Attachment 3: Drum Handling and Storage Procedures

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Attachment 2: Safe Work Practices for Lifting/Handling Batteries

Attachment 4: Work Plan Modifications

National Plan for Aton Battery Recovery and Disposal - index
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133

Encl. (4) TO COMDTINST 16478.12

First CG District ATON Battery Recovery Site Safety Plan

ATTACHMENT (3):

DRUM HANDLING AND STORAGE PROCEDURES PAGE 1

Detailed regulations regarding drum handling and spill containment can be found

at 29 CFR 1910.120(j)

Handling Drums.

Drums shall be inspected and given a unique identification prior to

Movement of drums must be kept to a minimum.

To the greatest extent possible, drums shall not be moved by unaided

manual methods.

Safe manual lifting procedures for batteries are provided as attachment 2.

Prior to shipment, each drum must be in good condition (or over-

packed) and properly

labeled in accordance with 49 CFR requirements.

A log shall be maintained to keep track of sampling, re-packing/over-

bulking/consolidation, on-site movement, off-site shipment, and any other

significant events related to each individual drum.

F.

Bulking or product consolidation is allowed only after individual

product contents have been characterized.

II.

Staging and containment areas.

A.

Pathways for hazardous substance dispersion: __Pathways are depicted

on the sitesafety plan provided as attachment 1.

B.

When drums are moved from their original locations to a work area or

staging area, a spill containment must be addressed. The containment

should be able to contain the maximum loss from any of the containers

in the area.

C.

Safe access and egress points must be provided to all staging areas.

Adequate room and ramps must be provided for equipment used to handle

drums.

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