Results from a recently released Environmental Protection Agency inspection of NAS Patuxent River indicated multiple areas requiring continued vigilance. The inspection assessed the station's and tenants' overall compliance in managing hazardous materials, hazardous waste, storage tanks, storm water and sanitary wastewater systems.
NAS Patuxent River Naval Facilities Command, or NAVFAC, staff and attorneys cooperated with the EPA to identify discrepancies and create plans of action to improve the installation's processes. On a positive note, it is evident that organizational managers and coordinators are following the notification, response and reporting procedures for installation oil and hazardous substance spills.
NAS Pax River's very name identifies the environmentally important position it holds as an eco-funnel point for major bodies of water on the eastern seaboard. The EPA and Maryland's Department of the Environment are agencies that help us protect the Chesapeake Bay, Patuxent River and all navigable waters associated with the NAS Patuxent River complex. These agencies foster environmental compliance through inspections and, like NAS Pax River's leadership, they want everyone to adhere to rules and regulations.
Everyone at Pax River who uses hazardous materials or generates hazardous waste must be vigilant to know and execute their duties in accordance with local base instructions. Hazardous material usage is governed by NASPAXRIVINST 4010.5B, and the Hazardous Waste instruction is NASPAXRIVINST 5090.5.
NAVFAC organizes the efforts of 65 Environmental Coordinators who manage waste sites across the NAS Pax River complex, and there are a number of Pax River personnel who manage HAZMAT and HAZWASTE for their organizations in full-time positions while others perform this work on a collateral-duty basis. However, in the arena of hazardous materials, it is the responsibility of all hands to maintain an environmental compass that promotes regulatory compliance.
Are some people becoming complacent in their use of HAZMAT? Are lock out/tag outs on fueling equipment performed 100 percent of the time? What would you say to someone who had walked away from a lab bench, leaving hazardous waste unattended and open to the environment?
Over the past few months reports of petroleum-based fuel and oil discharges to the environment have increased. Although a few of these releases have resulted from equipment failure, too many have been caused by human error. For example, it may be an improperly positioned switch, an uncapped drain port or loose fuel/oil line during maintenance actions, with subsequent work performed that leads to fuel/oil discharges.
Time is critical at the onset of a release, and established procedures must immediately be set in motion to prevent a minor spill from becoming a major environmental concern. The value of a well informed and qualified organizational spill response team cannot be overstated.
Regulators may come aboard the station any time they choose and perform inspections that represent a snapshot of the installation and tenant organizational procedures. Environmental agency representatives are evaluating our management practices and our attentiveness in maintenance and HAZMAT handling.
For more information, call the Regulated Waste Program Manager at 301-995-3627 or the Spills Program Manager at 301-342-1817.