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EMS

Hazardous Waste Management Program

Hazardous Waste
Management Program

Program Manager Contact Information:
Hazardous Waste Management
Program Manager  |  252-466-4951

Flammable Warning Sign
Program Overview        
 

The intent of the Hazardous Waste Management Program (HWMP) is to ensure the proper classification, handling, storage, and disposal of hazardous waste (HW) generated at Marine Corps Air Station (MCAS) Cherry Point, including the outlying areas. Requirements governing the generation and management of HW are found in the Resource Conservation and Recovery Act (RCRA) regulations codified under Title 40 of the Code of Federal Regulations (CFR). Hazardous waste is generated and managed in various areas throughout the Air Station and at the outlying fields. The proper management of the HW generated at MCAS Cherry Point consists of “cradle-to-grave” tracking of the HW from the generator, through storage, treatment, and ultimate disposal. The program also involves performing inspections at HW management sites, providing training to unit-level personnel to ensure the waste streams they are generating are being managed properly, and periodic HW program and permit reviews.

It is Marine Corps’ policy to reduce the quantity of HW disposal through prioritizing source reduction (for processes and products that generate HW), re-use of hazardous materials when and where possible, recycling, and lastly, off-site treatment and off-site disposal. The highest priority is placed on source reduction and recycling. The long-term Marine Corps goal is to achieve continuous reduction of HW generation through pollution prevention initiatives, Best Management Practices, and Best Demonstrated Available Technology.

Environmental Requirements        
 

Marine Corps policy requires that all Marine Corps installations and activities comply with all applicable environmental requirements, which may include Federal, state, local, Department of Defense (DoD), Department of the Navy (DON), Marine Corps, and MCAS Cherry Point rules, regulations, and requirements. Legal and other environmental requirements related to the HWMP are maintained on the EM Portal.

Programs, Plans, Resources and Responsibilities        
 

A complete description of the responsibilities of the HWMP can be reviewed on the EM Portal. Major components of the HWMP include:

  • Implementation of RCRA Subtitle “C” requirements and the RCRA Part B Permit

  • Maintenance of the Hazardous Waste Management Plan

  • Maintenance of the Waste Analysis Plan (WAP)

  • Ensuring that generators are able to properly identify, characterize, and store HW, as well as ensuring proper manifesting of HW (details are available on the EM Portal)

RCRA Part B Permit Maintenance and Compliance

MCAS Cherry Point has a RCRA Part B Permit for two permitted storage facilities. Outlying fields are not covered under the permit but are covered under the Air Station’s orders and the Hazardous Waste Management Plan. Detailed HW reporting and recordkeeping requirements are maintained on the EM Portal.

Hazardous Waste Management Plan

This plan provides the Hazardous Waste Program Manager and the Environmental Protection Specialists with day-to-day hazardous waste management guidance and instructions and must be updated to reflect current installation and tenant organization responsibilities, current practices, and regulatory requirements. The plan is currently being rewritten to incorporate new changes implemented by the state. The plan must also be signed by the Commanding Officer and distributed to all personnel who are affected by the requirements of the plan. The plan is saved electronically on the EM Portal.

Waste Analysis Plan

As MCAS Cherry Point has permitted hazardous waste storage areas, a WAP is required under Federal regulations (40 CFR 270.14(b)(2) and (3)). The WAP provides guidance to successfully implement a hazardous waste sampling and analytical management program capable of ensuring regulatory compliance with permit conditions and state and Federal regulations.

Training and Communication        
 

All designated hazardous waste management personnel must receive formal classroom training prior to assignment and within 364 calendar days of their original training date. No employee hired to handle HW at the Air Station will perform any HW related tasks unsupervised prior to completion of the training program. In addition, on an annual basis, all HW handlers and managers must receive annual refresher training. Additional training requirements are documented on the EM Portal.

Practice-Aspect-Impact Risk        
 

The risk of negative environmental impacts from MCAS Cherry Point operations may be assessed by analyzing the practices that occur at the facility. Aspects are the characteristics of these practices that can cause an impact to the environment or other resource. It is Marine Corps policy that all Marine Corps installations identify and assess the environmental risk of the practices and aspects associated with each environmental program. Significant practices and/or aspects associated with this program include:

  • Aircraft maintenance

  • HW storage (<90 day site)

  • Unexploded Ordnance (UXO)/Explosive Ordnance Disposal (EOD)

  • HW satellite accumulation area

  • Battery management

  • Boat operation/maintenance

  • Open burning/open detonation

  • PCB management

  • HW transportation

Objectives, Targets and Actions to Improve Performance        
 

Objectives and targets (O&T) related to the HWMP and their associated actions to improve performance are maintained on the EM Portal. One O&T is currently developed:

Objective: Implement waste prevention and recycling measures and comply with all federal and state requirements regarding solid, hazardous, and toxic waste management and disposal.

Target: Develop and distribute waste management posters as a waste management reduction campaign for education and outreach to all facilities and homes aboard the installation.

Audit and Evaluation of Compliance        
 

Extensive details on HW inspection and compliance are maintained on the EM Portal.

The HWMP is evaluated under each annual internal Environmental Compliance Evaluation (ECE) and each triennial Benchmark ECE. Findings and corrective actions from these audits are maintained on the EM Portal.

 

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Marine Corps Air Station Cherry Point