ATTACHMENT 2_2020 Contrator Guide_N4523A21Q5731_37 pgs.pdf

Attachment 2

Contractor Guide to Environmental and Safety

Compliance

Puget Sound Naval Shipyard &

Intermediate Maintenance Facility

Bremerton, Washington

The Contractor’s Guide to Environmental and Safety Compliance at Puget Sound

Naval Shipyard & Intermediate Maintenance Facility (PSNS&IMF) Controlled Industrial Area

(CIA) and Naval Station Bremerton, herein referred to as the Bremerton Naval Complex (BNC), is designed to meet the environmental and safety, basic information needs of contractors working at the BNC or one of the BNC managed properties. This is also a useful tool for other personnel

(e.g., contracting office representatives (CORs) and design managers) who will very likely find themselves confronted with environmental or safety issues.

This guide is intended as a “primer” for environmental and safety guidance on BNC policies and procedures within the fence line of the Controlled Industrial Area and a few outlying areas that are under PSNS&IMF Environmental, Safety, and Health (Code 106) oversight. It is structured around frequently asked questions addressing each media (e.g., air, water, waste, safety etc.) and issues you need to know about. This guide offers the level of detail needed for basic knowledge of key environmental and safety issues

In emergency situations, if the COR is not available, call the BNC’s designated point of contact using the telephone numbers provided in this pamphlet. These individuals may provide information but are NOT AUTHORIZED to provide direction to contractors that may be outside of the scope of work.

Disclaimer: Each contractor is responsible for compliance with all contractual requirements, including compliance with all applicable federal, state, and local environmental requirements, as well as Bremerton Naval Complex environmental requirements as specified in the contract. This document is provided for general awareness only. It remains the contractor’s duty to comply with all applicable laws, and this guide alone cannot assure such compliance. To the extent the requirements of this document are in direct conflict with the contract specifications, the issue should be discussed with the COR in order to avoid violating relevant environmental laws.

This document provides regulatory information in good faith but makes no representation as to its comprehensiveness or accuracy, it does not authorize any change in the terms, conditions, delivery schedule, price or amount of any government contract. In the event that these requirements could represent a change for which an equitable adjustment is required, contractors should advise the COR of the particular technical or contractual requirements regarded as changed, and take no action with regard to such changed requirements until notified, in writing, from the proper government representative.

This document is intended only as a guide toward compliance by a properly trained person. Individuals receiving this information must exercise their independent judgment in determining its appropriateness for a particular purpose. PSNS & IMF MAKES NO

REPRESENTATIONS OR WARRANTIES, EITHER EXPRESSED OR IMPLIED,

INCLUDING WITHOUT LIMITATION ANY WARRANTIES OF

MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE WITH RESPECT

TO THE INFORMATION SET FORTH HEREIN OR FOR WHICH THE

INFORMATION REFERS. ACCORDINGLY, PSNS & IMF WILL NOT BE

RESPONSIBLE FOR ANY DAMAGES RESULTING FROM USE OF OR RELIANCE

UPON THIS INFORMATION.

ABOUT THIS GUIDE

SAFETY AND HEALTH

General ................................................................................................................................................. Page 1

Fire ....................................................................................................................................................... Page 3

Traffic ..................................................................................................................................................... Page 4

Energy .................................................................................................................................................. Page 5

ENVIRONMENTAL

Introduction ........................................................................................................................................... Page 6

Spills ...................................................................................................................................................... Page 7

Air ........................................................................................................................................................ Page 9

Asbestos .............................................................................................................................................. Page 11

Polychlorinated Biphenyls ................................................................................................................. Page 13

Excavation ........................................................................................................................................... Page 14

Water .................................................................................................................................................. Page 17

Cultural Resources ............................................................................................................................. Page 21

WASTE

Hazardous Material and Waste ............................................................................................................ Page 23

Waste Management Plan ..................................................................................................................... Page 25

Solid Waste ......................................................................................................................................... Page 27

Hazardous Waste ................................................................................................................................. Page 28

Recycling Hazardous Waste ................................................................................................................ Page 29

Disposing of Waste ............................................................................................................................. Page 30

Storage................................................................................................................................................. Page 31

TELEPHONE LIST ....................................................................................................................................... Page 37

TABLE OF CONTENTS

POLICY: It is Navy policy to provide a safe and healthful workplace for all personnel. Horseplay, drinking alcoholic beverages, and using illegal drugs are not permitted on government property.

Failure to follow these rules will result in removal of the person(s) involved from PSNS & IMF and NBK.

There are many potential hazards in any large industrial complex. Do not be caught off guard. Familiarize yourself with the location of exits, internal evacuation routes, alarm signals, and work that is going on around you. Stay alert to your surroundings at all times. Report fire and medical emergencies immediately. For prompt medical treatment and ambulance, transport to local area hospitals; dial 911 from a Bremerton Naval Complex (BNC) phone or from a dial phone 360-

476-3333.

Accidents incurred by contractors or visitors shall be reported immediately to the BNC

Police Department (360-476-3333) and contractors to their COR. If the COR is not available, reporting shall be made to BNC Police Department.

All work requiring the obstruction or closing of streets and/or pedestrian walkways must be cleared in advance through the COR assigned to the contract, who will need to obtain concurrence from the affected PSNS & IMF departments, such as Security and Production.

Barricades, warning tape, or danger tape, when necessary, are the contractor’s responsibility, maintained for the duration, and removed upon completion of project.

Contractors are responsible to ensure that their employees and contract work areas continuously comply with applicable OSHA regulations, except in instances where appropriate

DOD and NAVY standards apply as specified by the contract.

PERSONAL PROTECTIVE EQUIPMENT: Safety glasses, hard hats and safety-toed shoes are required for entry into dry docks, on piers, and in all posted areas where eye, head, and foot hazards are present. Personnel engaged in hazardous operations while working in shops, ships, barges, docks, material lay down areas, and piers shall wear personal protective equipment appropriate to ensure protection from the hazards.

Hearing protection is required in all posted noise hazardous areas. Additionally, it is good practice to use hearing protection, if you must raise your voice to be heard.

PPE is not required if you stay within the designated travel routes in shops, on sidewalks, on streets, on piers, or similar routes. However, PPE should be carried when in the CIA or where hazards may be encountered.

The head of the sponsoring shop, code, or tenant activity shall ensure that all visitors whose business requires them to enter posted hazardous work areas use the appropriate personal protective equipment (PPE).

General Safety and Health

HOUSEKEEPING AND SANITATION: The work site will be kept clean. All debris, scrap material, tools, and equipment will be cleared from the work site as work progresses and at the end of each shift. DO NOT take hard hats, dirty coveralls, or tools into designated food and beverage consumption areas. Some areas have racks for your convenience. Wash hands before eating, drinking, smoking, or applying cosmetics for good industrial hygiene.

TOBACCO: Use is allowed in designated areas only. Designated tobacco use areas must be posted with a designated area sign. Designated tobacco use areas (DTUAs) must be a minimum distance of 50 feet from sidewalks, passageways, building doorways, open windows, intake ventilation air ducts, and eating areas. Each DTUA must contain an adequate number of tobacco waste receptacles.

SCAFFOLDS: Will be built of sound material and properly supported on a firm footing. A scaffolding platform must be equipped with a standard 42-inch high handrail, a middle rail, and a

4-inch toe board and ladders between levels. Scaffolding will be tied to adjacent walls. Scaffolding is not to exceed 30 feet horizontally and 26 feet vertically.

CONFINED SPACE: This means any space having a limited means of egress, which is subject to the accumulation of toxic or flammable contaminants or an oxygen-deficient atmosphere. A few examples of a confined space are: fuel tanks, boilers, voids, sewers, and utility tunnels. It is the responsibility of contractors to be aware of the requirements for working in, on or adjacent to confined spaces and to be aware of all work operations occurring in the space to ensure conflicting operations do not occur. Additionally, ensure non-conflicting certificates for shared worksites.

SECURITY: Never attempt to enter the CIA without an approved badge for the shipyard. This is required even when under escort. Do not take cameras/camera cell phones, portable computer drives, or recording devices in to the CIA. It is important to address any questions or concerns regarding security through your COR. Do not attempt to go into places not authorized for your work or visit. Also, do not attempt to go into an area with a higher security level than your badge authorizes unless PSNS Security has approved a special security plan via your sponsor. Be mindful that U.S. Navy Security Forces provide routine patrols, and shipyard security personnel conduct checks to ensure compliance with security protocols. Any government employee may also potentially address you regarding any perceived security concerns.

At times, United States Marine Corps Security Force is at PSNS & IMF to assist in providing security. They are specifically trained for the protection and security of special material, and under certain conditions, are authorized by the Commander, PSNS & IMF, to use deadly force in the performance of their duties. Should you enter an area guarded by Marines, you are likely to be challenged. This procedure is used to determine the identity, temperament and intent of any person in or near a Marine Sentry's area of control. When a sentry is unable to determine the identity and/or authority for the presence of a person within their area, the person will be challenged and identified. If a Marine challenges you, do exactly as instructed, even if you do not agree. To ensure your safety, don't walk away or ignore a sentry after being challenged. Do as the sentry directs and express your concerns after the fact. If you feel a sentry has mistreated you, or has incorrectly performed his duties, notify Code 1121.2 at 476-2841.

If Smoke or Fire is detected call 360-476-3333 or 911

PROCEDURES FOR RECOGNIZING AND REPORTING UNSAFE CONDITIONS:

Reporting unsafe conditions: Contract employees should contact their direct supervisor and their COR.

ALARM AND EVACUATION PROCEDURES:

Fire Alarms: in office buildings and shop areas will be a loud pulsating buzzing. Fire Alarms should be sounded continuously for 15 to 30 seconds, this pattern should continue for at least three minutes. All personnel must respond appropriately when an alarm sounds. Some building do not have fire alarms and alternate arrangements have been made. During construction these alarms may be disabled. Have a plan and brief your new employees.

Evacuation Routes: Primary and Secondary Escape routes are posted in common areas of all permanent buildings. It is each person’s responsibility to review the routes and know the best way out in the event of an evacuation. Contractors need to discuss primary and secondary escape routes as well as the official mustering location with their employees on a routine basis.

Alarm Response: Any person hearing an alarm in a building should take the following actions:

Pass the word (e.g., fire … fire…. fire) to warn others.

Evacuate the building as expeditiously as possible. Do not use the elevators.

o Help any personnel who may be in need.

If time permits, close doors and windows to confine the fire and secure classified material.

Do not endanger yourself or others in this effort.

Procedures to Account for all Personnel after an Evacuation:

All personnel shall muster in a predetermined location to ensure that everyone has been evacuated and all are accounted for. Contractors are responsible for communicating the predetermined mustering location to their employees.

FIRE

PEDESTRIANS and MOTOR Vehicles There shall be NO vehicular travel within the CIA between the 1602 and 1609 whistles.

Only bus and emergency vehicle travel is allowed during this time to facilitate ~6,000 personnel embarking. Motor vehicles shall be operated as per Washington State Law. Motor vehicles shall yield the right of way to trains, cranes, and material-handling equipment at all times. Within the

CIA, all contractor vehicles shall be identified with the company name.

SPEED LIMITS

(a) 5 mph on all piers, wharves, dry dock access routes, and other hazardous areas, such as building or ground construction sites, track repair areas, and heavy pedestrian movement within and outside the CIA.

(b) 10 mph on other streets within the CIA, unless otherwise posted.

(c) 20 mph on Farragut Avenue only, unless otherwise posted due to construction, obstruction, or detours.

(d) 20 mph in the community and non-industrial areas outside the CIA, unless otherwise posted.

(e) 10 mph is the speed limit for forklifts on Farragut (7 mph if on shoulder of Farragut to allow traffic to pass).

CRANES Contractors and visitors to PSNS & IMF at BNC and NAVBASE Kitsap may encounter cranes of various sizes, types, and purposes. Cranes that may be encountered range from air and electrically powered hoists found mounted inside shops and buildings, bridge cranes found in the overheads of the large shops, mobile cranes, floating cranes and large portal cranes which operate on rail systems throughout the shipyard. NAVY cranes are to be operated only by trained and qualified NAVY personnel.

A crane team directs all Navy-owned mobile, bridge, floating, and portal cranes at PSNS

& IMF. A Rigger in Charge, identified by a blue reflective vest and a yellow hard hat with Code

740 on both sides, leads these crane teams. Additionally, portal cranes are assigned a crane walker, identified by the same yellow Code 740 hard hat and an orange reflective vest. This crane team ensures that all crane operations are conducted safely, and that the crane, load, and personnel within the crane’s operating envelope are safe. Any instruction given by a Code 740 Crane Team member regarding the crane or the operating envelope around it shall be adhered to immediately.

Yellow lines painted on each side of each rail identify crane tracks and locomotive tracks, nothing should be stored (gear, tools, equipment, etc...) within 6 inches of either side of these lines.

Vehicles shall never park on the crane or locomotive rails or within the yellow lines encompassing the rails. This creates a collision hazard and can cause delays to crane and locomotive movement throughout the BNC.

It is PSNS & IMF policy to minimize vehicular traffic on piers and dry dock areas. During crane operations no vehicles will be allowed in the pier and dry dock areas. If contractors need track closures or vehicular access thru these areas contact your COR to work with the Naval Base

Kitsap Excavation Coordinator, N444.53 at 476-9455. PSNS & IMF Code 980.5 coordinates outages within the CIA, <BREM.PSNS.Outages.FCT@navy.mil>.

TRAFFIC

ENERGY

Control of Hazardous Energy (Commonly referred to as Lock-Out-Tag-Out)

Before an employee performs any servicing or maintenance on a system where the unexpected energizing, start up or release of stored energy could occur and cause injury or damage, the system shall be isolated.

Personnel and resources shall not be considered protected until hazardous energy control procedures have been performed.

Need for Coordination

Coordination is critical to servicing machinery, equipment, and systems in shipyard employment. In shipyards, employees face numerous issues that can complicate servicing operations, such as:

Large and complex machinery, equipment, and systems.

Machinery, equipment, and systems that have multiple power sources, isolation points and types of energy.

Difficulty identifying all energy sources due to complex and/or outdated engineering drawings and schematics.

Requirements

All hazardous energy control activities shall be coordinated with and approved by the shipyard designated authority.

When contractors use their company’s energy control procedures, they shall submit their hazardous energy control plan detailing the applicable procedures required for the job to the shipyard designated authority for acceptance.

Shipyard and contractor designated authorities shall fully coordinate their energy control activities with one another. Each shall inform the other of their approved energy control procedures and ensure that all employees understand and comply with rules and restriction of the procedures affecting their work before work can begin.

The U.S. Navy must be well prepared for their national defense mission and, at the same time, operate in an environmentally responsible manner. An important part of the BNC’s mission is to prevent pollution and protect the environment. To fulfill this mission, you (as a Navy-employed contractor) must also possess the personal commitment to the Navy’s environmental protection ethic.

Environmental protection standards and compliance monitoring are very strict at a nuclear shipyard operating adjacent to a city center and unique based on past agreements with various community groups, regulatory agencies, local, state, and tribal governments. The BNC operates under separate permits for air emissions, industrial wastewater discharges to the sanitary sewer, and discharges to Sinclair Inlet via storm drains or dry dock outfalls. Specific to hazardous waste, the BNC operates as a fully-regulated large quantity generator. The BNC, upon an Agreed Order with Washington Department of Ecology, has more stringent requirements than other facilities. These more stringent requirements are found in the areas of training and accumulation for waste management. Compliance with environmental regulations and BNC rules requires specialized knowledge or expertise. The BNC’s environmental staff will provide you, upon request and through this guide, information which will help you understand your responsibilities towards environmental compliance.

COMPLIANCE

“Environmental Compliance” is conformance to the many environmental regulations and BNC requirements. These regulations and requirements can vary with the different regulated media (e.g., air, water, waste) depending on your project status. For example, your project could be in compliance with water quality regulations but out of compliance with hazardous waste regulations.

WHY COMPLIANCE IS IMPORTANT

While your project may extend across several individual aspects of the BNC’s and

Navy’s mission, there is one area that is impacted by virtually every one of your actions and operations: the environment. The Secretary of the Navy’s policy is to fully comply with all applicable Federal, State, local laws and regulations; and Executive Orders. In order for you to comply, you must have a solid understanding of the local, state and federal regulations and the procedures set forth in the BNC’s Environmental Program to comply with the regulations.

Environmental compliance, although it may be more costly initially, is a responsibility you must plan for and accept as a cost of doing business with the BNC and the Navy. Non-compliance is far more costly in the long run, not only in dollars, but in bad publicity which can affect future jobs and relations in the community. It may also affect your ability to perform future work for the Navy.

Proper environmental coordination with operations at the BNC, or any of the BNC-owned properties, is not only needed for compliance reasons, it also benefits your project by preventing time delays or operational shutdowns and improves public relations. To this end, you must take a proactive approach to your policies, procedures, and operations.

Bottom line: Have an environmental plan, execute the plan and monitor the plan.

ENVIRONMENTAL INTRODUCTION

The Clean Water Act (CWA) addresses improvement of the nation’s water resources, and deals with the prevention of, and response to, Oil and Hazardous Substance (OHS) spills. The

CWA prohibits OHS discharges in quantities that are determined to be harmful to the public health or the environment. The Oil Pollution Act of 1990 (OPA 90) amended the CWA to strengthen the response and enforcement authority of the federal government, and outlines additional prevention and preparedness measures for both government and industry. In the BNC, not only must adequate spill prevention measures be employed to prevent any discharge of an oil or hazardous substance into the environment, but proper spill response actions must be taken to prevent spills from reaching navigable waters.

A Spill Event is a release involving any unauthorized spilling, leaking, pumping, emitting, emptying, discharging, injecting, escaping, leaching, disposing, or dumping of oil or hazardous substance. There are two types of spill events in the BNC: a non-emergency and an emergency spill event.

Quick Tip: When in Doubt . . . Call it out!

Call 911 from a BNC “land-line” telephone or cellular telephone Call: 360-476-3333.

Do not call the Safety Hotline!

NON-EMERGENCY SPILL EVENT

Definition: A discharge of a known material or hazardous substance of ten gallons or less that can be cleaned up by the personnel who discovered the spill and does not pose an immediate threat to human health or the environment. In a non-emergency spill event, the spill material is not released into any waterway inlet (e.g., storm drain) or outside the BNC fence line.

Actions Required in a Non-Emergency Spill Event:

Stop the source of the spill.

Contain the spilled material by keeping the spill away from drains or waterways by blocking off drains located near the spill if there is a chance that the spill will reach them.

Clean up the spilled material wearing the proper personal protective equipment.

Dispose of the spill debris per designation by Code 106.33. See Waste Management Plan section.

EMERGENCY SPILL EVENT

Definition: Any release of a known or unknown material or hazardous substance which poses an immediate threat to human health or the environment and is not classified as a non-emergency spill event. In these situations, the individual which discovers the spilled material may require assistance from the government. All unpermitted or uncontrolled releases, greater than ten gallons if on land, or any amount to any waterways, or outside BNC properties, are classified as emergency spill events.

SPILLS

Actions Required in an Emergency Spill Event:

If you don’t know the properties of the material or it is a threat to human health, evacuate the area and go upwind.

Warn others in the area and direct them upwind.

Ask someone to watch the area and to warn others away.

Call the Regional Dispatch Center (RDC) by dialing “911” from a BNC telephone (for cellular telephones, call 360-476-3333), and provide the requested information.

Return to the spill site and stand by for emergency response personnel.

Maintaining a safe distance, try to stop the source of the spill or contain it to prevent it from going into drains or waterways.

If you have Safety Data Sheets (SDSs) for the spilled material, provide them to the emergency response personnel.

To ensure protection of Washington waters, land, air, and natural resources from the impacts of Oil and Hazardous Substance (OHS) spills, you must operate in a manner which will provide the best achievable protection of public health and the environment. The

“Stormwater and Wastewater Management and How to Comply” section provides guidance on

Water Pollution Prevention Practices to prevent unauthorized discharges to the storm drains and sanitary sewer systems. Implementing the spill prevention procedures outlined in the following paragraphs will help reduce the risk of a spill occurring, and protect the area if one does occur.

All OHS Handling and Transfer Equipment shall be inspected prior to use and during intervals of the operation to ensure equipment is in proper working condition. All connections and transfer points shall be carefully checked prior to, during, and after transfer operations to monitor for leaks. Hose connections shall be wrapped and/or containment placed under them.

The OHS Storage Areas: Locate all containers with a storage capacity of 55 gallons or greater used to store oil and hazardous substances in an impermeable secondary containment which is capable of containing 100 percent of the largest container in the containment or 10 percent of the total volume of all containers whichever is greater. If secondary containments are not protected from rain, provide additional capacity for 5 inches of rain. Hazardous waste containers may have more stringent requirements.

A Spill Response Kit shall be placed at or near any OHS handling and transferring work sites. The kit needs to contain items appropriate for the cleanup of the type of spill that could occur from your project.

Some contracts may have the following requirements: Storage and refilling practices shall comply with 40 CFR Part 112. Secondary containment shall be provided and be no less than

110 percent of the tank volume plus five inches of free-board.

REQUIRED TRAINING

Washington Department of Ecology (WDOE) requires that all personnel involved in oil handling operations must be certified. Certification is accomplished by successful completion of a training course in Oil Spill Prevention and Response. This training promotes job competency and environmental awareness. Key supervisory and operations personnel must maintain certification that meets the requirements of Washington Administrative Code (WAC) 173-180C.

WHAT IS AIR POLLUTION?

Air pollution is the presence of one or more air contaminants in sufficient quantities and of such characteristics and duration as is, or is likely to be, injurious to human health, plant or animal life, or property or which unreasonably interferes with enjoyment of life and property.

The Puget Sound Clean Air Agency (PSCAA) is the local regulatory agency responsible for air pollution control, including all asbestos, demolition, and renovation work. They conduct job site compliance inspections at the BNC on a regular basis.

HOW DO I CONTROL AIR POLLUTION?

Fugitive Air Emissions

PSCAA requires the use of Best Available Control Technology (BACT) to control fugitive emissions. Fugitive emissions are those emissions (e.g., dust, mist, vapors, fumes) not caught by a capture system. Depending on the project, BACT can be as simple as a light water spray or as complex as a Class I containment. Some examples include:

Perform spray painting operations inside a spray enclosure equipped with an overspray emission collection device. If you are working outdoors, reasonable methods to confine overspray shall be used, such as tarps, shrink wrap, mobile enclosures, or similar methods.

Keep containers of paints or solvents closed unless they are being used.

Control dust from construction, road travel, demolition projects, sanding, grinding, concrete work, abrasive blasting, and clean-up work with a BACT such as water spray (if water spray is used, ensure wastewater generated is captured for disposal and not running off into storm drains).

Quick Tip: Keep your equipment and logs in good order.

Non-road Engines

Non-road engines are non-rolling stock engines and engines that don’t move while in use but are still portable. Portable engines that will remain at a project for 12 months or longer are considered stationary. Examples of which engines are included as non-road engines are listed below.

Included

- Portable generators

- Portable welders with engines

- Engine driven HP water sprayers

- Engine driven pumps, compressors and vacuums

- Emergency Diesel Generator (EDG)

Not Included

- Motor vehicles

- Self-propelled cranes

- String trimmers

AIR

Contractors must notify and coordinate with C/106.31 via their COR when an engine is required for a project prior to bringing it on site. Notifications are required to be filed with the

PSCAA when the cumulative size of non-road engine utilized by a project exceeds 50 HP, and at

2000 HP PSCAA must issue a written approval for non-road engine use (which can take 10 days).

Quick Tip: A man-made outage is NOT an “emergency” and must receive an engine permit.

PERMITS FOR AIR POLLUTION

Asbestos

PSCAA requires the submission of a Notice of Intent (NOI) for removals of 10 linear or

48 square feet of friable asbestos material and demolition projects with a roof area greater than

120 square feet. Receipt of the processed notification with PSCAA's case number and review signature and a C/106.31 or NBK Environmental (for NBK facilities) approved asbestos work plan are needed prior to the start of work.

Equipment Installation

A Notice of Construction (NOC) is required for the installation of new equipment which has the potential for creating air pollution.

New types of air polluting equipment operated at PSNS & IMF must either use existing permits to operate or go through air permitting process, which can take up to 2 years to complete.

There are a variety of permits for commonly used blast equipment but if there is a chance that the contract may require special equipment, early correspondence with C/ 106.31 and the

Contracting Officer is essential, particularly in the case of large non-road engines (local power source). If you require either a stationary or non-road engine for a period of 12 months or longer, make sure to notify your COR.

REFRIGERANT/OZONE DEPLETING SUBSTANCE (ODS) PROHIBITIONS

Class I and II ODS in pure or blended form should not be used, nor be provided as part of the equipment except for the use of servicing existing government owned equipment.

Class I and II ODS substances are defined in 40 CFR Part 82. These generally consist of products such as refrigerants that contain Chlorofluorocarbons (CFC), or fire extinguishing agents such as Halons. If you need assistance in determining if your products are Class I or

II ODS, or the contract specifies use of a Class I or II ODS, contact your Contracting

Officer.

Class I ODS and R22 must be turned into the government for recycling. Contact your

Contracting Officer for guidance on turn in procedures. Expect to provide cylinders for material storage if necessary. At the end of work, the contractor must provide details of maintenance and leak discoveries, full charge for the system, date and amount of refrigerant added, date and results of initial verification test, and date and results of follow-up verification test. Provide the required data to your COR so they can turn over required submittals to the PSNS&IMF Air, Asbestos & PCB Branch (Code 106.31).

ASBESTOS

BEFORE YOU GET STARTED

If you have not already done so, obtain an Asbestos Survey or Encountered Waste

Summary of the building, structure, or vessel that your work will be impacting. The BNC has completed asbestos surveys for many of its structures and these may be available for your use. If not, a survey must be performed by a building inspector who is trained per the requirements of

40 CFR 763.86 of the Asbestos Hazard Emergency Response Act (AHERA). A summary of the results of the asbestos survey must either be posted at the work site, or communicated in writing to all persons who may come into contact with the material. However, no asbestos survey is needed if the material is assumed to be Asbestos Containing Material (ACM) as you can almost always worst case the waste and work with asbestos controls.

The contractor will need to provide an Asbestos Abatement Plan in accordance with EM

385-1-1 06.C.03. The Asbestos Abatement Plan must include specific details of the planned asbestos removal activities, including but not limited to:

A description of each activity where ACM will be disturbed, including the OSHA class of work;

A description of the regulated area(s), types of containment, decontamination plan, and engineering controls;

Air monitoring plan for personal, environmental, and clearance monitoring;

Personal protective equipment, including respirators and protective clothing;

Housekeeping procedures to address the prevention and spread of contamination beyond the regulated area(s);

Hygiene facilities and practices;

Copies of employee certification/accreditation for the Competent Person and employees performing asbestos work;

Waste generation, containerization, transportation and disposal.

NOTIFICATION OF INTENT

If friable ACM is to be removed, the contractor must submit a Notification of Intent

(NOI) for asbestos removal to PSCAA at least ten days prior to the start of work. Be aware that the PSCAA definition of friable ACM is more restrictive than federal and state regulations.

PSCAA defines friable ACM as: asbestos containing material that, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure or by the forces expected to act upon the material in the course of demolition, renovation, or disposal. Such materials include, but are not limited to, thermal system insulation, surfacing material, and cement asbestos products.

All demolitions that make a structure permanently uninhabitable or unusable require a demolition NOI, whether or not asbestos is present in the structure. The PSCAA Demolition

NOI must be submitted at least ten days prior to starting work for any demolition which includes removing a load bearing member. “Load bearing members” are items like the foundation, a structural beam or wall, or structural roof components.

Provide a copy of the PSCAA approved notification(s) to your Contracting Officer prior to starting work. Your approved notification (“permit” to disturb or remove asbestos, or perform a demolition) must be in-hand prior to starting work. Copies of the NOI(s) and asbestos survey must be available at the work site for the duration of asbestos abatement and/or demolition work.

Quick Tip: PSCAA requires that an asbestos survey be performed and a demolition notification be submitted for all building demolitions WHETHER OR NOT THE

ASBESTOS SURVEY INDICATES THAT ASBESTOS IS PRESENT IN THE

BUILDING.

The government is responsible to identify all asbestos which will be removed or is likely to be disturbed. Contractors are responsible to ensure their employees and cognizant work areas are in compliance with the applicable OSHA and PSCAA regulations when working an Asbestos

Project. PSCAA defines an Asbestos Project as any activity involving the abatement, renovation, demolition, removal, salvage, clean up, or disposal of friable ACM.

Quick Tip: Contractor employees performing work on an Asbestos Project must be trained and certified per the 40 CFR 763 Subpart E Appendix C.

ASBESTOS WASTE

PSCAA requires that Asbestos Containing Waste Material (ACWM) be deposited within

10 days of removal at a waste disposal site authorized to accept such waste. If ACWM is to be stored beyond 10 days, a Temporary Storage Site must be established and registered with

PSCAA. If a Temporary Storage Site is used, PSCAA requires that the storage, transportation, disposal, and return of the waste shipment record to the waste generator not exceed 90 days.

Asbestos waste must be transported by a hauler who is licensed to do so, and disposed at a landfill permitted to receive asbestos waste. The disposal facility must be approved by the

Contracting Officer, and copies of all Asbestos Waste Shipment Records must be provided to the

Contracting Officer showing that the ACWM was delivered to the approved facility within the time limits specified above.

POLYCHLORINATED BIPHENYLS

Since 1979, the Environmental Protection Agency has regulated the use, storage, disposal, and distribution in commerce of PCBs. The law for PCBs is the Toxic Substance

Control Act (TSCA).

Light ballasts may or may not contain PCB. If they are not marked "No PCB" then they are assumed to contain greater than 50 parts per million (ppm) PCB and are fully regulated under the TSCA.

If ballasts are marked “No PCB” Washington State regulates as if there is 2 ppm or greater PCBs. The BNC no longer has transformers containing greater than 50 ppm PCB;

however, some do contain less than that amount. All transformers should be labeled identifying their PCB content. Discarded transformers, capacitors, or bushings containing PCB’s at concentrations of 2 ppm or greater (except when drained of all free-flowing liquid) are regulated in this State as dangerous waste. Fluid, core, and core papers from these specific sources are also regulated in this State as a dangerous waste when generated from the salvaging, rebuilding, or discarding of transformers, capacitors, or bushings.

Depending on the contract specifications, the contractor or the Shipyard will take samples of materials that have shown in the past to contain PCBs above the regulatory limit of 50 ppm.

Once the analytical from these samples is available, a plan should be developed which includes how to manage and dispose of the waste. Be sure to submit a Waste Information Sheet with Code

106.33 for designation of your waste. See the Waste Management Plan section. Responsibilities for disposal should be specified in the contract. The process for the management, transport, and disposal of PCBs is similar to dangerous waste (e.g., accumulation requirements, time limits, and manifests). Turn in PCB waste to Shop 99HM by end of shift. PCB waste storage areas are not allowed unless approved by the PCB Program Manager.

EXCAVATION

The BNC was established over 100 years ago. Practices that were considered acceptable in the past have been changed with regulations. Several sites in the BNC have been designated for the Installation Restoration (IR) Program, similar to the Superfund Cleanup Programs part of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).

While it is always possible to uncover unexpected items during any earth moving or excavation project, you need to be especially aware of this possibility working at the BNC IR sites. The

BNC has twelve IR sites within the fence line. The Bremerton Excavation Management Plan

(EMP) describes in detail the IR Sites, the contaminants at each site, and how to manage waste at each of the sites. An excavation permit is required prior to starting any digging work. The excavation permit process can be found in Section 4 of the Bremerton EMP. In addition, if an excavation is planned within an IR Site, the pavement or “cap” must be restored to prior to better condition to ensure compliance with CERCLA requirements. Information on the BNC Superfund

CERCLA sites has been placed in the local libraries and at NAVFAC Northwest offices for public review. The information in the library is under the name Puget Sound Naval Shipyard.

Contact your Contracting Officer to confirm if your work area is within one of these sites.

EXCAVATION

Take measures to preserve the work area’s natural resources. Protect existing trees which are to remain, and be sure to not injure, bruise, deface or otherwise damage during contractor operations. Confine your construction activities to within the limits of your work site.

Restore to an equivalent or improved condition when the job is completed. Do not cut, deface, injure or destroy trees or shrubs without the Contracting Officer and Naval Base

Kitsap Environmental’s permission. Furthermore, unless you have permission, do not fasten or attach ropes, cables, or guys to existing heavy trees for anchorage. Be advised that if damage occurs where you have had approval to attach these items, you could be charged for repairs.

Upon the Contracting Officer and Naval Base Kitsap Environmental’s approval, remove and replace trees and other landscape features scarred or damaged by equipment operations. Removal of rocks and trees should be coordinated through Naval Base Kitsap

Environmental office.

During excavation or any digging or trenching operations, inspect the work site for obvious signs of contamination (e.g., cement asbestos pipe, insulation, cans, drums, stained soil, or strong odors). Telephone in obvious signs of contamination immediately to the RDC at 911 from a BNC telephone, from a cellular telephone dial: 360-476-3333. Report it as a spill to the RDC operator, and then notify your Contracting Officer. If you are uncertain, or for questionable items or signs of contamination, immediately notify your Contracting Officer.

Quick Tip: KEEP YOUR EYES OPEN!!

There are areas of high archeological potential. Check with your Contracting

Officer to see if you are working in one of these areas. If you find historical or archaeological items or human skeletal remains in the course of your digging, STOP

WORK in the immediate area of the discovery, until directed by the Contracting Officer to resume excavating.

SOIL CONTROL AND MANAGEMENT

You need to know if your work will take place in an IR site potentially contaminated with lead, asbestos, PCB’s, and other toxic materials. This knowledge serves two purposes, one is for health and safety reasons, the other is for determining possible options for excess soil. How much soil will be reused at the same site is also important to plan for. Dispose of the soil per designation by Code 106.33. See Waste Management Plan section. Regardless of where soil is being excavated the following guidance applies unless otherwise approved by the COR.

Additional information about soil reuse and management can be found in the Bremerton

Excavation Management Plan.

If soil is reusable at the same work site: Accumulate reusable soil within the same area as the excavation from which it was removed, preferably as near to the excavation as practicable.

Create a storage area in the following manner:

Underlay the soil accumulation area with a continuous impervious sheet of plastic.

Protect the plastic from perforation during loading and handling operations. The thickness of the plastic shall be sufficient to contain the soil, and in no case be less than ten mil. Thicker or reinforced plastic, or other measures, to protect the integrity of the plastic underlayment may be required if there is danger that the plastic will be punctured or torn during soil accumulation. If it is necessary to join two or more sheets of plastic to cover the pile, all seams shall be welded, heat sealed, or taped continuously on both sides of the sheet.

Install a berm around the pile so that soil remains in the designated area. The edges of the underlayment must be laid over the top of the berm and secured to prevent water from running under the soil pile.

Secure the top cover sheet to ensure that wind will not balloon the cover or blow it aside leaving the soil exposed to weather.

Keep the soil pile covered and secured at all times except when actually adding or removing soil or taking samples.

There must be an ID label on stockpiled soil containers (or the tarp covering it) identifying the waste/soil as "Soil, Non-Hazardous".

If soil is not reusable at the same work site: Sometimes, soil may not be reusable due to compaction, excavation needs or other reasons. If this is the case, check with your Contracting

Officer to see if it can be used somewhere else at the BNC. If soils are removed from an IR Site, the soil must be tested and disposed of according to local, state, and federal regulations. This soil cannot be reused anywhere at BNC. If soils are removed from areas other than IR Sites, the soil may require testing, depending on where the soil came from and where it will be placed. If not eligible for relocation, then it is waste soil and must be designated for disposal; Sampling for testing prior to excavation is highly recommended. It eliminates the guesswork and the contractor can arrange for the proper disposal site before they excavate. Dispose of the soil per designation by Code 106.33. See Waste Management Plan section. Due to limited storage space at the BNC, it can make the project run smoother when you can direct-load for disposal off-site.

However, before the contractor can sample, they must submit a Sampling and Analysis

Plan to the COR for approval by Code 106.33. Once approved, these tests, at minimum, must be performed:

A Toxicity Characteristic Leaching Procedure (TCLP) metals test (includes arsenic, barium, cadmium, chromium, lead, mercury, selenium and silver) will tell you the levels of heavy metals in the soil.

A Total Metals test for Copper, Nickel and Zinc.

If the presence of petroleum or the type of petroleum is unknown, request the Washington

Total Petroleum Hydrocarbon Identification (WTPH-HCID).

AND

After detecting hydrocarbons through a WPTH-HCID test or knowing the type of petroleum hydrocarbon present, request the specific test method for that type of petroleum

(e.g., gasoline, diesel, or 418.1 modified) to tell you the level of contamination that is there.

Potential Additional Tests: If the soil is in an area, where there is a possibility that PCBs are present in some degree, test for PCBs including Aroclor 1268. Other contaminants are also possible in an IR site, so check with your Contracting Officer. There has been extensive studies and sampling to determine the constituents of concern in each IR site, which is documented in the Bremerton EMP.

All of this and more will be taught during Site Specific training (HW49). Request this class through your Contracting Officer. Class is typically held the third Thursday of each month.

WATER

The goal of the Clean Water Act (CWA) is to “restore and maintain the chemical, physical, and biological integrity of the Nation’s waters.” The two crucial programs regarding the BNC’s CWA compliance are the National Pollutant Discharge Elimination System

(NPDES) Permit and the State Waste Discharge Permit.

The NPDES Permit controls discharges going directly into surface waters, such as

Sinclair Inlet. Specific discharges from the BNC into Sinclair Inlet that are authorized and limited by the BNC’s NPDES permit include: non-contact cooling water, ground water, steam condensate, air-conditioning condensate, potable water and stormwater runoff.

The State Waste Discharge Permit Program regulates industrial wastewater discharges into the sanitary sewer. Wastewaters from industry, households, and commercial establishments combine and flow to a sewage treatment plant (owned and operated by the City of Bremerton).

At the plant, the wastewaters are treated and discharged into surface water (e.g., Sinclair Inlet).

Industrial discharges from the BNC into the sanitary sewer are specifically regulated by the

BNC’s State Waste Discharge Permit, which prohibits the introduction of any pollutants into the sanitary sewer system that would interfere with the operation of Bremerton’s Wastewater

Treatment Plant, or cause the city to violate its NPDES Permit by allowing the pollutants to pass through untreated. Examples of prohibited discharges include all hazardous materials or wastes, oils, solvents, etc. All industrial wastewaters that are not permitted to be discharged into Sinclair

Inlet or the sanitary sewer system must be disposed of in accordance the Waste Management

Plan section.

Quick Tip: Get approval, VIA the C/106 Storm Drain and Sanitary Sewer Discharge

Request form or the Waste Information Sheet per the Waste Management Plan section, before discharging any water anywhere! In general, Storm Drain and Sanitary Sewer

Discharge Request form is only used for very clean water that is not contaminated with any products/chemicals and not…