Hazardous Waste Management


Documents

Please see the Environmental Documents page for program-specific environmental documents and work instructions.


Background


The Resource Conservation and Recovery Act (RCRA) is the principal federal legislation governing the management of solid and hazardous waste. The U.S. Environmental Protection Agency (EPA) has established regulations under RCRA which govern hazardous waste (HW) generation, storage, transportation, and disposal. EPA has designated the Alabama Department of Environmental Management (ADEM) authority to administer and enforce RCRA in Alabama.

Army Regulation 200-1 (Chapter 10) implements HW requirements and provides installation personnel with procedures and responsibilities to manage HW consistent with federal, state, and local laws and regulations. Fort Novosel's Hazardous Waste Management Plan (administered by the DPW Environmental and Natural Resources Division) provides even more specific guidance for those handling HW.


Waste Generation


The primary missions of Fort Novosel are pilot training, aircraft maintenance, and air traffic control training with emphasis on rotary-wing aircraft. HW is generated and managed at numerous locations on Fort Novosel properties. This HW is primarily the result of maintenance of Army equipment and property, expired shelf-life hazardous materials, and medical service support activities. Fort Novosel also generates various types of special waste, in addition to HW, during normal operations and other activities and must dispose of such materials. This includes used oil and universal waste (UW) batteries, pesticides, mercury-containing equipment, lamps and aerosol cans (see Universal Waste Management program page).

Fort Novosel is considered a large quantity generator (i.e. generates greater than 1000 kg or 2,200 pounds per month) of HW, and submits a HW report every other year to the state of Alabama and the EPA. Cairns Army Airfield is not contiguous to the main Fort Novosel property and is a large quantity generator with a separate EPA ID number. Shell Army Heliport is also not contiguous to the main Fort Novosel property and is a small quantity generator with a separate EPA ID number.


Waste Accumulation and Turn-In 


As a designated large quantity generator, Fort Novosel is allowed to accumulate HW for up to 90 days on-site. Fort Novosel operates two main 90-day hazardous waste central accumulation areas (90-HWCAA), as well as four other interim 90-day storage sites around the installation. Additionally, Fort Novosel operates a 180-day HWCAA at Shell Army Heliport that is managed as a 90-HWCAA. Fort Novosel also has numerous hazardous waste satellite accumulation areas (HWSAA) and universal waste accumulation sites around the installation.

Containers of waste accumulated in an HWSAA must meet the following conditions:

·              Located at or near the point of generation

·              Under the control of the operator

·              Compatible with the contained waste 

·              Maintained in good condition (no dents, corrosion, leaks, noticeable spills, bulging, or excessive rust)

·              Kept closed unless actively adding or removing waste

·              Labeled with the words "HAZARDOUS WASTE", the EPA ID number, and the type of waste being accumulated

·              Transfer to a 90-HWCAA within 3 days of meeting the accumulation threshold (55-gallons for HW or 1 quart for acutely HW)

HW must be turned in to a 90-HWCAA using a DD Form 1348-1A. Detailed information about waste turn in is found in ENV-SW001, Waste Turn-In Procedure. HW that is accumulated in a 90-HWCAA is managed in accordance with applicable regulations and the requirements in the HWMP.


Hazardous Waste Management Plan (HWMP)


Fort Novosel's HWMP is a comprehensive document covering all installation operations involving HW, including all activities and tenants that generate, temporarily store, transport, and turn-in for disposal regulated and hazardous waste. The requirements of this document are applicable to all military and civilian personnel at Fort Novosel, including commanders and directors.

The HWMP discusses procedures that ensure each step in the "cradle-to-grave" management of hazardous wastes is carried out in a consistent manner and in accordance with all regulatory requirements.  

The HWMP is posted on the Environmental Documents page, along with current copies of the work instructions referenced and incorporated.


Hazardous Waste Training


Please review the HWMP and the USAACE Form 2735, Hazardous Waste Job Description and Training Record to read more about HW training required for all personnel who are involved in any aspect of HW generation or handling. THIS TRAINING IS MANDATORY IN ORDER TO COMPLY WITH ALL APPLICABLE LAWS AND REGULATIONS! A variety of HW training is provided on a quarterly basis through DPW-ENRD. The Defense Hazardous Materials / Waste Handling Course (DHMWHC), provided annually, is required for 90-Day HWCAA managers and recommended for other HM/HW handlers.

For More Information


For more information about HW or UW procedures, contact your organization's Environmental Officer or the DPW-ENRD Hazardous Waste program manager (334-255-0487).