Encl. (4) TO COMDTINST 16478.12
REMEDIAL ACTION PLAN
BATTERY CLEANUP SITE OPERATIONS
MATERIAL HANDLING, SEGREGATION,
PACKAGING AND DISPOSAL
A.
SCOPE AND RATIONAL
A.1 Coast Guard units that are assigned to remove batteries from ATON sites
must follow this protocol to ensure that batteries are handled properly.
Proper handling will ensure that personnel safety, environmental safety and
regulatory compliance are accomplished. Handling of batteries will be
conducted in a uniform manner under a standard operating procedure (SOP).
Since differences in site conditions will dictate the site specific approach to
be taken, there must be flexibility to the site operations plans.
A.2 Survey, remove and dispose of abandoned aids to navigation (ATON)
batteries. The driving force behind the battery cleanup operations is the
perception that the batteries are causing harm to the environment, and
therefore the Coast Guard is causing environmental harm. The disposal of
batteries in the coastal environment is an illegal activity, and because the
batteries do not decompose it appears that the Coast Guard is engaged in
illegal action.
A.3 Recovery of spent batteries at ATON sites is a current obligation of the
ANT teams. The recovery of discarded batteries is also a logical extension of
ANT duties. The ANT teams are trained in the handling of live batteries (which
are potentially more hazardous than the spent or discarded batteries). With
additional training the ANT's will be able to safely, legally and successfully
acomplish this mission.
B.
INITIAL SITE RECONNAISSANCE
B.1 Upon arrival at the site take a few minutes to orient yourself and get a
feel for the lay of the land. Using a standard Site Plan 1" = 20', draw in the
relative position of the shoreline and the position of the aid.
B.2 All members of recovery team meet to determine who will go where and
where the stage-out area will be set up along with position of safety
equipment, "tailgate site safety plan" will be developed. Search zones will be
established.
B.3 Personal protective equipment (tyveks and boots) is donned, pH paper, a
Site Plan 1" = 20' and a supply of flags taken into the search zone.
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