Atch 06 - FA2523-09-R-0001 CEV-15B Hazardous Waste Mgmt Plan 01 July 08 Final

HAZARDOUS WASTE MANAGEMENT PLAN

Thule Air Base

CDRL CEV-15B

FINAL

OPR: GREENLAND CONTRACTORS

Chief of Environmental Engineering DSN 629-3840 ext. 2698 Supersedes CDRL CEV-15B, 01 July 2007 edition

Contract No. FA2523-05-C-9001 01 July 2008

CDRL CEV-15B Hazardous Waste Management Plan

TABLE OF CONTENTS

1 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

2 GENERAL

2.1 Purpose

2.2 Scope

2.3 Regulatory Overview

3 ORGANIZATIONS AND RESPONSIBILITIES

3.1 Installation Commander, 821 ABG/CC

3.2 Accounting and Finance, 821 ABG/FM

3.3 Danish Liaison Officer, DLO

3.4 Occupational Safety & Health, GC/SE

3.5 GC Civil Engineering, GC/CE

3.6 Base Supply, GC/LGS

3.7 GC Environmental Engineering, GC/CEE

3.8 Defense Reutilization and Management Organization DRMO, GC/LGDRM

3.9 Fire Protection, GC/AMF

3.10 Generators of Hazardous Waste

4 HAZARDOUS WASTE CHARACTERISTICS

4.1 Characteristic Waste?

4.1.1 Ignitable Waste (D001):

4.1.2 Corrosive Waste (D002):

4.1.3 Reactive Waste (D003):

4.1.4 Toxicity Characteristic Waste (D004-D43):

4.1.5 Radioactive Waste:

4.2 Listed Waste:

4.2.1 F-list (F001-F005)

4.2.2 K-list:

4.2.3 P-list

4.2.4 U-list:

5 HAZARDOUS WASTE STORAGE

5.1 Hazardous Waste Accumulation Point

5.1.1 Requirements for HWAP

5.1.2 Documentation for the HWAP

5.2 Hazardous Waste Storage Area

Thule Air Base 3 01 July 2008

5.2.1 Requirements for HWSA

5.2.2 Documentation for the HWSA

5.3 Closure Plans

6 LABELING

6.1 Hazardous Waste Label

6.2 Non Hazardous Waste Label

6.3 Hazard Class

7 TURN-IN PROCEDURES

7.1 Hazardous Waste Turn-in Procedure

7.2 Hazardous Materials Turn-in Procedure

7.3 EPA Provisional ID Number

8 CONTINGENCY, PREPAREDNESS AND SPILL RESPONSE

9 PERSONNEL TRAINING

APPENDICES

APPENDIX 1: DEFINITIONS AND TERMS

APPENDIX 2: HAZARDOUS WASTE INVENTORY AT THULE AB

APPENDIX 3: WASTE ANALYSIS PLAN

APPENDIX 4: BATTERY DISPOSAL PROCEDURES

APPENDIX 5: TURN-IN DOCUMENTS

APPENDIX 6: EMPTY CONTAINER MANAGEMENT FOR HWSA

APPENDIX 7: LOGBOOKS FOR HWAP/HWSA

APPENDIX 8: INSPECTION CHECK LIST FOR HWAP/HWSA

APPENDIX 9: CLOSURE PLAN

APPENDIX 10: DRUM / SMALL ITEM SHEET

APPENDIX 11: DISTRIBUTION LIST

Thule Air Base 4 01 July 2008

1 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

Title: The title of this document is “Hazardous Waste Management Plan”. The acronym HWMP will be used throughout the document.

Classification: This document is unclassified.

Responsibilities: Greenland Contractors, Environmental Engineering (GC/CEE) is the office of primary responsibility for developing and maintaining the HWMP. The instructions given in this plan are applicable to all organizations and tenant units at Thule AB. Organizations are authorized to extract and reproduce those sections of the HWMP that are essential in the accomplishment of necessary planning and in the preparation of supporting documents and reports.

References: References referred to in the HWMP do not appear in the plan, but they may be accessed through GC Environmental Engineering or the Air Force Electronic Publication Library

(AFEPL).

Reviews/changes: The HWMP will be reviewed and updated annually IAW the CDRL and distributed accordingly. A draft is submitted to the requiring office, 21CES/CEANN, by 1 Nov for review. Review comments, if any, will be provided by 21CES/CEANN within 60 days. Review comments received will be incorporated in the final version of the plan within 30 days; thereafter the document will be submitted to 821ABG/CC for signature. The signed plan will then be submitted as the Final edition.

Furthermore, the plan is subject to change if any of the applicable laws, regulations, or requirements are altered.

Distribution: The plan is distributed IAW the CDRL Summary distribution list, APPENDIX 11.

Thule Air Base 5 01 July 2008

2 GENERAL

2.1 Purpose

The purpose of the HWMP is to ensure that documented guidance for hazardous waste (HW) management is available to all installation personnel.

The documentation will include:

• Identification of all HW generators.

• Identification of all HW streams.

• Identification and description of all HW being produced.

• Implementation of proper procedures for handling, labeling, marking, storing, and disposing of HW.

• Monitoring the required performances with regard to HW management as described in this plan.

• Continued evaluation and update of the HW inventory and analysis plan.

• Establishment of procedures to ensure outside contractors' compliance with the Thule AB

HWMP.

• Revision and update of host-tenant support agreements and exercise support agreements (BOX-TOP, ICEX, etc.) by the Environmental Protection Committee to ensure that these comply with the HWMP.

The goal is to achieve a full state of awareness throughout the installation in order to protect employee health, provide a safe work environment, minimize adverse effects on the environment from the generation and disposal of HW, and minimize the disposal costs of the generated HW.

2.2 Scope

The provisions of the HWMP apply throughout Thule AB and to all personnel. Certain responsibilities are specifically assigned to selected individuals identified in the plan.

Related plans that are developed to cover other functions may need to be consulted:

• Solid Waste Management Plan, CDRL CEV-15E

• Spill Prevention and Response Plan, CDRL CEV-15C

• Asbestos Management Plan, CDRL CEV-15A

• Slug (Wastewater) Management Plan, CDRL CEV-15J

• Storm Water Management Plan, CDRL CEV-15G

• TABI 32-101, Management of Electrical Equipment Containing Polychlorinated Biphenyls

(PCB)

Thule Air Base 6 01 July 2008

2.3 Regulatory Overview

In accordance with USAF policy, Thule AB is required to comply with the following public laws and their respective regulations.

Federal Regulations: 40 CFR, Title 40, Parts 1-790 and Environmental Requirements

Parts 1-900 (Guidance)

49 CFR, Title 49, Parts 171-80 and Hazardous Material Parts 100- 199 (Guidance)

USAF: Final Governing Standards for Environmental Protection by United

States Forces in Greenland, prepared by HQ AFSPACECOM, referenced herein as FGS.

Thule AB: EPC Decisions

Host Country: Country to Country Agreement concerning Disposal of United

States Salvage:

Memorandum of Understanding (MOU), “An Agreement Concerning the Disposal of United States Salvage, Surplus or Excess Equipment and Supplies at USAF Aerospace Defense Command Bases and Sites in Greenland”, dated 29 June 1976 and 1987 Amendment.

Thule Air Base 7 01 July 2008

3 ORGANIZATIONS AND RESPONSIBILITIES

In order to ensure that hazardous waste is handled in an environmentally correct manner, it is important that the hazardous waste generators are fully aware of their responsibilities in the HW management program. These responsibilities are outlined in the following:

3.1 Installation Commander, 821 ABG/CC

The Installation Commander has the overall responsibility for the management of HW generated at Thule AB. The responsibility is implemented through the base Environmental Protection Committee (EPC), of which the Installation Commander is the chairman.

The Installation Commander, or designated representative, serves as the On-Scene Commander in all incidents that may require emergency response action.

3.2 Accounting and Finance, 821 ABG/FM

The Accounting and Finance office assists in setting up accounts for fund management for the laboratory analysis and disposal costs of all HW.

3.3 Danish Liaison Officer, DLO

The Danish Liaison Officer serves as the official representative of Denmark and the Greenland Home Rule concerning environmental issues at Thule AB.

3.4 Occupational Safety & Health, GC/SE

The Occupational Safety & Health office performs safety and health inspections. Occupational Safety & Health is involved in an advisory role in any unknown situations waste handling personel encounter in relation to personal protective gear, correct signs, escape routes, ventilation and other work related potential hazards. By maintaining proper signs in English federal employees are warned about the potential hazards in handling hazardous waste.

3.5 GC Civil Engineering, GC/CE

The Civil Engineering office is responsible for the establishment of procedures to ensure that all projects are reviewed by GC Environmental Engineering. All projects must include special provisions to ensure that the disposal of HW is carried out in accordance with the HWMP, and that seasonal contractors properly dispose of HW generated, as a result of their activities at Thule AB.

3.6 Base Supply, GC/LGS

Base Supply is responsible for the operation of the Thule Air Base HAZMART (see Reference 16: AFI 32-7086, Hazardous Materials Management (HAZMART)).

3.7 GC Environmental Engineering, GC/CEE

Environmental Engineering is responsible for developing and implementing the HWMP.

GC Environmental Engineering must assist waste generators at TAB in identifying, characterizing and evaluating all HW.

• Supervise the waste generator on the correct procedures for handling, storing and turning in HW. Ensure seasonal contractors comply with the requirements for disposal of HW as outlined in this plan.

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• Conduct quarterly inspections of the Hazardous Waste Accumulation Points (HWAPs) and monthly inspections of the Hazardous Waste Storage Areas (HWSAs).

• Conduct required training for employees handling HW.

• Confirm that contractors, who want to dispose of their waste outside the DRMS system, have developed their own manifest tracking system to provide an audit trail from the point of generation to the ultimate disposal.

3.8 Defense Reutilization and Management Organization DRMO, GC/LGDRM The responsibilities of the DRMO includes:

• Off-site shipment of HW.

• Maintaining records of DD Form 1348-1A (manifests). Manifests must be retained for a period of three years.

• File the U.S. EPA Uniform Manifest (EPA Form 8700-22).

• Operation and weekly inspection of the HWSA using the checklist in APPENDIX 8.

• Assisting the hazardous waste generators and GC Environmental Engineering in identifying proper labeling and packaging for transportation.

3.9 Fire Protection, GC/AMF

The Fire Chief serves as the initial On-Scene Commander for emergency response actions.

The Fire Chief’s responsibilities include:

• Providing technical assistance on fire protection aspects of HW management.

• Assisting in the required fire prevention training for employees handling HW.

• Inspecting HW accumulation areas for fire hazards.

3.10 Generators of Hazardous Waste

Any waste generator (Greenland Contractors or other contractors) that generates HW through its activities must handle it in accordance with the HWMP. The waste generator must notify GC Environmental Engineering whenever there is an inconsistency with the current generation of HW, or the generation of HW changes. It is the responsibility of the supervisor to ensure that the Hazardous Waste is handled correctly.

Each shop that generates Hazardous Waste, including turn-in of Non Hazardous Waste, must have a Point of Contact (POC) for the HW or a HazMat Specialist. The POC must refer to a HazMat Specialist.

It is the obligation of any generator of Hazardous Waste to allocate the needed facility and manpower – this includes the needed time for training and maintenance of training.

Thule Air Base 9 01 July 2008

4 HAZARDOUS WASTE CHARACTERISTICS

Waste is hazardous if it can be harmful to human health and the environment when handled improperly.

Hazardous waste is a solid waste that:

1. Is a listed waste1 or

2. Exhibits a characteristic of a hazardous waste2 or typical hazardous materials characteristics3

The Waste identification process is shown in the flowchart below:

Solid waste

Is the waste listed? Does the waste exhibit any of the 5 characteristics specified?

No

The waste is hazardous waste

The waste is solid waste

See SWMP

Yes

No

Yes

Solid Waste The Hazardous Waste identification process is the first step in determining if the waste is solid or not.

Solid waste is: Garbage, refuse, sludge, and other discarded materials including solid, semisolid, liquid, and gaseous containing materials, resulting from industrial and commercial operations and from community activities.

It does not include solids or dissolved material in domestic sewage or other significant pollutants in water resources, such as silt, dissolved, or suspended solids in industrial wastewater effluent, dissolved materials in irrigation return flows or other common water pollutants.

1 See FGS appendix 1 2 See FGS appendix 1 3 See FGS Table C5.T1 Thule Air Base 10 01 July 2008

Outdated HM being stored for use and maintained beyond its shelf life, or due to a mission change, is no longer required. These items are not considered HM and must be turned in to the DRMO as HW. This is according to guidelines from DRMO, Norfolk who no longer has the capacity to handle HM and ensure the HM to be used or resold. The only items shipped as HM is batteries from cars, trucks, UPS etc.

4.1 Characteristic Waste?

There are five Hazardous Waste characteristics. If a waste exhibits one or more of the five characteristics it is a Hazardous Waste. This can be determined by the user’s basic knowledge (MSDS) or by analyzing the waste.

The five characteristics are:

• Ignitable

• Corrosive

• Reactive

• Toxic

• Radioactive

4.1.1 Ignitable Waste (D001):

Waste is ignitable when the flash point is less than 140oF/ 60oC.

A flash point is the lowest temperature at which a liquid can emit a vapor that will ignite when exposed to an ignition source.

Oil based paint, cleaners, and contaminated fuel

4.1.2 Corrosive Waste (D002):

Waste is corrosive if it has a pH

• Less than 2

• Greater than 12.5

• Liquids that corrode steel at a rate greater then 0.24 inches per year

Strong acids such as battery acid

Bases such as hydrochloric and sodium hydroxide

4.1.3 Reactive Waste (D003):

Waste is reactive if it is an unstable material that can pose a problem at any stage of the waste management cycle. Materials that are reactive include:

• Wastes, when mixed with water, react violently, form explosive mixtures, or generate toxic gases.

• Waste that is normally unstable or capable of detonation at standard temperature and pressure.

• Wastes that contain cyanides or sulfides and generate toxic gases at pH between 2 and 12.5.

• Waste that is listed by DOT as a Class A or Class B explosive.

Thule Air Base 11 01 July 2008

• Wastes, when exposed to a strong initiating source or if heated under confinement, are capable of detonating (non-empty aerosol cans).

Not something we normally have on Thule Air Base!!

4.1.4 Toxicity Characteristic Waste (D004-D43):

Waste has a toxicity characteristic if it contains one or more compounds in a concentration higher than or equal to the regulatory level listed in the table below. These concentrations are determined using the EPA’s Toxicity Characteristic Leaching Procedure (TCLP) test method 1311 as stated in EPA publication SW-846.

EPA HW REGULATORY NO. CONTAMINANT LEVEL (mg/L) D004 Arsenic 5.0 D005 Barium 100.0 D018 Benzene 0.5 D006 Cadmium 1.0 D019 Carbon Tetrachloride 0.5 D020 Chlordane 0.03 D021 Chlorobenzene 100.0 D022 Chloroform 6.0 D007 Chromium 5.0 D023 o-Cresol 200.0 D024 m-Cresol 200.0 D025 p-Cresol 200.0 D026 Cresol 200.0 D016 2,4-D 10.0 D027 1,4-Dichlorobenzene 7.5 D028 1,2-Dichloroethane 0.5 D029 1,1-Dichloroethylene 0.7 D030 2,4-Dinitrotoluene 0.13 D012 Endrin 0.02 D031 Heptachlor (and its epoxide) 0.008 D032 Hexachlorobenzene 0.13 D033 Hexachlorobutadiene 0.5 D034 Hexachloroethane 3.0 D008 Lead 5.0 D013 Lindane 0.4 D009 Mercury 0.2 D014 Methoxychlor 10.0 D035 Methyl Ethyl Ketone 200.0 D036 Nitrobenzene 2.0 D037 Pentachlorophenol 100.0 D038 Pyridine 5.0* D010 Selenium 1.0 D011 Silver 5.0 D039 Tetrachloroethylene 0.7 D015 Toxaphene 0.5 D040 Trichloroethylene 0.5 D041 2,4,5-Trichlorophenol 400.0 D042 2,4,6-Trichlorophenol 2.0 D017 2,4,5-TP (Silvex) 1.0 D043 Vinyl Chloride 0.2

Thule Air Base 12 01 July 2008

4.1.5 Radioactive Waste:

Waste has a radioactive characteristic if it has a concentration higher or equal to the regulatory level of radioactivity measured by an approved meter.

Radioactive detectors - must be collected in a drum for later measurement by US bio-environmental.

Old smoke detectors – rarely found on Thule AB!!

4.2 Listed Waste:

A listed HW is a waste identified on one of four lists published in the EPA regulations. The lists are divided into

• F-list non-specific source wastes

• K-list specific source wastes

• P-list commercial chemical products

• U-list commercial chemical products

4.2.1 F-list (F001-F005)

F-listed waste at Thule Air Base only applies to waste that is generated from the use of certain common organic solvents. Solvents used as solvent for their solvent properties, for example -used for degreasing and cleaning. The listing only covers solvents that are above a certain concentration before use - see Appendix 1 in FGS. It is only F001 to F005 that are relevant at Thule Air Base.

Rags used for cleaning or degreasing and waste residue

4.2.2 K-list:

K-listed Hazardous Waste is from a specific source on the K-list. This list includes waste from certain wood-preserving chemical manufacturing, petroleum refining, and other manufacturing processes. This list is not relevant for Thule Air Base.

4.2.3 P-list

P-listed waste is certain unused acutely hazardous commercial chemical product.

4.2.4 U-list:

A U-listed waste is an unused commercial chemical product that is not acute. A complete list is found in FGS, Appendix 1.

Waste Mixtures:

A HW mixture is a mixture of a listed HW and any other material, or a mixture of a characteristic HW and any other material - provided that the mixture still exhibits the hazard characteristic.

Thule Air Base 13 01 July 2008

Most mixtures of HW and other wastes or materials are classified as HW. Therefore, mixing a HW with a non-HW does not produce a non-hazardous mixture.

Waste Residue:

• Any residue remaining in a container, or an inner liner removed from a container that held any commercial chemical product or manufactured chemical intermediate, having the generic name listed in Table AP1.T4 in the FGS, annotated "P" or "U" as the first character in the USEPA waste number.

• Any residue or contaminated soil, water, or other debris resulting from the cleanup of a spill into or on any land or water of any commercial chemical product or manufactured chemical intermediate having the generic name listed in Table AP1.T4 in the FGS, annotated "P" or "U" as the first character in the USEPA waste number.

Thule Air Base 14 01 July 2008

5 HAZARDOUS WASTE STORAGE

At Thule Air Base, there are two types of HW accumulation and storage points:

HWAP Hazardous Waste Accumulation Point

HWSA Hazardous Waste Storage Area

All HW must be accumulated in approved accumulation and storage points.

5.1 Hazardous Waste Accumulation Point

An HWAP is an area designated for the accumulation of HW at or near the point of generation.

Any shop, which generates HW, must have an HWAP in order to accumulate waste in accordance with the FGS. The requirements for the HWAP must ensure the waste is accumulated in a proper and environmentally safe manner.

A HWAP may be used to accumulate no more than 55 gallons of hazardous waste, or 1 gallon of acute waste from each waste stream.

HWAPs are established at the different work places as listed in APPENDIX 2. In the event that new hazardous waste streams are identified, HWAPs will be established or the waste stream will be added to an existing HWAP in coordination with GC Environmental Engineering as soon as possible.

(See FGS 6.2.6/6.3.2 Hazardous Waste Accumulation Points).

5.1.1 Requirements for HWAP

The requirements for an HWAP are as follows:

1. All HW must be accumulated in an approved HWAP at or near the point of generation.

2. There must only be one 55-gallon container for each HW stream or 1 gallon of acute HW4.

3. The superintendent/supervisor of the shop must appoint a primary and alternate HWAP manager. Furthermore, there must be at least one POC or HazMat Specialist for the HW.

An appointment letter must be sent to GC Environmental Engineering, Fire Protection and DRMO. The appointment letter has to be renewed when the appointed HWAP manager or alternate change.

4. HW that contains free liquids must be placed in secondary containment. The secondary containment must have sufficient capacity to contain 10% of the volume of all containers, or the volume of the largest container, whichever is greater.

5. The HWAP must be segregated from all potential ignition sources, including electrical sources, open flames, heat sources, cutting and welding operations, any smoking areas and ashtrays at a distance of 50 ft.

4 The waste listed in Appendix 1 in FGS with a U.S EPA waste number with the designator “P” or the waste with (H) following the waste number.

Thule Air Base 15 01 July 2008

6. Signs:

• Signs must clearly mark the designated area. The text on the sign must, as a minimum, be “Hazardous Waste Accumulation Point”.

• The HWAP must clearly be marked with striped safety hazard tape.

• “No Smoking” signs must be placed whenever there is a hazard from ignitable or reactive waste.

• Each HWAP must have Warning signs/ Hazard class outside or at the HWAP.

7. It is recommended that the size of the container used for accumulating a recurrent HW stream be adjusted for the amount of HW accumulated in one year. There is no time limit for accumulation in an HWAP.

8. Only 90% of a container must be filled in order to allow for expansion.

9. When 90% filled, the container must be transferred to the HWSA within five working days.

10. HW containers must be labeled as directed in Chapter 7.

11. Containers must be UN-approved except for containers for batteries.

12. Containers must be in a good condition (no rusting, bulging or structural defects).

13. Containers must be closed when HW is not filled in to the drums.

14. Container with flammable liquids must be grounded (especially when transferring liquid hazardous waste).

15. A contingency plan must be maintained and easily accessible for each HWAP, see Chapter 9.

16. Portable fire extinguishers must be available.

17. Emergency telephone or radio must be available.

18. Appropriate spill absorbent for the waste stored.

19. Personal protective equipment must be available in sufficient amounts and appropriate for the waste stored, e.g. an eye wash station.

20. The HWAP must be inspected weekly.

21. The HWAP is inspected once every quarter by GC Environmental Engineering.

22. The schedule for inspection of well managed HWAPs can be reduced by GC Environmental Engineering to one internal inspection every month and two Environmental Engineering inspections per year.

5.1.2 Documentation for the HWAP

1. A training record for the individual that handles hazardous waste and their superintendent/ supervisor must be available.

2. Turn-in document for the last three years.

a. 1348-1A

b. 1930

3. A log for each drum where heterogenic hazardous waste is being added (see APPENDIX 7). Containers with different kinds of batteries do not require a log.

Thule Air Base 16 01 July 2008

4. Inventory for all items in the HWAP.

5. Analyses results for the recurrent Waste Stream/ Waste Characterization.

6. Inspection records are kept on file for at least three years.

7. Small item sheet for each item that is not a recurrent waste stream.

8. Inspection checklist from internal inspections and inspections made by GC Environmental Engineering for the last three years.

When the turn in documents, analyses and checklists from inspections are no longer needed they will be sent to GC Environmental Engineering.

5.2 Hazardous Waste Storage Area

A HWSA is an area designated for accumulation and storage of HW. In the HWSA, there is stored HW in quantities greater than 55 gallons received from one or more HWAPs. Testing and maintenance of emergency equipment is conducted regularly.

There are no limitations volumetrically on the quantity of HW accumulated, and no requirements to the HWSA being located at or near the point of generation.

At Thule AB, there are the following HWSAs:

• Yard outside Bldg. #580 - Mainly HW from Vehicle Maintenance and Services shops/activities

• Yard outside Bldg. #551 - Mainly HW from special products shops/activities

• Bldg. #604 - Funded HW storage. Operated by DRMO

• Bldg. #969 - Central HWSA

5.2.1 Requirements for HWSA

1. Hazardous waste has a maximum Storage-Time of one year.

2. Storage of more than 55 gallons of hazardous waste or one gallon of acute waste.

3. The Manager that is responsible for the shop must appoint an HWSA manager, an alternate and POC’s, and send an appointment letter to GC Environmental Engineering, DRMO and Fire Protection. The appointment letter has to be renewed when the appointed HWAP manager or alternate change.

4. HW that contains liquids must be placed in secondary containment. Annual leak tests of the secondary containment must be performed.

5. The HWSA must be designed and maintained to prevent fire, explosions, and release of HW/HM into the environment.

6. Access must be controlled to prevent incidental contact.

• For outdoor facilities, the requirement is a fence with a lockable gate.

• For buildings, the requirement is a lockable entrance to the building.

• When outdoor facilities and buildings are not in use, fences and doors are kept locked.

Thule Air Base 17 01 July 2008

7. Signs:

• Two types of signs must be posted and must be visible from at least 25 ft.

• Written in English, Danish, and Greenlandic, and read as follows:

English:

• "DANGER UNAUTHORIZED PERSONNEL KEEP OUT"

• “HAZARDOUS WASTE MANAGEMENT AREA"

Danish:

• ”Uvedkommende ingen adgang”

• ”Område med farligt affald”

Greenlandic:

• ”Navianartoq susassaqanngitsut iseqqusaanngillat”

• ”Tamanna nakkutigineqarpoq Navianartumik ilitsivik”

• ”NO SMOKING" signs must be displayed at several locations at the accumulation areas.

8. Ignitable or reactive waste must be segregated from all potential ignition sources to prevent fire or explosions. These types of waste must be separated from all electrical sources, heat sources, open flames, cutting or welding operations, and smoking areas at a distance of 50 ft.

9. Aisle space must be wide enough to allow inspection of the drums. A minimum of 4 ft. is recommended along the center aisle, and a 2-ft vertical and horizontal aisle should be provided between the other rows.

10. Incompatible wastes are properly segregated.

11. A contingency plan must be maintained and easily accessible for each of the HWSAs.

12. Emergency response equipment must be available, see chapter 9.

13. Personal protective equipment must be available in sufficient amounts and appropriate for the waste stored.

14. Emergency telephone or radio must be available.

15. Spill absorbents appropriate for the waste stored.

16. Portable fire extinguishers.

17. Eye wash station.

18. Closure plan for the stores HWSA.

19. The HWSA must be inspected weekly.

20. The HWSA is inspected once every quarter by GC Environmental Engineering and annually by Fire Protection.

21. An operation log must be maintained for these areas by the local DRMO function. In this log the date, volume, type of waste transferred to or from the HWSA, a notification of the observations made, and the date and nature of any repairs or other remedial actions must be noted.

Thule Air Base 18 01 July 2008

22. The DRMO function must prepare the EPA Uniform Manifest for all off-site shipments and maintain a copy of the manifests for at least three years after shipment. The HWSA manager must ensure that a DD Form 1348-1A, a DRMS Form 1930, and relevant support documents (MSDS, analysis report, log) accompany all HW turned in, and that the HW is funded by GC Environmental Engineering.

23. When stored in Bldg. #604, the containers must be placed on pallets and sufficient aisle space must be ensured between rows to allow forklift operation and ready access for inspection and possible leak response.

24. Incompatible hazardous waste must be segregated with beams/temporary walls to avoid incidental mixing if a spill occurs.

5.2.2 Documentation for the HWSA

1. A training record for the individual that handles hazardous waste and their superintendent/supervisor must be available.

2. Turn-in documents for the last three years:

• 1348-1A

• 1930

3. Inventory over all items in the HWSA.

4. Inspection records for at least three years.

5. Drum item sheet on all items.

When the turn in documents, analyses and checklists from inspections are no longer needed they are to be sent to GC Environmental Engineering

5.3 Closure Plans

Every HW Storage Area (HWSA) must have a closure plan (see APPENDIX 9) before it is opened. The plan must specify the procedures to be followed in order to achieve complete and safe closure. This includes:

1. Removal of all waste to another HWSA or by ship to CONUS.

2. Removal of all temporary dike walls. If spills have occurred on flexible liners, these should be containerized and disposed of as HW. If no spills have occurred, the liners may be disposed of in the sanitary landfill.

3. Removal of used pallets. If any spills have occurred on the pallets or they show any visible signs of contamination, the pallets should be dismantled and disposed of as HW, otherwise they may be disposed of at the sanitary landfill.

4. Handling of any polluted soil by treatment and disposal of this as HW.

It is the responsibility of the HWSA manager to ensure a complete and safe closure of the storage area. The closure must be coordinated with GC Environmental Engineering.

Thule Air Base 19 01 July 2008

6 LABELING

Containers must be properly marked to indicate their use for waste accumulation and stores.

The container must be marked with one of the three labels and hazard class.

All other markings on the container from previous use must be removed before it is used for waste accumulation.

6.1 Hazardous Waste Label

Yellow label: “HAZARDOUS WASTE” is used when the waste is determined to be hazardous. The information on the label must include:

Name: Organization (e.g. 821ABG/GC/SVCS, Bldg.

#237)

Address: Thule Air Base, Greenland

City: APO AE 09704-5000

US-EPA id no.: MIR 0000 36616

EPA waste no.: The EPA waste no. (stated by MSDS, or FGS)

Accumulation start date: The date the drum is filled to 90% of its capacity

The proper shipping name and UN number must be written e.g., “Environmentally Hazardous Substances Solid N.O.S” UN: 3077.

White label: “THIS CONTAINER ON HOLD PENDING ANALYSIS” is used if the contents of the container are unknown and a sample must be collected for HW characterization and while awaiting analysis results: The information on the label must include:

Contents: e.g., Drum found on base

Origin of materials: Process or activity, e.g. Drum Project

Address: Organization (e.g., 821ABG/GC/OMEP, Bldg. #801)

Accumulation start date: The date the drum is filled to 90%

Black label: “USED BATTERIES” is used for batteries.

Shipper: Organization (e.g., 821ABG/GC/CEMR, Bldg.

#551)

Address: Thule Air Base, Greenland

City: APO AE 09704-5000

Contents: Used batteries/ hazardous waste

Thule Air Base 20 01 July 2008

6.2 Non Hazardous Waste Label

Green label: “NON-HAZARDOUS WASTE” is used when the waste is determined to be non-hazardous. The information on the label must include:

Shipper: Organization

(e.g., 821ABG/GC/SV, Bldg. #237)

Address: Thule Air Base, Greenland

City: APO AE 09704-5000

Contents: e.g., used developer

“Used oil” label is used for oil suitable for energy recovery (See SWMP). The information on the label must include:

Company: Organization

(e.g., 821ABG/GC/LGTM, bldg. #580)

Address: Thule Air Base, Greenland

City: APO AE 09704-5000

Source: e.g., Oil changes in WM

Contact: Hazmat specialist/ Shop Supervisor

“Drained used oil filter” label is used for oil filters. The information on the label must include:

Accumulation start date: The date the drum is filled to 90% of its capacity

Below the “Accumulation start date” write shop name: GC/LGTM bldg. #580

Thule Air Base 21 01 July 2008

6.3 Hazard Class

The warning labels most commonly used at Thule AB are:

Flammable: Hazard class 3 Flashpoint is below 140º F (60º C).

Poisonous: Hazard class 6

Corrosive: Hazard class 8 pH-value is less than 2 or greater than 12.5.

Miscellaneous: Hazard class 9

All labels can be ordered from the DRMO, ext. 2785. The DRMO will identify the proper Department of Transportation (DOT) marking for each shipping container.

Thule Air Base 22 01 July 2008

7 TURN-IN PROCEDURES

7.1 Hazardous Waste Turn-in Procedure

The following procedure must be followed when HW is turned in:

1. Get a Material Safety Data Sheet (MSDS) or analysis test results and if required the logbook for HW.

2. The waste generator characterizes the hazardous waste.

3. Hazardous waste containing free liquids must always be over packed before turn-in.

Containers below 55 gallons must be placed in the salvage drum that is packed with absorbent material.

4. Label the container, see Chapter 7.

5. The waste generator must in cooperation with DRMO fill out the turn-in papers for HW:

a. Hazardous Waste Profile Sheet, (DRMS Form 1930), see APPENDIX 5.

b. DD Form 1348-1A, see APPENDIX 5.

6. Contact the DRMO, ext. 2785, for weighing and transportation.

7. All HW turn-in documents must be kept on file at the DRMO and the waste generator for a period of three years from the date of turn-in.

7.2 Hazardous Materials Turn-in Procedure

The procedure for turn in of HM, only batteries, is the same as for HW, except for the following:

1. A DD Form 2521 or DD Form 2522 (half the size of a DD Form 2521) must be filled out instead of the DRMS Form 1930. The form must be filled out using the information given on the material’s MSDS.

2. The original price or an estimate price must be printed on the DD Form 1348-1A.

3. The strict regulations, which apply for packaging HW, do not apply for HM, but packaging must be appropriate for transportation.

7.3 EPA Provisional ID Number

Shortly (7 to 8 days) before the Pacer Goose departs from Thule AB to Norfolk, VA, EPA Form 8700-12 “RCRA Subtitle C Site Identification” is prepared for 821ABG/CC signature and consequently submitted to the Virginia Department of Environmental Quality IAW CDRL CEV-

18. The EPA Provisional ID Number must be renewed after 30 days of the initial number, if the HW has not reached its final location.

Thule Air Base 23 01 July 2008

8 CONTINGENCY, PREPAREDNESS AND SPILL RESPONSE

Contingency Plan: A document setting out an organized, planned, and coordinated course of action to be followed in case of a fire, explosion, or release of hazardous waste or hazardous waste constituents that could threaten human health or the environment.

The HW generators are responsible for the development and updating of the site-specific contingency plans for each HWAP/HWSA. GC Environmental Engineering will, if required, assist in the development and updating of the plans, which should be available in English, Danish and Greenlandic.

The plan has to be submitted to any function identified in the plan, and which the plan relies upon to provide emergency services, e.g. police department, fire department, hospital and emergency response teams.

The contingency plan must be designed to minimize hazards to human health or the environment from fires, explosions, or any unplanned sudden or non-sudden release of HW into the air, soil, and water. The emergency response procedures must be detailed in the contingency plan. Specific requirements to be incorporated into the plan are described below.

Each contingency plan must contain the following information:

• The most important and most detailed portion of the contingency plan is the description of the emergency procedures that will be followed for HW-related emergencies. The plan should detail response actions that will be implemented in the event of a release, fire, and/or explosion at each accumulation site. A current list of all persons to contact with office and home phone numbers.

• Where HW is generated, accumulated, or stored must be evaluated to determine what kinds of emergency equipment may be necessary to abate emergencies that may be reasonably anticipated to occur at that location. A list of emergency equipment that may be used in the event of a HW incident.

• The emergency response equipment can include:

- Spill booms or absorbent pillows.

- Granular absorbents (one drum for every 300 gallons stored).

- Fire control equipment, as decided by GC/AMF.

- Chemical respirators suitable for the waste in storage.

- Emergency eyewash stations (bottle-type is sufficient).

- Gloves and boots.

- Face shields and safety glasses.

- Salvage drums.

Personal protective equipment must be available in sufficient amounts. GC Environmental Engineering must ensure, together with Fire Protection, that there is enough equipment and that it is properly maintained.

If there is a possibility that evacuation from a building or the installation may be necessary, the contingency plan must include an evacuation plan. The evacuation plan must describe signals used to begin evacuation and evacuation routes. Alternate evacuation routes must be described if the primary routes are blocked by the release of HW, fire, or explosion.

Thule Air Base 24 01 July 2008

9 PERSONNEL TRAINING

The Hazardous Waste Handler Course is mandatory for personnel that handle or otherwise manage HW, and their supervisor / superintendent / managers. Superintendents / supervisors / managers must participate a minimum of one time, while personnel who handle hazardous waste (i.e. POC for HWAP/HWSAs) must participate once a year.

The training is provided by GC Environmental Engineering in accordance with the Environmental Training Plan. GC Environmental Engineering sends a notification to the supervisor/ superintendent when a course is scheduled.

The training will include but is not limited to:

• Chemical hazards of HW.

• Regulatory overview.

• Emergency procedures (response to spills, spill kits, clean-up, etc).

• Drum/container handling/storage and safe use of HW equipment.

• Personal protective equipment.

• Record keeping, inspections, contingency plans and storage requirements.

• Turn-in procedures (HW profiles, funding documents, etc).

Newly assigned personnel handling HW should be provided the training before starting the job.

Training records for personnel involved in the handling of HW must be kept on file by the organizations/departments, to which the employee in question is assigned, and retained for 3 years after termination of duty of the employee. Records must identify the employee's position and responsibility in handling HW, as well as the date when the training was received.

Thule Air Base 25 01 July 2008

APPENDICES

Thule Air Base 26 01 July 2008

APPENDIX 1: DEFINITIONS AND TERMS

Acute Hazardous Waste – Waste listed in Appendix 1 with a U.S. EPA waste number with the designator “P” or waste with (H) following the waste number. See FGS Appendix 1.

Characteristic Waste - Waste that exhibits any of the characteristics listed in the FGS, Appendix 1 (i.e. toxicity, corrosive, ignitability, reactivity).

Closed Container - A HW container where the lid is fastened with locking rings or bungs wrench-tight.

Container - Any device, in which a material is stored, transported, treated, disposed of, or otherwise handled.

Disposal - The utilization of those methods of treatment and/or containment technologies, as are approved in the FGS, section 11, that effectively mitigate the hazard to human health or the environment of the discharge, deposit, injection, dumping, spilling, leaking, or placing of any HW into, or on any land or water in a manner that, without application of such methods, such hazardous wastes or any constituent thereof may enter the environment or be emitted into the air or discharged into any waters including groundwater.

DOT - Department of Transportation.

DRMO (local) - Defense Reutilization and Marketing Office.

DRMS - Defense Reutilization and Marketing Service.

EPA - Environmental Protection Agency.

EPA Hazardous Waste Number - The number assigned by the EPA to each HW listed in the FGS, Appendix 1, and to each characteristic identified in the FGS, Appendix 1.

EPA Identification Number - The number assigned by the EPA to each generator, treatment, storage, or disposal facility. Thule AB EPA ID Number: MIR 0000 36616.

EPC - Environmental Protection Committee.

FGS - Final Governing Standards.

Flash Point - The minimum temperature, where there is sufficient vapor to ignite the source, if introduced to an external ignition source.

Generator - Any person or site whose act or process produce HW, identified or listed in the FGS. Thule AB is considered a small quantity generator.

Generating Activity - Every organization (including tenants), shop and/or work area possessing an operation or process that initially generates a HW stream.

Hazardous Waste Characterization - HW characterization is the identification, description, and qualification of a HW stream.

Thule Air Base 27 01 July 2008

Hazardous Waste Profile Sheet - DRMS-Form 1930, which describes the physical and chemical properties of a HW.

HTSC – Harris Technical Service Corporation.

HM - Hazardous Material.

HW - Hazardous Waste as defined in the FGS, Appendix 1.

HWAP – A Hazardous Waste Accumulation Point is a location designated for accumulation of HW from a specific process, in a container near its point of generation. The volume accumulated must not exceed 55 gallons for each HW stream or 1 gallon of acute HW.

HWSA – A Hazardous Storage Area is a designated location for waste from Accumulation Points. The HWSA is a storage area where more than 55 gallons of hazardous waste is stored, and more than one container per waste stream may be placed at the accumulation point.

Normal storage time at this point is one year for small quantity generators, but due to the Arctic conditions with a limited port season, this time requirement cannot always be met.

Listed Waste - A specifically identified chemical, which is listed in the FGS, Appendix 1.

Manifest - The shipping document originated and signed by the generator, which contains the information required by the EPA.

Manifest Document Number -The serial number assigned to the manifest by the generator for recording and reporting purposes.

N.O.S. – Not otherwise specified.

Secondary Containment – A system that is sufficiently impervious to contain leaks, spills and accumulated precipitation until the collected material is detected and removed.

Spill - The accidental spilling, leaking, pumping, pouring, emitting, or drumming of HM, which become HW when spilled into water or on any land.

Storage-time – The time that HW has been stored since the container has been finally closed at the HWAP.

Thule AB - Thule Air Base.

Waste Stream Code - A unique identification number assigned to each waste stream by GC Environmental Engineering after the identification of that waste stream. The waste stream number is generated by department initials (CE/LG/SV/AM/SG/BAE/HTSC) + CFY (current fiscal year) + building number + serial number.

Thule Air Base 28 01 July 2008

APPENDIX 2: HAZARDOUS WASTE INVENTORY AT THULE AB

The Hazardous waste inventory list also contains waste that in accordance with the FGS is not hazardous waste. It concerns PCB ballasts, radioactive detectors, and Asbestos containing materials that is appropriate to manage and dispose as hazardous waste.

HW inventory is developed based on the information provided by the individual shops. The table includes the following information:

Type of Waste: The type of waste, which is generated in the shop.

Waste Stream Code: The waste stream code is a unique identification number, which is put on waste if a shop accumulates more than 50 gallons a year. All containers sent out of the base must be marked with a specific waste stream code for identification. The solid waste being disposed of at the sanitary landfill or recycled on base, or elsewhere, does not have a waste stream code. The code number consists of:

- Respective department initials (OM/LG/SV/AM/SG/BAE/ HTSC)

- CFY (Current Fiscal Year)

- Building No.

- Serial No.

Example: CE-01-551-001

Baseline Analysis: The requirements for the turn in of HW. Logbook, analysis result, MSDS, or user knowledge is required.

EPA HW Code: The EPA HW code, which identifies the waste as a HW.

LIST OF BASE-WIDE GENERATED WASTE STREAMS

Type of Waste Disposal Method Various batteries Collected in a base wide collection system by the DRMO personnel. The batteries are sorted and disposed of as recycled materials, non-HW or

HW.

Toner cartridges Accumulated in packs of 10, labeled with a return label enclosed in the original packaging and sent of for recycling via the American Post Office, Bldg. #211.

Toner and developer Disposed through the DRMO if possible.

Fluorescent lights Disposed through the DRMO Radioactive detectors Collected at a centralized point –

USAF bio-environmental is responsible for the analysis.

Thule Air Base 29 01 July 2008

LIST OF RECURRING INDUSTRIAL GENERATED HAZARDOUS WASTE STREAMS

Type of Waste Waste Stream Code Baseline Analysis

EPA

Hazardous Waste Code

BLDG. #113, NON SECURE COMMUNICATION, MAINTENANCE CENTER

Rechargeable batteries (NiCad, lead-acid/gel-cell)

LG-CFY-113-002 MSDSs/User knowledge D002/D008 /D006

Non-rechargeable batteries:

(Alkaline mercury, Silver containing)

N/A MSDSs/User knowledge D009/ D011

Lithium batteries LG-CFY-113-003 D003

BLDG. #118, HOSPITAL

Developer for X-Ray Film SG-CFY-118-002 Annual waste stream update Rechargeable batteries (NiCad) N/A MSDSs/User knowledge D002 Non rechargeable batteries N/A MSDSs/User knowledge Lithium batteries D003

BLDG. #237, LAUNDRY

“Pure Dry” cleaning sludge SV-CFY-237-002 Waste stream update every third year

BLDG. #551, CE SERVICE SHOP

PCBs; solid, ballasts OM-CFY-551-001 MSDS serial number: CDYVK 40 CFR, part

Spray cans (oil-based) OM-CFY-551-003 Annual waste stream update D001 Rechargeable batteries (NiCad, lead-acid/gel-cell)

N/A MSDSs/User knowledge D002/D008/ D006

Non rechargeable batteries;

(mercury; Silver containing)

N/A MSDSs/User knowledge D002/D008/ D009/ D011

Lithium batteries D003 Fluorescent light tubes OM-CFY-551-005 Turned in at DRMO Oil, recoverable

N/A Burned at K-Plant

BLDG. #561 BAE SYSTEMS

Solders, Wick/ Sponges (lead solder)

BAE-CFY-561-001 Waste stream update every third year

D008

Rechargeable batteries (NiCad, lead-acid/gel-cell)

N/A MSDSs/User knowledge D002/D006/ D008

Non rechargeable batteries;

mercury; Silver containing)

N/A MSDSs/User knowledge D008/D009/ D011

BLDG. #571, CONSTRUCTION SHOP

Paint (oil based) Paint (Latex)

OM-CFY-571-007 Logbook, annual waste stream update

D001

Asbestos OM-CFY-571-010 Logbook, asbestos landfill Asbestos waste

Paint thinner OM-CFY-571-009 Logbook, annual waste stream update

D001

Rechargeable batteries (ni-cad, lead-acid/gel-cell)

N/A MSDSs/User knowledge D002/D008/D0

Lithium batteries N/A MSDSs/User knowledge D003 Alkaline batteries N/A MSDSs/User knowledge N/A Rags with solvent OM-CFY-571-011 MSDSs/User knowledge F001

Thule Air Base 30 01 July 2008

EPA

Hazardous Waste Code

BLDG. #580, VEHICLE MANAGEMENT

Paint and thinner LG-CFY-580-001 Logbook, annual waste stream update D001

Filter element on the aerosol paint can puncture

LG-CFY-580-004 Waste stream update every third year

F001

Asbestos Brake pads

LG-CFY-580-015 Logbook, asbestos landfill Asbestos waste

Batteries (acid) LG-CFY-580-010 HM recycled via DRMO D002/ D008 Rechargeable batteries (NiCad, lead-acid/gel-cell)

N/A MSDSs/User knowledge D002/D006 /D008/

Non rechargeable batteries;

(mercury; Silver containing)

N/A MSDSs/User knowledge D002/D008/ D009/ D011

Lithium batteries N/A MSDSs/User knowledge D003 Fuel Filters LG-CFY-580-005 Waste stream update every third year D008

Rags contaminated with solvent LG-CFY-580-005 MSDSs/User knowledge F001 Paint from punctured spray cans LG-CFY-580-004 MSDSs/User knowledge D001 Aerosols oil products LG-CFY-580-001 MSDSs/User knowledge D001 Antifreeze, green N/A MSDSs/User knowledge D001 Sediment from Antifreeze green N/A MSDSs/User knowledge D001 Antifreeze, red N/A From new vehicles coming to

TAB. Turned in to DRMO, D001

Airbags N/A Airbags in vehicles Oil, recoverable N/A Mixed oil fraction, burned at K-

Plant F001

Windshield washer fluid N/A MSDSs/User knowledge F001 Brake fluid N/A Logbook, annual waste stream update F001

BLDG. #606, AIR GREENLAND

Non rechargeable batteries;

(Alkaline, mercury; Silver containing)

N/A MSDSs/User knowledge D002//D008/ D009/ D011

Rechargeable batteries (NiCad, lead-acid/gel-cell)

N/A MSDSs/User knowledge D002//D008

Oil, recoverable N/A Mixed oil fraction, burned at K- Plant

F001

BLDG. #801, ENTERPRISE

Paint (oil based) Paint (Latex)

OM-CFY-801-003 Logbook, annual waste stream update

D001

Paint thinner OM-CFY-801-002 Logbook, annual waste stream update

D001

Fluorescent light tubes OM-CFY-801-003 Turned in at DRMO.

Rechargeable batteries (NiCad, lead-acid/gel-cell)

N/A MSDSs/User knowledge D002//D008

Non rechargeable batteries;

(Alkaline, mercury; Silver containing)

N/A MSDSs/User knowledge D002//D008/ D009/ D011

Lithium batteries

N/A MSDSs/User knowledge D003

Thule Air Base 31 01 July 2008

EPA

Hazardous Waste Code

BLDG. #836, P & G

Rechargeable batteries (NiCad, lead-acid/gel-cell)

N/A MSDSs/User knowledge D002/D006/ D008/D009/ D011

Non rechargeable batteries;

(alkaline; mercury; Silver containing)

D002/D006/ D008/D009/ D011

Lithium batteries D003 Paint spray cans OM-CFY-836-001 D001 Glycol Waste N/A MSDS/User knowledge Various used oils N/A Burned at K-Plant

BLDG. #1332

POL-Water AMP-CFY-1332-001 Annual waste stream update if accumulated.

Unknown

BLDG. #1401, K-PLANT

Rechargeable batteries (lead-acid/gel-cell, NiCad)

N/A MSDSs/User knowledge D002/D006/ D008/D009/ D011

Rags contaminated with solvent LG-CFY-1391-007 MSDSs/User knowledge F001 Non-rechargeable batteries (Alkaline; Mercury Silver containing)

N/A MSDSs/User knowledge D009/ D011

Drained oil filter LG-CFY-1401-005 MSDSs/User knowledge D001 Lithium batteries D003 Potash generated through the burning of used oil

OM-CFY-1401-001 Annual waste stream update D006 / D007, D008

BLDG. #1408, AUXILIARY POWER

Batteries (acid) OM-CFY-1408-010 HM recycled via DRMO D002, D008 Batteries (acid non-spill able) OM-CFY-1408-011 HM recycled via DRMO D002, D008 Fuel filters LG-CFY-1408-012 Waste stream update every third year D008

BLDG. #1411, ASE

Rechargeable batteries (NiCad, lead-acid/gel-cell)

N/A MSDSs/User knowledge D002, D006, D008

Non-rec…