Control Act (TSCA) requirements for making declarations when importing or exporting TSCA listed chemicals. See: http://environmentalmanagement.arc.nasa.gov “Forms” and http://environment.arc.nasa.gov “Forms”. 1.3 Resident Agency Liaison, NASA Research Park Development Office, Airfield Operations, and Principal Investigators The Resident Agency Liaison, NASA Research Park Development Office, Airfield Operations, and Principal Investigators shall assure that Resident Agencies, Partner Tenants, Airfield users, and non-NASA personnel participating in authorized activities at NASA Ames: 1.3.1 Conduct operations, including required inspections of use and storage areas, applicable monitoring and training records, and proper labeling, in compliance with all applicable regulations, requirements, agreement documents, and permit terms and conditions. 1.3.2 Maintain a file of MSDS for current hazardous material inventory. 1.3.3 Maintain and make available required records, such as inspection logs, spill logs, training records, and MSDSs, upon request to the EMD RCRA Program Manager, Safety, Health and Medical Services Division, the Fire Department, auditors, and regulatory agencies, including Santa Clara County Department of Environmental Health. 1.3.4 Maintain an accurate Hazardous Material Inventory Statement, including aboveground and underground tanks and all compressed gases, and their storage locations. 1.3.5 Submit the HMIS to the Santa Clara County, Department of Environmental Health as required by regulation, and provide a copy to the EMD RCRA Program Manager and NASA Ames Fire Department. 1.3.6 Update hazardous materials inventory when chemicals are added or removed and when storage area locations are changed or no longer used. 1.3.7 Participate and provide input to the EMD in order to complete plans and records on time. 1.3.8 Provide point of contact and access to facilities for inspections, assessments, and audits by the EMD, Safety, Health, and Medical Services Division, NASA Ames Fire Department, auditors, and regulatory agencies. 1.3.9 Implement applicable corrective actions. 1.3.10 Attend training as required. Maintain training records and provide copies upon request to the EMD, Safety, Health and Medical Services Division, the Fire Department, auditors, and regulatory agencies of any applicable non-Ames training.

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1.3.11 Inform the EMD of changes in operations, including closure, that affect storage and use of hazardous materials. 1.3.12 Maintain storage areas clean of debris and free of rainwater. Designate storage areas of either hazardous materials or hazardous wastes with posted emergency signs and provide designated spill kit. 1.3.13 Prepare and submit the Hazardous Material Business Plan (known at Ames as the Building Emergency Actions Plans (BEAP)) to the Santa Clara County Department of Environmental Health, NASA Ames Fire Department, and the EMD RCRA Program Manager. 1.3.14 Maintain permits, pay fees, and maintain records for a three-year period. 1.3.15 Close hazardous materials storage areas or equipment no longer in use. Provide closure plan to Santa Clara County Department of Environmental Health and EMD RCRA Program Manager at least 30 days prior to closure. 1.3.16 Report to EMD all releases of hazardous materials to the environment. 1.4 Environmental Management Division (EMD) Environmental Management Division (EMD) shall: 1.4.1 Designate a RCRA Program Manager and provide contact information on the EMD websites. 1.4.2 Identify hazardous material laws, regulations, Executive Orders, and NASA policies and procedures to which Ames must adhere. 1.4.3 Develop and maintain Ames hazardous material policy and procedures to implement the identified laws, regulations, Executive Orders, and NASA policies and procedures. 1.4.4 Provide hazardous material oversight and guidance. 1.4.5 Provide training to NASA personnel as required. 1.4.6 Provide technical advice, implement a cost recovery program, process fee payments, services, and support, including internal self-inspections. 1.4.7 Prepare and submit the Hazardous Material Inventory Statement, Hazardous Material Business Plan (known at Ames as Building Emergency Action Plans (BEAP)) and Closure Plans to the Santa Clara County Department of Environmental Health for NASA Ames Research Center Hazardous Materials Users, and maintain the NASA Ames BEAP webpage. See BEAP EWI. 1.4.8 Provide a web-based chemical data management system to NASA Ames chemical users.

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1.4.9 Report to the appropriate regulatory agencies all reportable releases of hazardous materials to the environment. 1.4.10 Maintain permits, implement cost recovery system, process fee payments to regulatory agencies, and maintain records according to records Chapter 3, Records. 1.4.11 Oversee closure process and prepare closure reports for hazardous materials storage areas, including hazardous material-containing equipment, no longer in use for NASA Ames Research Center Hazardous Materials Users. 1.4.12 Conduct inspections of hazardous materials storage areas with Inspector from Santa Clara County, Department of Environmental Health and serve as liaison to the County. 1.4.13 Enter findings in “Environmental Findings” tracking system. See https://share.nasa.gov/teams/arc/j/jq/ems/default.aspx, and notify responsible chemical user and division or branch chief of findings (normally by e-mail). 1.4.14 Submit design drawings to the County for new and re-modeled hazardous materials storage facilities, implement cost recovery system, process plan review fee payment, and coordinate on-site inspection with County and NASA Ames Research Center Users. 1.4.15 Provide technical information, upon request, to the Safety, Health, and Medical Services Division chemical purchaser agreement program. 1.4.16 Inform chemical users of TSCA import and export declaration requirements found at http://environment.arc.nasa.gov and http://environmentalmanagement.arc.nasa.gov. 1.4.17 Inform the local hospital (normally El Camino Hospital) of changes in the types of chemicals stored at Ames and injuries and illnesses that may result due to a release or exposure. 1.5 Safety, Health, and Medical Services Division Safety, Health, and Medical Services Division shall: 1.5.1 Prepare and distribute non-hazardous materials BEAPs, including electronic copies for inclusion on the EMD-provided BEAP webpage. 1.5.2 Inform the EMD RCRA Program Manager of any observed new, changed, or abandoned hazardous materials storage areas, including equipment containing hazardous materials (e.g. tanks, portable generators, transformers). 1.5.3 Inform potentially affected personnel and organizations of all changes in related Federal, State, and local laws, regulations, Executive Orders, and NASA policies and procedures, e.g.,

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changes in the Occupational Health and Safety Act regulations affecting hazardous materials use. 1.5.4 Implement chemical purchaser agreement program in coordination with EMD RCRA Program Manager. 1.5.5 Inform chemical purchasers of TSCA import and export declaration requirements found at http://environment.arc.nasa.gov and http://environmentalmanagement.arc.nasa.gov. 1.6 Line Management and Contracting Officers Technical Representatives Line Management and Contracting Officers Technical Representatives shall: 1.6.1 Ensure compliance with hazardous materials laws, regulations, Executive Orders, and NASA and NASA Ames policies and procedures in their area of responsibility. 1.6.2 Ensure that sufficient resources are available to achieve compliance with applicable laws, regulations, Executive Orders, and NASA and NASA Ames policies and procedures. Anticipate permit fees and costs in developing budgets and cost estimates. 1.6.3 Ensure that appropriate spill response materials and personal protective equipment are available to employees. 1.6.4 Ensure that personnel who purchase chemicals follow NASA Ames chemical purchase agreement process implemented by Safety, Health and Medical Services Division. 1.6.5 Ensure that employees receive training required to handle hazardous materials. 1.6.6 Ensure that hazardous materials management contract provisions are adequate, appropriate, and implemented. 1.6.7 Ensure that employees make necessary TSCA import and export declarations using forms available at http://environment.arc.nasa.gov and http://environmentalmanagement.arc,nasa.gov. 1.6.8 Ensure that findings and closure actions are updated in the NASA Ames Environmental Findings tracking system. 1.6.9 Ensure that records, such as inventory, spill logs, inspection logs, MSDS, and training records, are maintained and made available upon request to the EMD RCRA Program Manager, NASA Ames Fire Department, auditors, and regulatory agencies. 1.6.10 Coordinate with the EMD RCRA Program Manager for technical advice and support. Chapter 2: Requirements for Hazardous Material Handlers / Users, all Hazmat Sites 2.1 General Requirements

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2.1.1 Liquid hazardous materials must be secondarily contained to prevent leakage or spills. 2.1.2 All compressed gases must be secured with at least one (preferably two) non-combustible strap(s). All gas cylinders not in use must be stored with the valve cover in place. Store gas cylinders according to their chemical compatibility. See also Toxic Gas EWI. 2.1.3 All hazardous materials must be segregated according to hazard class to prevent inadvertent mixing of incompatible materials. 2.1.4 Hazardous materials shall not be stored in locations where they may be exposed to conditions (heat, light, air, water, etc.) that are incompatible with the material. 2.1.5 To prevent hazardous materials from accidentally reaching the sanitary sewer, hazardous materials should not be stored above sinks, next to sinks or floor drains, or in fume hoods with open sink (unless secondarily contained). 2.1.6 All hazardous materials containers, lockers, and cabinets, and piping must be properly labeled. See also Appendix E. 2.1.7 Signs identifying contact information for emergency response must be posted in hazardous material storage areas within sight of the user. Uniform signs may be obtained from EMD. 2.1.8 Appropriate spill cleanup materials and personal protective equipment must be available in areas of hazardous material storage and labeled or designated as a spill kit. 2.1.9 Hazardous materials storage areas and operations must be inspected monthly and deficiencies corrected in a timely manner. Inspections shall be recorded by using a form similar to that found in Appendix B that includes all items applicable to the particular hazardous materials storage area. 2.1.10 An MSDS must be available for each hazardous material listed in the operations’ hazardous materials inventory. Materials must be handled as described on the MSDS. For additional information on MSDS, refer to the Ames Health and Safety Manual APR 1700.1, Chapter 24, Chemical Hazard Communication Plan. 2.1.11 Each hazardous material, if present at the Center for more than 30 days must be included in the operations’ Center chemical data management system, which must be kept current. Contact EMD RCRA Program Manager for guidance. See Appendix E. 2.1.12 Releases must be cleaned up immediately by trained personnel, and all releases must be documented on a spill log. 2.1.13 Hazardous materials must not be stored in such a manner that the hazardous material could impact storm drains.

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2.1.14 Hazardous materials must not be stored on unpaved surfaces. 2.1.15 All containers storing hazardous materials must be compatible with the material stored and must be free of defects. 2.1.16 All storage areas must be free of debris and rainwater. 2.1.17 All storage areas must be labeled and secured. Information on labeling can be obtained from the EMD RCRA Program Manager. 2.1.18 Maintain appropriate fire extinguishing equipment and ensure availability. 2.2 Secondary Containment 2.2.1 Except for containers in use, all liquid hazardous materials must be secondarily contained. 2.2.2 Secondary containment must be kept dry and free of debris and defects. 2.2.3 Secondary containment must be chemically compatible with the material(s) in storage. 2.2.4 Secondary containment must be able to contain the following: 2.2.4.1 One hundred ten (110) percent of a single container’s volume. 2.2.4.2 Ten (10) percent of the aggregate volume of multiple containers or 150 percent of the largest container, whichever is greater. 2.2.4.3 Additionally, the secondary containment must be able to contain a 20-minute fire sprinkler release, if open to such a system. 2.2.4.4 Additionally, if the storage system is open to rainfall, then the secondary containment must be able to accommodate the volume of a 24-hour rainfall, as determined by 100-year storm, i.e., be another four (4) inches higher than if the secondary containment is not open to rainfall. For more information about storm water management and spill prevention, contact the NASA Ames Water Compliance Program Manager in EMD. 2.2.4.5 If the secondary containment obscures the identification of the containers inside, the containment itself must be labeled to describe its contents and their hazards. 2.3 Segregation 2.3.1 All hazardous materials must be segregated according to hazard class and compatibility to prevent hazardous reactions that result from inadvertent or accidental mixing of chemically incompatible materials. Segregation is the separation of materials through isolation or physical

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barriers. Appendix C presents a chemical compatibility matrix and procedures for use of the matrix. 2.3.2 Hazardous material and hazardous waste must be stored in separate secondary containments. 2.4 Labeling 2.4.1 All hazardous materials containers, cabinets, and associated piping (at 20-foot intervals) must be labeled with contents, including day-use or bench-top containers. Labels must indicate the name of the material spelled out in English and any hazards associated with it (e.g., “ACETONE”-“ FLAMMABLE”). The chemical formula alone is not sufficient. See also Appendix E. 2.4.2 Labels should meet the following hazard communication requirements (see APR 1700.1, Ames Health and Safety Procedural Requirements, Chapter 24, Chemical Hazard Communication Plan). See also Appendix E. 2.4.2.1 Identification of contents in container. 2.4.2.2 Identification of primary health and safety hazards. 2.4.3 If the chemical is subject to the EMD Hazardous Material Inventory Statement and Hazardous Material Business Plan: 2.4.3.1 Individual containers must be labeled with a yellow bar code from the EMD-provided hazardous material data management system. (See Appendix E.) 2.4.3.2 If the EMD chemical data management system is unavailable, containers subject to labeling must follow para. 2.4.4 until a yellow bar code can be obtained. (See Appendix E.) 2.4.3.3 Custom labels may be special ordered from commercial vendors, when necessary, if approved by the EMD RCRA Program Manager. 2.4.4 If the user is not subject to the EMD Hazardous Material Inventory Statement and Hazardous Material Business Plan, the user must label their containers as long as the label meets labeling content requirements, are durable and legible, and letters are large enough to be visible from a distance of approximately six (6) feet except for small containers (less than five gallons). Uniform marking guidelines for hazardous materials and hazardous waste have been developed by the Santa Clara County Manufacturing Group and have been adopted by Santa Clara County. These guidelines (UN-016) are included as Appendix E and can also be found at http://www.unidocs.org/hazmat/marking-labeling/un-016.pdf. 2.5 Spill Cleanup, Fire Protection, and Personal Protective Equipment (PPE)

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2.5.1 Whenever hazardous materials are used or stored, appropriate spill response equipment and fire protection equipment must be available. For example, a laboratory using acids should have an acid compatible spill kit, with acid-resistant gloves and a fire extinguisher for corrosives. In a shop where oil is used or stored, absorbent booms and floor-dry and sturdy chemical-resistant gloves should be available. Locations of hazardous material storage and spill response equipment are indicated on BEAP maps. 2.5.2 Hazardous materials spills shall be cleaned up only by personnel familiar with the hazards of the material and trained in chemical emergency response. Any spill or release of an extremely or acutely hazardous material, or any spill large enough to take two people more than 30 minutes to clean up, should be handled by the NASA Ames Fire Department. 2.5.3 The BEAP contains detailed instructions on hazardous materials spills, or other releases. Also refer to EWI on Emergency Response for spill response procedures and BEAP guidelines. 2.5.4 All spills must be recorded on a spill cleanup log posted in the vicinity of the hazardous materials storage or use area. 2.5.5 After a spill has been cleaned up, the resulting material must be managed as a hazardous waste. Complete a Form A (http://environment.arc.nasa.gov or http://environmentalmanagement.arc.nasa.gov) and contact the EMD’s Hazardous Waste group for pick-up. (Refer to EWI on Hazardous Waste Management) 2.6 Inspections 2.6.1 Unless prior approval has been given by the EMD, all hazardous materials storage areas must be inspected monthly. An Environmental Self Inspection Form can be found in the BEAP. 2.6.2 Daily inspection of aboveground storage tanks without secondary containment is required. An Environmental Self Inspection Form can be found in the BEAP. 2.6.3 Hazardous materials inspections must be documented and maintained on site according to Chapter 3, Records, but no less than three years, and made available upon request to the EMD, Safety, Health and Medical Services Division, NASA Ames Fire Department, auditors, and regulatory agencies. 2.7 Inventory Reporting 2.7.1 All hazardous materials stored on-site for more than 30 days must be included in the operations’ inventory of hazardous materials. Each year, personnel from the EMD compile and update the NASA Ames Research Center’s inventory and report it to the Santa Clara County Health Department, Hazardous Materials Compliance Division. This information is the basis for NASA Ames Research Center’s hazardous materials storage permits and fees and informs the Hazardous Material Business Plans (a.k.a. BEAP). The information in the inventory is also used to satisfy numerous other regulatory requirements.

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2.8 Training Requirements 2.8.1 All employees who use, handle, or store hazardous materials must receive training in the safe use, handling, and proper storage methods specific to the materials and hazards associated with their normal work. Employees must also receive training on how to read and understand MSDS and how to respond to a hazardous materials spill. 2.8.2 A minimum of sixteen (16) hours of training are required for employees who handle hazardous materials. This training includes a minimum of hazard communication and spill response classes as well as additional classes in hazardous materials management (e.g., Hazardous Waste, Environmental Essentials and Spill Response, Storm Water Pollution Prevention, Polychlorinated Biphenyl (PCB) Management, chemical specific training, etc.). 2.8.3 All employees are required to complete BEAP training (available in SATERN) annually, or within ninety (90) days of hire. Training must be documented and records maintained. 2.8.4 For specific training requirements and regulatory references, refer to Environmental Training Environmental Work Instruction. Class schedule information is available at http://environment.arc.nasa.gov and http://environmentalmanagement.arc.nasa.gov. Chapter 3: Records Record Name Title of

Responsible Person Retention Requirements

Location

Hazardous Materials Storage Permits

NASA Ames HazMat Program Manager

NRRS Schedule 8 23 (A11)

All chemical storage locations

Monitoring Records Chemical users NRRS Schedule 8 23 (A4)


Hazardous Material Business Plans



NASA Ames BEAP webpage

Hazardous Material Inventory Statement



Hazardous Material Inventory System and successor Hazardous Material Management System

Training Records NASA Ames Safety & Health Training Officer

NRRS Schedule 8 23 (A3a)

SATERN, ASAP

Inspection Records Chemical users NRRS Schedule 8 23 (A5)


Spill Logs Chemical users NRRS Schedule 8 23 (A5)


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APPENDIX A. DEFINITIONS A.1 Acute. A sudden event, condition, or exposure; e.g., skin burns caused by a corrosive material or death caused by inhalation of a poisonous gas. A.2 Acutely Hazardous Material. A substance that is listed on the Environmental Protection Agency (EPA) List of Extremely Hazardous Substances, 40 CFR, Part 355, Appendix A, or Santa Clara County Acutely Hazardous Materials List. A.3 Building Emergency Action Plan (BEAP). A plan required for facilities storing, handling, or dispensing hazardous materials that describes the chemicals stored and used, their locations, building hazards, escape routes, and emergency spill response procedures. A.4 Chronic. A long-term event, condition, or exposure; e.g., cancer or liver damage caused by long-term exposure to low levels of contaminants. A.5 Compatibility. The chemical characteristics of a material that determine other materials with which it may or may not be safely combined. A.6 Corrosive. Any aqueous material with a pH of less than or equal to 2.0, or greater than or equal to 12.5, or that corrodes SAE steel at a rate of 0.25 inches per year at 130ºF. Any non-aqueous material that, when mixed with an equivalent weight of water, produces a solution with a pH less than or equal to 2.0, or greater than or equal to 12.5, and that corrodes SAE steel at a rate of 0.25 inches per year at 130ºF. A.7 Day use containers. Containers that will be under the control of a knowledgeable individual at all times and all contents used before the end of a shift) need only show the chemical name (not chemical formula.) A.8 Extremely Hazardous Material. A substance or combination of substances that, if human exposure should occur, will likely result in death, disabling personal injury, or serious illness caused by the substance or combination of substances because of its quantity, concentration, or chemical characteristics. A list of these substances can be found in Appendix D (titled Reportable Quantities and Threshold Planning Quantity, 40 CFR, Part 355, Appendix A). This list of chemicals had been adopted by both the state and the county as their list of acutely hazardous or extremely hazardous materials. A.9 Hazardous Material. As defined in California Health and Safety Code, Chapter 6.95, Section 25501, any material that, because of its quantity, concentration, or physical or chemical characteristics, poses a significant present or potential hazard to human health and safety or to the environment if released into the workplace or the environment. Hazardous materials include, but are not limited to, hazardous substances, hazardous waste, and any material that a handler believes would be injurious to the health and safety of persons or harmful to the environment.

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A.10 Hazardous Materials Inventory Statement (HMIS). An annual report filed with Santa Clara County that delineates the type and quantity of hazardous material including wastes stored or handled at a particular site. A.11 Hazardous Material Storage Area. An area within or the same as a storage facility defined in the Santa Clara County HMSO as any one or combination of tanks, sumps, wet floors, waste-treatment facilities, pipes, vaults or other portable or fixed containers, used or designed to be used for the storage of hazardous materials at a facility. A.12 Ignitable. A liquid with a flashpoint of less than 60ºC (140ºF); a non-liquid capable of causing fire through friction, absorption of moisture, or spontaneous chemical changes, and, when ignited, burns vigorously and persistently; any oxidizer; and any ignitable compressed gas. A.13 Material Safety Data Sheet (MSDS). Documentation prepared by the manufacturer or distributor of a hazardous material that describes the product and its use; identifies and describes hazardous ingredients; describes the material's physical and chemical characteristics; explains any special hazards (such as fire, explosion, polymerization), health hazards, the reactivity of the product, precautions for safe handling and use, and any necessary control measures to minimize exposure. A.14 Reactive. Any material that is normally unstable and readily undergoes violent change without detonation; reacts violently with water, forms potentially explosive mixtures with water, or generates toxic gases, vapors, or fumes when mixed with water; is capable of detonation or explosion if subjected to an initiator or heat; or contains cyanide or sulfide, which generates toxic gases when exposed to pH conditions above 2.0 and below 12.5. A.15 Secondary Containment. An impermeable, chemically compatible container (e.g., bermed pad, tray, or over pack drum) that contains spills and leaks from primary containers and meets the volume requirements of Section 2.2.4. A.16 Segregation. The separation of chemically incompatible materials by physical barriers or distance. A.17 Threshold Planning Quantity. The quantity for an extremely hazardous substance as defined in 40 CFR, Part 355, Appendix A (included as Appendix D to this chapter).

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APPENDIX B. ACRONYMS APD Ames Policy Directive APR Ames Procedural Requirements ASAP Ames Safety Accountability Program BEAP Building Emergency Action Plan CAS Chemical Abstracts Service CCR Code of California Regulations CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations COTS Commercial Off-The-Shelf CY Calendar Year DOT Department of Transportation EMD Environmental Management Division E.O. Executive Order EPA Environmental Protection Agency FSM Facility Services Manager FY Fiscal Year GIS Geographic Information System HMIS Hazardous Materials Inventory Statement HMSO Hazardous Materials Storage Ordinance, Santa Clara County HSC California Health and Safety Code MSDS Material Safety Data Sheet NFPA National Fire Protection Association

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NPD NASA Policy Directive NPR NASA Procedural Requirements NRRS NASA Records Retention Schedule OSHA Occupational Safety and Health Act PCB Poly-Chlorinated Biphenyl RCRA Resource Conservation and Recovery Act SAE Society of Automotive Engineers SATERN System for Administration, Training, and Educational Resources at NASA TGO Toxic Gas Ordinance, Santa Clara County TSCA Toxic Substances Control Act USC United States Code UW Universal Waste

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APPENDIX C. REPORTS

Hazardous Materials Management Frequency: Annual Reported To: Santa Clara County Environmental Health

Department FY or CY Data CY Required By: Title 42, Section 11022 Report Due: 3/1/2011 California Health and Safety Code, Chapter

6.95, Section 25505(d) Internally Report To:

Dan Winningham Christy Ray-Hagenau

Santa Clara County Hazardous Materials Storage Ordinance Division B11, 304.02

Data Source Primary Contact Contact(s) For Past Reports

Data Required Units

Chemicals Users Various contacts based on HMIS data or other information

Christy Ray-Hagenau

Chemical data for stored chemicals

Type and quantities (lb, gal.) of chemicals used in a calendar year

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APPENDIX D. MARKING REQUIREMENTS AND GUIDELINES FOR HAZARDOUS MATERIALS AND WASTES

UN-016 - 1/8 www.unidocs.org Rev. 02/11/08

MARKING REQUIREMENTS AND GUIDELINES FOR HAZARDOUS MATERIALS AND WASTES

For Use by Unidocs Member Agencies or where approved by your Local Jurisdiction Authority Cited: California Fire Code; California Health and Safety Code (HSC); Title 22 California Code of

Regulations (CCR) Hazardous Materials Storage Ordinance (HMSO)1, Toxic Gas Ordinance (TGO)1

Copy available as: http://www.unidocs.org/hazmat/marking-labeling/un-016.pdf Also see: http://environmentalmanagement.arc.nasa.gov (internal NASA Ames) at: http://environmentalmanagement.arc.nasa.gov/reports/haz-mat-waste.html

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APPENDIX E. NASA AMES HAZARDOUS MATERIAL MANAGEMENT SYSTEM: FREQUENTLY ASKED QUESTIONS

HAZARDOUS MATERIAL MANAGEMENT SYSTEM

Frequently Asked Questions (FAQ)

1. Why is NASA Ames Environmental Management Division (EMD) upgrading from Hazardous Materials Inventory System (HMIS)? The current system, HMIS, is programmed on a platform that the Information Technology (IT) Directorate has determined is unsustainable and cannot meet the NASA IT Security Requirements.

2. How was the new system selected?

More than 40 Commercial Off-the-Shelf (COTS) systems were evaluated at NASA Dryden Flight Research Center, Marshall Space Flight Center, Goddard Space Flight Center and Ames Research Center. The Hazardous Material Management System (HMMS) was selected by these Centers for several factors:

a. The inventory process is streamlined and the data entry burden on chemical

users is significantly reduced. b. Containers are bar-coded to aid inventory tracking and reconciliation.

Transitioning to bar coding has been a Center goal since 1989. c. Database integrity is greatly improved. Data integrity is necessary for

regulatory reporting and emergency response planning. d. Reporting required by various regulations is automated. e. Hazardous material and hazardous waste data are integrated, which allows for

the retirement of the Waste Tracker system (another database requiring upgrade to a new platform due to instability of the current platform).

f. Regulatory findings and corrective action follow up requirements due to inaccurate inventories and improper labeling will be reduced.

3. What are the major changes of HMMS for the chemical users?

a. All (100%) of containers must be turned in to the EMD Hazardous Waste Team for disposal and inventory update. The list of contacts will be maintained on: http://environment.arc.nasa.gov (external) http://environmentalmanagement.arc.nasa.gov (internal).

b. EMD Hazardous Material Team will inventory and label/bar-code existing containers and new containers upon receipt or notification of receipt. Purchasers and/or users must report newly received chemicals to the EMD Hazardous Material Team for entry into the HMMS. The list of contacts will be maintained on: http://environment.arc.nasa.gov (external) and http://environmentalmanagement.arc.nasa.gov (internal) .

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c. The team will enter the data into the database and barcoding (Ames EMD personnel may go to where chemicals are located to inventory and barcode the chemicals or deliver pre-printed barcodes to the location.) Alternatively, purchasers and/or users must arrange for chemicals to be delivered to EMD in T20G, Room (will be posted at entrance to T20G), whereupon EMD personnel will enter data into inventory, barcode containers, attach Material Safety Data Sheets (MSDS), and deliver to the chemical purchaser listed on the packing slip, normally same day as receipt.

d. The EMD Hazardous Material Team will conduct inventory updates and reconciliation.

e. Users may obtain fully compliant secondary container labels and waste container labels from the EMD Hazardous Waste Team.

4. What will NOT change for the chemical user with the upgrade to HMMS?

a. Users may continue to order materials however they choose. However, users are encouraged, but not required, to establish vendors in the Logistics Division’s vendor list and purchase through Logistics.

b. Chemical purchasers must continue to complete or otherwise maintain Chemical Purchaser Agreements (managed through the Safety, Health and Medical Services Division in coordination with EMD).

c. If a new room is created or room layout is changed, the Facility Services Manager (FSM) must notify the Facilities Engineering Division to update the floor plans in the facilities Geographic Information System (GIS) and notify the EMD Building Emergency Action Plan (BEAP) lead to update the BEAP.

d. Notify EMD of any changes in location of chemicals so that EMD can update the location data in the HMMS and thus also in the associated BEAP.

e. Notify EMD of any plans to remove materials off-site so that EMD can help prepare the proper forms under the Toxic Substances Control Act (TSCA), available on the EMD website http://environmentalmanagment.arc.nasa.gov and http://environment.arc.nasa.gov, as well as make the proper notifications to the U.S. Environmental Protection Agency (EPA).

5. What chemicals must be inventoried in the HMMS?

All hazardous materials as defined in Division B11 of the Santa Clara County Hazardous Material Storage Ordinance (HMSO) Code, Chapter XIII, Article 2 are required to be inventoried. The ordinance provides exceptions for consumer retail products used as they would be by the general public – not as an occupational requirement or on an industrial scale – as well as for small quantities of janitorial or maintenance products. For specific exemptions, contact the EMD.

6. Do day-use containers require new inventory records and barcodes? No. 7. How will my existing inventory data be entered into the HMMS?

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Personnel from the EMD will be responsible for the “wall-to-wall” inventory of existing materials and ensuring complete and proper data entry. Personnel/Interns will be sent out to storage locations to conduct a pre-inventory survey. The purpose of this survey is two-fold; first, to identify material that can be disposed of (unneeded, old, past expiration date, poor label/container condition, etc.), and second, to identify the materials, manufacturers and container sizes or quantities typically used at the Center. The data from the pre-inventory survey will be used to create the Center’s catalog of chemicals, which will facilitate the inventory process. Once the catalog records are completed, personnel/interns will again visit the storage location with a laptop and portable printer to create the actual inventory records and print and affix the bar code labels to the individual containers.

8. How will updates be entered into the HMMS?

In addition to the on-going entry into inventory of new, moved, or disposed of chemicals upon notification by the user to the EMD, the EMD will be responsible for completing inventory reconciliations at least once a year. The update process will entail accessing all storage areas, scanning items with bar code labels and inventorying items without bar code labels. This process can be requested at any time.

9. What if I move a chemical?

The EMD will be responsible for maintaining the chemical inventory data. If a material is permanently moved to another location, please notify the EMD. This is especially important if a material is moved to another building. Movement of materials within a specified control area (usually defined as the building) is not normally an issue.

10. What about materials brought on site for a short period of time?

Generally, materials subject to the HMSO and stored on-site for more than thirty (30) days are required to be in the Inventory. Contact the EMD Hazardous Material Team to arrange for an inventory to be taken (similar to the procedures for entering existing materials into the system). Note requirements for import and export declarations for chemicals listed under the Toxic Substances Control Act (TSCA). See http://environment.arc.nasa.gov.

11. What about materials that are shipped to another location?

Contact the EMD Hazardous Material Team to arrange for the inventory to be updated. Note requirements for import and export declarations for chemicals listed under the Toxic Substances Control Act (TSCA). See http://environment.arc.nasa.gov.

12. What about the annual requirement to update my chemical inventory?

Once your operations are transferred over to the new system, the EMD will be responsible for maintaining the chemical inventory data and will continue to submit

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required inventory reports to the various regulatory agencies as well as coordinate with Santa Clara County for the annual inspections.

13. How can I access my chemical inventory?

Users can request an inventory report at any time from the EMD. Additionally, users will still have the ability to view and print an inventory list.

14. How can I access MSDSs?

This new system will augment, not replace, the current MSDS management processes. ChemWatch will still be available for on-line access to certain MSDSs. Hard or soft copies of MSDSs for any material in the HMMS can be requested from the EMD.

15. Can the system provide secondary container labels?

Yes. You can request secondary container labels from the EMD for any material in your inventory. These labels will meet all requirements for OSHA and Santa Clara County. They need only show the chemical name (not chemical formula) and the primary hazard of the material. Day use containers (containers that will be under the control of a knowledgeable individual at all times and all contents used before the end of a shift) need only show the chemical name (not chemical formula).

16. What if the container is too small for the bar code or secondary label?

In those rare instances when the container is too small for the yellow bar code label or a secondary container label, the EMD will consult with the user to find a workable solution. It may require that the containers be stored in a rack or bag that bears the full label or for an inventory sheet displaying the bar code labels to be posted nearby.

17. What if I mix two materials together and create a new one?

These situations can be handled in one of two ways; the new material is considered either a product or a waste. If it is a waste, it should be labeled as a waste and picked up for disposal within the correct time frame (fifty (50) days for normal accumulation areas and two hundred seventy (270) days for Satellite Accumulation Areas). If it is a material, it should be labeled as a secondary container showing at least the chemical name (not the chemical formula) and the primary hazard. These new materials do NOT need to be entered into the HMMS provided that the source materials are. This applies to mixtures and dilutions. Please note that if the new material is going to be shipped off-site or “offered in commerce,” users will need to work with the Safety Division to develop an MSDS for the material.

18. How can I request waste containers?

As is currently done, you may contact the EMD Hazardous Waste Team by phone at

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4-2613 or FAX a Form A (ARC 749) to 4-2612 and request containers for your waste. Include funding information. An estimate may be requested. These containers can be pre-labeled and dated or they can be blank. The EMD Hazardous Waste Team has developed waste profiles for users and operations to facilitate fully compliant hazardous waste labels. Users are responsible for filling out and affixing the proper hazardous waste labels to blank containers.

19. Can I still get empty containers and create my own waste labels?

Yes. While it is preferable to request pre-labeled waste container, EMD is aware that not all waste generation can be planned. The Hazardous Waste Team will still pick up properly labeled and containerized waste and enter the required information into the integrated system.

20. How can I request a waste pick up?

The Hazardous Waste Technicians in the EMD Hazardous Waste Team can be contacted at the following numbers: Phone: 4-2613 FAX: 4-2612 Please note that under this new system, the EMD is requiring 100 % turn in of all empty hazardous material containers. Also, pre-labeled containers will have a date on them when they are delivered. To ensure compliance with Hazardous Waste Regulations, containers will be automatically scheduled for pick-up within the appropriate time frame for the specified waste area (fifty (50) days for regular storage areas, two hundred seventy (270) days for satellite accumulation areas).

21. What will happen if I do not turn in an empty material container?

The container will be identified as missing during a comprehensive inventory update conducted by the EMD. EMD will need to determine if it is more likely than not that the material was used and the container properly disposed of as solid waste or if the material was moved to another location. The EMD will update the system accordingly.

22. What will happen if I cannot find a waste container?

First, all efforts will be made to find the container. EMD will track the container until such a time that EMD can determine that the container is not present on the Center (after the annual complete Center-wide inventory). Then EMD will update the HMMS to reflect the loss. The RCRA program will be reviewed to see if improvements can be made to ensure additional losses do not occur in the future as the RCRA program is a cradle-to-grave program.

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