Atch 11 - FA2523-09-R-0001 CEV-15C Spill Prevention-Response Plan 01 July 08 Final

Contract No. FA2523-05-C-9001 Final 1 July 2008

FINAL

SPILL PREVENTION & RESPONSE PLAN

CDRL CEV-15C

Thule Air Base

OPR: GREENLAND CONTRACTORS

Chief of Environmental Engineering DSN 629-3840 ext. 2698 Supersedes CDRL CEV-15C 1 July 2007 (revised 12 Sept 2008) This edition supersedes plan submitted on 26 January 2009

CDRL CEV-15C Spill Prevention & Response Plan

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TABLE OF CONTENTS

1 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

2 INFORMATION AND EMERGENCY CONTACTS

2.1 Emergency Phone Numbers

3 GENERAL

3.1 Purpose

3.2 Scope

3.3 Facility Description

3.4 Organizational Structure

3.5 Criteria for Spill Prevention and Response Planning

3.6 Deficiencies

4 ORGANIZATIONAL ROLES AND RESPONSIBILITIES

4.1 821 ABG/CC, Installation Commander

4.2 DLO, Danish Liaison Officer

4.3 GC/SE, Occupational Safety & Health

4.4 GC Fire Protection

4.5 GC/CEE, Environmental Engineering

4.6 821 SFS, Security Forces Squadron

4.7 GC/CEOM, Operations & Maintenance

4.8 General Personnel

5 PERSONNEL TRAINING

5.1 HAZMAT Personnel Training

5.2 Spill Response Team Training

5.3 Personnel

5.4 Training Records

6 POTENTIAL SPILL SITES

6.1 Areas of Concern

6.2 Stationary Potential Spill Sites

6.3 Non-Stationary Potential Spill Sites

7 SPILL PREVENTION

7.1 General Information

7.2 Emergency Services

7.3 Facility Incident Commander (FIC)

7.4 Inventory of Potential Spill Sites

7.5 Initiatives at the Shop Level

7.6 Initiatives on the POL System

7.7 Worst Case Scenarios

8 SITE SPECIFIC CONTINGENCY PLANS

9 SPILL RESPONSE PROCEDURES

9.1 Immediate Notification and Reporting

9.2 External Notification

9.3 Additional Emergency Assistance Organizations

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10 CLEANUP ACTIONS

10.1 Probable Spill Route

10.2 Containment, Clean-up and Disposal

10.2.1 Material Safety Data Sheets

11 REPORTING AND DOCUMENTATION

APPENDICES

APPENDIX 1: DEFINITIONS

APPENDIX 2: SECONDARY CONTAINMENT METHODS

APPENDIX 3: POTENTIAL SPILL SITES

APPENDIX 4: SITE SPECIFIC SPILL ROUTE MAPS AND EVACUATION PLANS

APPENDIX 5: ASSESSMENT OF REGULATORY COMPLIANCE

APPENDIX 6: SPILL RESPONSE AREA EQUIPMENT

APPENDIX 7: GENERATORS AT THULE AB

APPENDIX 8: DISTRIBUTION LIST

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1 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

Title: The long title of this plan is “Spill Prevention and Response Plan”. The short title is SPRP, and this title will be used as reference throughout the entire document.

Classification: The document is unclassified.

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

References: References referred to in the SPRP 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 SPRP is reviewed and updated annually IAW the CDRL and distributed accordingly.

During the external ESOHCAMP in August 2006 the assessor team prepared a finding, describing that the plan was inadequate and did not include all requirements described in Chapter 18.

During the October 2007 revision most of these requirements have been fulfilled. However, expansion of the location specific spill plans (i.e. with maps and flow directions) was requested and has been completed with the present revision of the plan.

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.

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

Distribution: The plan will be distributed to the organizations shown on the distribution list in

APPENDIX 8.

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2 INFORMATION AND EMERGENCY CONTACTS

As Thule AB is a remote site, no immediate support from outside installation agencies may be expected in case of emergencies. If an emergency occurs and Thule AB is not capable of responding, 21st Space Wing must be contacted.

2.1 Emergency Phone Numbers

List of persons to be contacted in case of an emergency situation and their phone numbers:

Department: Extension

Main Base Fire Department or Ambulance 911

BMEWS Site I Fire Department or Ambulance 911

DET-3 Fire Department or Ambulance 911

821 SFS Security Forces 911

Thule Response Group 2763/2764

Civil Engineering Service Call 2111

GC Environmental Responder on Call (Service Call) 2111

GC Chief of Environmental Engineering 2698/3742

GC Safety Engineer 3250

821 SPTS/SG Medical Liaison Officer 2696

821 ABG Safety Officer 2709

821 SPTS/CE Civil Engineering 3274

Danish Liaison Officer 2612/2206

Danish Police Inspector 2406/2280

21 CES/CEANN DSN 834-7727

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3 GENERAL

3.1 Purpose

The purpose of the plan is to assure that documented guidance regarding spill prevention and response is available to all installation personnel. The plan will describe the procedures, methods, and equipment being used to prevent spills at Thule AB, as well as procedures to be followed in case of releases, accidents, and spills. The goal is to achieve a full state of awareness throughout the installation and in this way enable personnel to:

- Be familiar with spill prevention and response procedures including related regulatory requirements.

- Develop related planning documents (e.g. action plans) that will bring the installation into full compliance with regulatory requirements.

- Quickly and appropriately respond to spills in a manner that will greatly reduce or eliminate contamination, which is the overall purpose.

- Maintain a safe working environment at the installation.

3.2 Scope

The provisions of the SPRP apply throughout the whole installation and to all personnel. Certain responsibilities are specifically assigned to selected individuals identified in the plan. The SPRP limits its contents to spill prevention and response issues. Related plans have been developed to cover other functions and may need to be consulted. TABI 10-105 controls the Thule Response Group. This TABI is the overall response instruction for major spills and natural disasters.

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

US State Laws: Not applicable

USAF: AFI 10-2501, Full Spectrum Threat Response

Final Governing Standards for Environmental Protection by United State Forces in Greenland

Thule AB: EPC Decisions

Host Country: The Greenland Home Rule (GHR) Authority has the primary role for environ-mental protection in Greenland.

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3.3 Facility Description

Thule AB is located 695 miles North of the Arctic Circle (76 32' North latitude, 68 50' West longitude), and 947 miles south of the North Pole on the northwest side of the island of Greenland. It is approximately 550 miles east of the North Magnetic Pole.

The Thule Defense Area is a large land area that includes various base functions outside the Main Base area. Thule AB contains three distinct areas; the Main Base, BMEWS, and Det-3.

The areas of the base are divided into building areas designated as 100 through 900 areas. The Group Headquarters and other support functions are located in the 400 area of the base. The area identified as the goal for consolidation efforts is within the 100 and 200 areas (See Figure 4.1) together with flight line facilities in the 600 area. Also, some large facilities in the 500, 700, 800 and 900 areas, primarily with stand-alone heating systems, will remain.

Figure 4.1: Thule AB Facility Areas.

Thule AB is located in the valley of a glacially fed stream called North River. This area is designated by the Danish government as the Thule Defense Area. The Main Base is located on a relatively flat plain near the mouth of the stream. Det-3 is located 3 miles east of the Main Base and BMEWS located 12 miles northeast and 1,250 feet higher on a hill overlooking Wolsten-holme Fjord.

The base mission consists of BMEWS 12th Space Warning Squadron (12 SWS) and Detachment-3 (Det-3), 22nd Space Operations Squadron (Det-3, 22 SOPS) satellite tracking and control operation.

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3.4 Organizational Structure

The organizational structure at Thule AB involves several different organizations, including on-site USAF personnel and contractors. The on-site staff consists of military and civilian personnel from the following organizations: 821 ABG, 12 SWS, 22 SOPS DET-3, Harris Cooperation, BAE Systems, Air Greenland (GA) and Greenland Contractors (GC).

The organizations responsible for compliance with the development and implementation of the SPRP at Thule AB are summarized in the following table.

Functional Area USAF Contractor Off Site

Spill site identification and evaluation

821 SPTS/CE GC/CEE None

Secondary containment measure 821 SPTS/CE GC, BAE, HARRIS, GA None Spill response management 821 SPTS/CE GC, BAE, HARRIS, GA None Material compatibility program 821 SPTS/CE GC, BAE, HARRIS, GA None Inspection 821 SPTS/CE GC, BAE, HARRIS, GA None Preventive maintenance 821 SPTS/CE GC, BAE, HARRIS, GA None Housekeeping needs 821 SPTS/CE GC, BAE, HARRIS, GA None Pollution Prevention program 821 SPTS/CE GC, BAE, HARRIS, GA None Security 821 SFS/CC GC, BAE, HARRIS, GA None Monitoring requirements 821 SPTS/CE

821 SPTS/SG

21 ADOS/SGGB

GC, BAE, HARRIS, GA None

Training 821 SPTS/CE GC, BAE, HARRIS, GA None Plan reviews and update 821 SPTS/CE GC, BAE, HARRIS, GA None

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3.5 Criteria for Spill Prevention and Response Planning

The criteria below, from Chapter 18 of the Final Governing Standards for Greenland (FGS), have been used for this edition of the Spill Prevention and Response Plan.

FGS Chapter 18.3 Criteria, Spill Prevention and Response Planning C18.3.2 Prevention Section C18.3.2.5 Arrangements for Emergency Services C18.3.2.6 Means to Contact Emergency Services C18.3.2.7 Detailed Descriptions C18.3.2.8 Emergency Equipment C18.3.2.9 Evacuation Plan C18.3.2.10 Description of Deficiencies C18.3.2.11 Written Procedures C18.3.3 Spill control C18.3.3.5 Roster for personnel C18.3.3.6 Notification of the Facility Installation Commander (FIC) C18.3.3.7 Assignment of Responsibilities C18.3.3.8 Surveillance Procedures C18.3.3.9 Prioritized list if applicable C18.3.3.10 Other resources-include copies of agreements C18.3.3.11 Cleanup Methods C18.3.3.12 Disposal Procedures C18.3.3.13 General Health, Safety, and Fire prevention C18.3.3.14 Public affairs section C18.3.4 Reporting Section

3.6 Deficiencies

The current Spill Prevention and Response Plan has the following deficiencies in relation to the requirements of the FGS:

Site specific plans for potential spill sites:

Indoor organizational tanks in buildings 241, 1401, 1702 and 4016 should have site specific spill plans, including availability of spill control equipment and alarms. These plans will be included in the next revision of the plan (November 1, 2009)

Missing information on liquid hazmat quantities in buildings 555 and 604:

Due to the annual cycle defined by the Port Season at Thule AB, liquid quantities stored at these locations vary. Maximum amounts will be researched and included in the next revision of the plan in (November 1, 2009)

FGS 18.3.2 requires a list of all emergency equipment at each site where this equipment is required. These lists are provided in appendices 5 and 6 but do not include two 125,000 gal tanks (facility 4027 and 4028 at the BMEWS site). This deficiency will be corrected in the next revision of the plan in (November 1, 2009)

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4 ORGANIZATIONAL ROLES AND RESPONSIBILITIES

It is the responsibility of the personnel mentioned below to publish the procedures necessary for implementing this plan. Such procedures shall ensure adequate training of personnel and implementation of environmental protection and pollution abatement procedures in their areas of responsibility. The personnel will designate additional project officers and monitors as required ensuring an effective program. These designated individuals will continuously inspect the work areas under their individual areas of responsibility. The names and telephone numbers of the project officers and monitors will be posted in prominent locations at potential spill sites.

4.1 821 ABG/CC, Installation Commander The Installation Commander exercises the overall responsibility for the management of spill prevention and response planning at Thule AB. The 821 ABG/CC is the chairperson of the Environmental Protection Committee (EPC).

All notifications to the DLO and/or external offices must be accomplished by or coordinated with the Installation Commander prior to execution.

The Installation Commander, or designated representative, is the Incident Commander. The Incident Commander is responsible for directing and coordinating all spill response actions within Thule AB. The Incident Commander will have the authority to utilize the expertise and resources of the Spill Response Team (SRT), or any other office of expertise in determining and performing response actions.

4.2 DLO, Danish Liaison Officer

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

4.3 GC/SE, Occupational Safety & Health

This office will evaluate all safety procedures associated with a spill incident.

4.4 GC Fire Protection

The Fire Department at Thule AB is first responder to all incidents. Its responsibilities include responding, containing and assessing all incidents to ensure that the scene is a safe and controlled incident site. It is the Fire Chief’s responsibility to designate an entry control point based on the incident situation. The Fire Chief or Assistant Fire Chief on duty is the Facility Incident Commander (FIC).

4.5 GC/CEE, Environmental Engineering

GC/CEE has the responsibility of managing the Thule AB SPRP. In a spill situation, GC/CEE is tasked to assist the Incident Commander or Fire Chief in evaluating the situation and provide guidance in spill containment, cleanup actions and restoration activities. If the spill exceeds the reportable quantity for the specific spilled material according to the FGS, GC/CEE must notify 21 CES/CEANN within 24 hours. GC/CEE will manage a record of all spills at TAB.

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4.6 821 SFS, Security Forces Squadron During a spill situation, the Security Forces will:

- Evacuate personnel from the scene, if needed, based on the decisions of the Incident Commander or the Fire Chief.

- Secure the area as “Off Limits” to unauthorized personnel.

- Coordinate the movement of specific personnel to assist at the incident scene.

- Direct traffic.

4.7 GC/CEOM, Operations & Maintenance

The Spill Response Team (SRT) consists of designated members mainly from the Fuels Operation section, but personnel from other shops can also be appointed. The task of the SRT is to respond to spills when requested by the Incident Commander or the Fire Chief in order to perform spill containment, recovery, disposal, and restoration activities.

The SRT at TAB is limited in equipment and training, and is therefore not able to respond to all types of incidents. Peterson AFB will be contacted for assistance in case of an emergency that Thule AB is not equipped or otherwise able to respond to.

4.8 General Personnel

Each individual working at Thule AB including all seasonal contractors are tasked to report any spills to the Alarm Center ext. 911 and to take every reasonable precaution to prevent spills.

The Alarm Center will report all spills to GC/CEE.

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5 PERSONNEL TRAINING

The personnel involved in spill response actions can be divided in two groups; HAZMAT personnel and the Spill Response Team (SRT). The HAZMAT team is the personnel who initially will respond to any spill situation and get it under control. The SRT will be notified by the Incident Commander or the Fire Chief and requested to initiate cleanup actions when the incident scene is considered under control and safe to enter, using appropriate personal protection if needed.

5.1 HAZMAT Personnel Training

The training requirements for the HAZMAT personnel are provided in the AFI 10-2501, Full Spectrum Threat Response. The training must be given initially with annual refresher training through exercises.

- First Responder Awareness

- First Responder Operations

- First Responder Technician

According to AFI 10-2501, Full Spectrum Threat Response the HAZMAT personnel may not require technician level training.

Response drills occur through participation in USAF incident drills. A list of the organizational positions that are participating in the drills are listed in section 5.3 below.

5.2 Spill Response Team Training

In order to provide the SRT with the skills needed to handle a spill situation, the training should include:

- General awareness and function specific training to enable the employee to recognize and identify hazardous materials.

- Safety training concerning emergency response information, measures to protect the employee from the hazards associated with hazardous materials, and methods and procedures for avoiding accidents.

- Proper training in using the Spill Response Equipment.

The requirements for the SRT training is not specified in the AFI 10-2501, Full Spectrum Threat Response, but should as a minimum include: safety and health training, personal protective equipment training and decontamination procedure training.

GC Environmental Engineering provides this training quarterly as a one-day course “Hazardous Material Handling”.

This training will be based on MSDS information on the general chemicals present at Thule AB and on site-specific conditions.

If respiratory protection is used during cleanup actions, only personnel trained in accordance with SI.02.15.02.007 will be placed on the cleanup team. This training can be obtained through GC/SE, Occupational Safety and Health.

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5.3 Personnel

Personnel that may be involved in spill response actions (including drills) consist of:

Spill Response Team (GC/OPS) HAZMAT Personnel (GC/AMFO) Incident Commander Security Forces Civil Engineering (GC/CE) Operations (GC/OPS) Civil Engineering QAE (821 SPTS/CE) Environmental Engineering (GC/CEE) Base Health Director (GC Health Services) Safety Engineer (GC/SE)

5.4 Training Records

To ensure proper training records are maintained, supervisors must annotate AF Form 55 in the employee folder for each employee who has received training.

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6 POTENTIAL SPILL SITES

In order to initiate spill prevention and prepare for any spill response, it is important to realize and identify the spill scenarios that are possible at Thule AB. In addition, it is important to know what areas in particular are concerns according to section 6.1.

The identification of the potential spill site is based on site-specific conditions and surveys.

6.1 Areas of Concern

- Coastal Waters: The North Star Bay and Wolstenholme Fjord are very vulnerable areas in case of POL (petrol, oil and lubricant) spills during the tanker operations, or release of POL elsewhere at Thule AB. A spill may result in potential damage of the Arctic environment around Thule AB.

- Streams, rivers and Lakes: The many streams and rivers flowing through Thule AB lead to coastal waters, therefore any spill in these streams and rivers will eventually end up in the coastal waters. Of all the lakes in the area, Lake Crescent must especially be protected from any pollution, as this lake is used as TAB’s primary supply of potable water.

- Soil and Vegetation: In high Arctic areas, natural degrading of contaminated soils happens very slowly due to the harsh conditions. A spill may therefore ruin an area if this area is not properly cleaned up and reestablished.

6.2 Stationary Potential Spill Sites

The potential spill sites in stationary facilities at Thule AB consist of POL bulk storage tanks and piping as well as chemicals (hazardous materials and wastes) stored inside buildings. The potential spill sites from the POL storage tanks are listed in Appendix 3. A list of buildings holding large amounts of chemicals (hazardous materials and wastes) are provided in Appendix 3, which also contains tables for the regulatory compliance for all major POL tanks at Thule AB (Appendix 5). The tables can be used as reference material for the data on POL tanks.

6.3 Non-Stationary Potential Spill Sites

At Thule AB, the non-stationary potential spill sites consist of transportable tanks and the vehicle fleet including trucks, heavy equipment, and airplanes. The potential spill hazards include POL used for running the machinery and the cargo that is carried by the machinery.

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7 SPILL PREVENTION

7.1 General Information

A facility description and map for TAB is available in section 3.3. Vulnerable water resources include the North Star River, the North Star Bay, Wolstenholme Fjord and Lake Crescent. Lake Crescent is a critical water resources as the lake supply Thule AB with potable water.

The Thule Defense Area does not support activities unrelated to the military operations and recreational activities for base personel.

7.2 Emergency Services

Emergency services will be contacted by telephone. The 24 hours number is 911. Fire protection and medical services are contracted with Green Contractors. Access control will be carried out by the base Security Forces.

7.3 Facility Incident Commander (FIC)

The FIC at Thule AB is the Fire Chief.

Name Title Responsibility Telephone

DP / HP

Aage Johansen Fire Chief Facility Incident Commander First Responder

3249 / 3149

Henrik B. Ulbjerg Asst Fire Chief, Operations Alternate FIC First Responder

2477 / 2676

Flemming Kanto Asst. Fire Chief, Operations

Alternate FIC First Responder

2589 / 3715

Henrik W. Simonsen Asst. Fire Chief, Operations

Alternate FIC First Responder

2589 / 2501

The duty of the FIC and/or Assistant Fire Chief of Operations (AFCO) is to evaluate the spill situation and provide guidance in spill containment, clean-up actions and restoration activities.

GC/CEE is tasked to assist the FIC and/or AFCO.

The FIC and/or AFCO will normally assume point of contact and act as Incident Commander until the area is safe and will:

Relay grid coordinates for the incident site to the Consolidated Communications Center

(CCC).

Establish appropriate cordons.

Establish Entry Control Points (ECP).

In case of fire, call additional fire fighting equipment and position personnel and equipment UPWIND if possible.

In case of fire, a report will be submitted IAW AFI 32-2001.

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If and when more fire fighting equipment is needed, the FIC/AFCO will determine so upon arrival at the spill area.

Oil and water absorbent compound will be used to absorb the fuel and then be removed to a safe place. If foam is used, it must be cleaned up as soon as the hazardous condition is neutralized.

If there is no fire, and the spill is neutralized e.g. by covering with foam, Fire Protection's role is limited to standby actions. Fire fighting vehicles will not be used to remove or wash oil and hydraulic fluid spills. The operation will be given to the agency responsible for recovering and decontamination of the spill. Agency and time will be annotated in the CCC logbook.

7.4 Inventory of Potential Spill Sites

Potential POL spill sites are listed in Appendix 3, Tables A-E. Potential hazardous material spill sites are listed in Appendix 3, Table F. Maps of potential spill sites with flow directions are given in Appendix 4. site-specific procedures should be maintained at each site on the facility where significant spills could occur.

There are no potential spill sites for pesticides or PCB containing oil on Thule AB, as these materials are not used or stored at the installation. A complete PCB survey is expected to be completed by November 1, 2008; evidence points to PCB being limited to cables and electronic components. Previous analytical results indicated that PCBs in cables are below the 50 ppm threshold. Thus, PCBs in cables is not an issue.

7.5 Initiatives at the Shop Level

At the shop level and for the day-to-day work assignments, all supervisors and superintendents, as well as personnel specifically appointed to work with hazardous materials, are provided “Chemical Hazard Communication Training”. This training provides the personnel with an understanding of how to safely handle hazardous materials, and how to read and understand Material Safety Data Sheets. All personnel handling hazardous waste receive “Hazardous Waste Handler Training”. The “Chemical Hazard Communication Training” and the “Hazardous Waste Handler Training” emphasize how to use the proper spill kits, in case of small spills that can be handled by the shop personnel without requiring assistance from the Fire Department.

7.6 Initiatives on the POL System

The fuel distribution system within Fuels Management has been replaced from 1999 to 2004.

Cluster 1 from 1955 remains unchanged and is in good condition. The Cluster serves as back up for the new Hydrant System at Bldg. 614. The current plan is to demolish Cluster 1.

For the fuel distribution system, the following changes have occurred:

• All bulk storage tanks at the North Farm have been refurbished and new dikes estab-lished with double liner secondary containment.

• Piping running from the pier through the North tank farm, to Power and Heating Plants, to Truck Fill stand and Hydrant System, has been replaced.

• Truck Fill stand and Aviation Hydrant System, including 25K gal hydrant tanks have been refurbished. Dike with double liner secondary containment is installed.

• 20 plus bulk storage tanks have been demolished.

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• Future initiatives include a leak detection system for all pipes and an automatic water drainage system to remove water from the tank bottom. The project design is complete, funding for the construction project has been postponed until further notice.

• As part of a Delong Pier renovation project scheduled for FY-09 the fuel pipelines will be replaced.

Funding for upgrading older single-walled organizational tanks is not available as no legal driver for secondary containment exists for tank with a capacity of less than 50,000 gallons in the FGS.

Work on an alternative driver is in progress.

Refurbishing and replacement of transportable tanks is ongoing. Two types of transportable tanks will be available, for stationary mobile equipment during projects and mobile tanks complying with ADR and DOT standards. The new program for transportable tanks is the responsibility for transportation, and maintenance of the tanks under one shop. Furthermore, the personnel transporting the tanks must be certified IAW ADR.

7.7 Worst Case Scenarios

A disaster scenario at Thule AB would be if the tanker that delivers POL to Thule AB during the summer experienced a significant spill. Thule AB does not currently have the capacity to employ a boom or otherwise contain such a spill. Pumps are available to recover fuel from the ocean surface.

In case a weather warning for high wind speeds is issued the fuel transfer will be aborted temporarily. This minimizes the risk for a spill under conditions where the POL will enter open water fast and thus prevent outside assistance to arrive in time to avoid an environmental disaster.

A critical failure of a Bulk Storage Tank could potentially release more than 2 million gals. of fuel.

The procedure for containing such an event would be to pump the spill from the secondary containment to an empty bulk storage tank. There are currently no level alarms installed at the Bulk Storage Tanks at Thule AB. The probability for such a failure is very low.

At the present time there is no designated storage capacity to accommodate very large spills (i.e. from bulk storage tanks or oil tanker). BST 34 will be emptied of its current content of drained fuel product (tank bottoms) and designated as emergency storage capacity. Tank bottom will then be stored in POL water tanks at the tank farm north.

BST 34 can act as emergency storage capacity if the project WWCX100111, UPGRADE SECONDARY CONTAINMENT BST 34, FAC 30034, CWE $2,500,000, is initiated and completed. This project is to install secondary containment berm at BST 34 with an impervious liner to meet FGS C9.3.2.1 requirement for secondary containment.

A failure of one or both of the bulk storage tanks at BMEWS would endanger the Wolstenholme Fjord. The tanks are protected by secondary containment IAW the FGS and the probability for such a failure is very low.

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8 SITE SPECIFIC CONTINGENCY PLANS

A contingency plan is a plan prepared for specific areas where hazardous materials and/or POLs are stored indoors and/or used (excluding outdoor POL tanks). The purpose of such a plan is to address worst-case scenarios for accidental discharge.

The HWAP/HWSA managers or the shop supervisors also develop contingency plans. The plans should be posted in readily accessible areas at the applicable potential release sites so that it can be used by the personnel initially discovering a release to initiate containment procedures and by the Incident Commander to provide assistance in directing release response actions.

At a minimum, the information in a contingency plan should include:

- The evacuation procedures to be initiated in the event of a release.

- The initial release response actions that should be taken by individual(s) discovering a release. These actions should include all relevant release response and notification pro-cedures, along with the location of valves and pump controls that could stop the release, as well as the location of, and procedures for using any readily available release response equipment, such as fire extinguishers, absorbents, and drain plugs.

- The requirement that applicable Material Safety Data Sheets (MSDSs) be kept available.

- A list of special notification requirements and procedures including phone numbers.

The contingency plans will be inspected during annual visits from Environmental Engineering and quarterly inspections of HWAPs.

FGS 18.3.2 requires a list of all emergency equipment at each site where this equipment is required. These lists are provided in appendices 5 and 6. Potential spill sites listed in Appendix 3 not mentioned in these appendices do not have any emergency equipment associated specifically to them.

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9 SPILL RESPONSE PROCEDURES

9.1 Immediate Notification and Reporting

If a spill is of such a nature that the personnel on site cannot handle it, the following actions will be taken immediately:

• Restrict all sources of ignition

• Check causes and stop source of spill if possible without undue risk of personal injury

• Evacuate the area

• Notify the Alarm Center ext. 911

• Make the spill scene “Off Limits” to unauthorized personnel

When notifying the Fire Department, the following information should be provided:

• Name of individual reporting spill

• Location of spill

• Number of injured personnel and nature of injuries

• Substance spilled

• Amount spilled (estimated)

• Rate substance currently leaking (estimated)

• Time spill occurred (estimated)

• Extent to which the spill has traveled

• Any pertinent information (e.g. other potential hazards)

Small Spill (< 1 gal.):

If the spill is small and can be handled by the shop personnel, actions to respond, control and clean up the spill will be initiated. If a spill kit is used in the spill response action, this must be properly disposed of in accordance with the Hazardous Waste Management Plan or guidance provided by GC/CEE.

GC/CEE must immediately be notified. GC/CEE keeps a file with all the reported spill incidents at Thule AB irrespective of the size of the spill.

Medium Spill (1 gal. – 25 gal.):

If the shop personnel can handle the spill, the above guidelines shall be used.

If the spill cannot be handled or occurs in areas of concern, the personnel on site will take the following action:

Notify the Alarm Center ext.: 911, who notify Security Forces, Fire QAE, Fuels QAE, 821

SPTS/CE, 821 ABG/SE, 821 SPTS/CC, GC/AMF, GC/CEE, GC/CE, GC/OMUFM.

Area of Concern: Coastal Waters (North Star Bay and Wolstenholme Fjord), streams, rivers and lakes, soil and vegetation that cannot be properly cleaned up and reestablished.

GC/CEE must notify 21 CES/CEANN if the spill occurs in an area of concern. All reporting must be coordinated with 821 SPTS/CE and the Installation Commander.

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Large Spill (> 25 gal.):

The personnel on site will take the following action:

Notify the Alarm Center ext.: 911, who notify Security Forces, Fire QAE, Fuels QAE, 821

SPTS/CE, 821 ABG/SE, 821 SPTS/CC, GC/AMF, GC/CEE, GC/CE, GC/OMUFM.

GC/CEE must notify 21 CES/CEANN and all reporting will be coordinated with 821 SPTS/CE and the Installation Commander.

The reporting method to 21 CES/CEANN is by email.

Hazardous substance All Hazardous substance that exceeds the quantities in the FGS, table AP1.T4, must be reported to 21 CES/CEANN; reporting method is by email.

Files of all spills must be documented in the CEE office. When CEE is notified of a spill the CEE office will issue a “Memo for Record Spill” within 24 hours. The CEE Superin-tendent or alternate will approve the report and submit it to 821 ABG, DLO and/or 21

CES/CEANN.

The Memo for Record must contain the following items

• Name of installation

• Date and time of incident

• Actual damage or potential threats to human life, property, and plant or animal life

• Location of incident and the nature of the terrain

• Cause of incident

• Type and estimated amount of pollutant

• Corrective action to remove pollution source

• Assistance required

• Estimated completion date of remedial actions

• Anticipated or actual reaction by the news media and public to the incident

• POC

9.2 External Notification

GC/CEE must immediately notify and submit CDRL FU-3 IAW CDRL Distribution List when:

• The spill exceeds the reportable quantity (100 gallons for POL products). The reportable quantity for other chemicals is indicated in the Final Governing Standards (FGS), Appendix 1, Table AP1.T4

• A spill occurs inside Thule AB and cannot be contained within any required berm or secondary containment

• A water resource has been polluted

• The Incident Commander determines that the spill is significant

Additionally, GC/CEE will notify 21 CES/CEANN in case of an incident that Thule AB is not capable of responding to. The information that must be given includes:

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• Name of installation

• Date and time of incident

• Actual damage or potential threats to human life, property, and plant or animal life

• Location of incident and the nature of the terrain

• Cause of incident

• Type and estimated amount of pollutant

• Corrective action to remove pollution source

• Assistance required

• Estimated completion date of remedial actions

• Anticipated or actual reaction by the news media and public to the incident

• POC

• GC/CEE will prepare and distribute CDRL FU-3 using the format in AFI 23-201 Sup 1, App. 11

• For spills larger than 100 gallons notify IAW Environment Incident Investigation

Board (EIIB) Procedure Policy Memo (HQ AFSPC/A7CV Policy P06004V). Letter of November 7, 2007 waives the requirement to report sewage spills smaller than 110 gallons

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9.3 Additional Emergency Assistance Organizations

A major peacetime accident may occur involving POL and/or hazardous materials. Actions required may range from simple suppression to highly complex and time-consuming operations with international and/or political implications. It is recognized that response may also be required to accidents occurring outside the Thule Defense Area. However, such responses must be coordinated through the Thule AB Danish Liaison Officer using appropriate Greenlandic and Danish official channels (Grønlands Kommando). Further details of actions to be taken during major peacetime accidents, including base evacuation, are outlined in Thule CEMP 10-2.

Additional emergency assistance or information may be required during or after a spill incident.

For this purpose, the following list contains contact numbers for various offices that may be of assistance. Contact to these offices will occur through 821 ABG/CC.

Name of Organization Assistance Available Telephone Number U.S. Forces Scott AFB or MAJCOM Additional Communication Support DSN 576-1110 (opr) HQ AFSPC Airlift Support Scott AFB Air Force Rescue Coordination Center (AFRCC)

Airlift Support DSN 576- 4815/16/17/18/19 Commercial: (618) 256- 4815/16/17/18/19

Elmendorf RCC, Elmendorf AFB, AK

Emergency contact DSN 517 522-5375

Keflavik RCC Keflavik NAF, Iceland Emergency contact DSN 450-5007/08 or USAF Keflavik Command Post DSN 450-5000

Air Force Civil Engineering Services Agency (AFCESA)

Technical guidance and assistance DSN 970-1110

USAF Occupational and Environmental Health Laboratory

(OEHL)

Sampling and analytical support for a complex spill

DSN 240-3305

Chemical Transportation Emergency Center (CHEMTREC)

24-hour hot line warnings and limited guidance to OSC when spill product can be identified by either chemical or trade name

US 1(800) 424-9300

Environmental Technical Information Systems (ETIS)

State and federal regulations Directories of federal and state contracts

DSN 970-6167

Oil and Hazardous Materials Technical Assistance Data System

(OHMTADS)

Computerized information on various hazardous substances

US 1(800) 424-8802

Canadian Forces Halifax RCC, Nova Scotia, Canada Emergency contact DSN 447-8200/2100/2102

RCC Comm. DSN 447-

Edmonton RCC, Alberta Canada Emergency contact DSN 620-4402/4403 Commercial:(405) 973-

Note: Edmonton RCC has primary responsibility for Canadian SAR in Northern Canada. They maintain a SAR response team on 24-hour alert.

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Name of Organization Assistance Available Telephone Number Trenton RCC, Ontario Canada Emergency contact DSN 827-3870/3875

(RCC) DSN 827-3765

(ATOC)

CFS Alert Emergency contact DSN 627-8011 ext. 201 via Ottawa operator

Danish Forces GLK (Grønlands Kommando) Contact through DLO

Emergency Contact DSN 268 3840 ext.2612

Others Greenland Fire Protection, Nuuk Ro-Clean Spill Boom, similar to

Thule AB Spill Boom Commercial: 32 10 56

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10 CLEANUP ACTIONS

When a spill incident is under control and it is safe to enter the spill area, it is very important to initiate containment and cleanup actions as quickly as possible to limit the damaging effects on the arctic environment.

10.1 Probable Spill Route

A major concern in a spill situation is the spill route. It is important as quickly as possible to determine if any vulnerable area might be adversely affected, e.g. coastal waters or Lake Crescent. If this is the case, the containment and cleanup actions must be emphasized here in order to avoid or reduce the damage of such areas. Site specific spill flow prediction maps for individual locations are included in appendix 4 of this plan.

10.2 Containment, Clean-up and Disposal

The Incident Commander or Fire Chief will notify the Spill Response Team (SRT). The SRT performs the cleanup with assistance from appropriate personnel if deemed necessary. Prior to any cleanup action all personnel participating must be briefed about the hazards associated with the spilled material and the personal protection equipment to wear if needed.

Depending on the spill situation, various actions for containment and cleanup actions may be initiated:

• POL can be reclaimed e.g. by pumping the POL into a secondary containment

• Temporary dikes can be constructed to contain and control POL spills (see Appendix 2)

• The cleanup operation can be accomplished using spill absorbent materials

• Polluted soil can be removed and handled at a later time

10.2.1 Material Safety Data Sheets

The SRT must be familiar with the hazards associated with the specific materials and what kind of personal protection equipment is needed prior to the cleanup action. Fire Chief, GC/SE and GC/CEE will evaluate the need for personal protection equipment based on the Material Safety Data Sheet (MSDS) information and the site-specific conditions.

In any spill situation, the containment and cleanup actions must be coordinated with the Incident Commander or the Fire Chief, the SRT and Environmental Engineering personnel.

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11 REPORTING AND DOCUMENTATION

GC/CEE keeps a file with all the reported spill incidents at Thule AB irrespective of the size of the spill. If a spill exceeds the reportable quantity, GC/CEE must notify 21 CES/CEANN, within 24 hours. All reporting must be coordinated with 821 SPTS/CE and the Installation Commander prior to execution.

The report must include the following information:

• Name of installation

• Date and time of incident

• Actual damage or potential threats to human life, property, and plant or animal life

• Location of incident and the nature of the terrain

• Cause of incident

• Type and estimated amount of pollutant

• Corrective action to remove pollution source

• Assistance required

• Estimated completion date of remedial actions

• Anticipated or actual reaction by the news media and public to the incident

• POC

The spill reports in the GC/CEE file dates back to 1989.

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APPENDICES

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APPENDIX 1: DEFINITIONS

ADR - Europe. Agreem./Internet. Carriage of Dangerous Goods by Road.

BAE – British Aerospace Engineers

Chemical name - Scientific designation of a chemical in accordance with the nomenclature system developed by the International Union of Pure and Applied Chemistry (IUPAC) or the Chemical Abstracts Service (CAS) rules of nomenclature, or a name that will clearly identify the chemical for the purpose of conducting a hazard evaluation.

CHEMTREC - Chemical Transportation Emergency Center: operated by the Chemical Manufacturers Association to provide information or assistance to emergency responders.

CHEMTREC contacts the shipper or producer of the material for more detailed information on the chemical released to facilitate response and cleanup actions.

CHEMTREC maintains technical information files on over 300,000 proprietary chemicals. During emergencies, CHEMTREC can provide information regarding the effects of most chemicals on persons or the environment and suggest methods for treatment, containment, and control of an incident. CHEMTREC also maintains a directory of experts and industry assistance teams that can assist in an emergency. CHEMTREC can be reached 24 hours a day (1-800-424-9300).

DOT – Department of Transportation

EPC – Environmental Protection Committee

Emergency Response - The response to any occurrence that results in or is likely to result in a release of a hazardous substance due to an unforeseen event.

Environment - Water, air, and land, and the interrelationship, which exists among and between these and all living things.

Facility - Any building, structure, installation, equipment, pipe or pipeline (including any pipe into a sewer or publicly owned treatment works) well, pit, pond, lagoon, impoundment, ditch, landfill, storage container, motor vehicle, rolling stock, or aircraft, or any site or area where a hazardous substance has been deposited, stored, disposed of, or placed, or otherwise come to be located; but does not include any consumer product in consumer use or any vessel. For the purpose of the emergency release notification, the term includes motor vehicles, rolling stock, and aircraft.

FGS - Final Governing Standards for Greenland

GC - Greenland Contractors

Hazard Communication - The Occupational Safety and Health department instructions requires employers to communicate risks from hazardous substances to workers in regulated facilities.

Hazardous Chemicals - All chemicals that constitute a physical hazard or a health hazard.

HAZMAT – Hazardous Material Team

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Health Hazard - Chemical for which there is statistically significant evidence (based on at least one study conducted in accordance with established scientific principles) that acute or chronic health effects may occur in an exposed human population.

HM - Hazardous Material. Any material or combination of materials that pose a substantial actual or potential hazard to human health or living organisms. Materials considered to be hazardous are listed in the FGS, Appendix A.

HW - Hazardous Waste. Any waste or combination of wastes that pose a substantial actual or potential hazard to human health or living organisms. Wastes considered hazardous are listed in FGS, Appendix A.

HWAP – Hazardous Waste Accumulation Point

HWSA – Hazardous Waste Storage Area

MAJCOM - Major Command

Mitigation - Activities to alleviate the effects of a major disaster or emergency; or long-term activities to minimize the potentially adverse effects of future disasters in affected areas.

MSDS - Material Safety Data Sheet compilation of the health, flammability, and reactivity hazards of a chemical. It is a legal document, required by the FGS, Chapter 5. Each MSDS contains information about safe handling of a hazardous chemical in the workplace and recommended exposure limits.

MOU - Memorandum of Understanding

NFPA - National Fire Protection Agency

Oil Spill - A reportable spill of oil as defined by the FGS, Chapter 18. Occurs when a release of oil results in applicable state water quality standards being violated or when the spill causes a film, sheen, or discoloration on the surface of a navigable water or adjoining shoreline, or causes a sludge or emulsion to be deposited beneath the surface of the water or upon an adjoining shoreline.

Incident Commander (OSC) - Official who directly commands and allocates local resources and supervises all local operations at the scene.

OSH - Occupational Safety and Health

Physical Hazard - Chemical for which there is scientifically valid evidence that it is a combustible liquid, a flammable gas, explosive, flammable, an organic peroxide, an oxidizer, pyrophoric, unstable reactive, or water reactive.

Placard - Required on all four sides of all transport vessels, displaying UN class code and four-digit identification number for contained hazardous material within an 11-inch diamond.

POC – Point of Contact

POL - Petroleum, Oil and Lubricants

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Potential Spill Site - A potential spill site under the plan is any oil or hazardous substance facility including any building, structure, installation, equipment, pipe, or pipeline (including any pipe into a sewer or publicly owned treatment works), well, pit (including fire training pit), pond, lagoon, impoundment, ditch, landfill, storage container, motor vehicle, rolling stock, or aircraft (except consumer products in consumer use such as residential housing areas) that could potentially experience a spill or release. Spills or releases of reportable quantities at installations in foreign countries should be reported to MAJCOM.

Release - Any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing into the environment (including the abandonment or discarding or barrels, containers, and other closed receptacles) of any hazardous chemical, which enters the environment.

Reportable Quantity (RQ) - The reportable quantity established in the FGS, Appendix A and for POL in the FGS, chapter 18.5.3.2.

SPRP – Spill Prevention and Response Plan

SRT - Spill Response Team

Thule AB - Thule Air Base

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APPENDIX 2: SECONDARY CONTAINMENT METHODS

Secondary containment is the physical containment or capture of a spill to prevent its release to the environment.

This is accomplished by physical structures such as dikes, curbs, depressed areas, storage basins, sumps, drip pans, liners, and double-walled piping. While these systems are flexible, their effectiveness is related to the volume, type, and location of material spilled. For areas with a potential for large spills, dikes and depressed areas are normally constructed. For process areas and small storage areas (in addition to dikes and depressed areas), curbs, sumps, drip pans, double-walled pipes, and sewage collection systems (usually in combination with oil and water separators) are often used.

When secondary containment at the spill site is impractical, flow diversion and remote secondary containment should be practiced.

This consists of trenches, drains, curbs, berms, graded pavement, gratings, overflow structures, sewers, and culverts used to direct a spill to a remote secondary containment facility where the spill can be sufficiently detained prior to its collection or treatment. Holding or storage basins, ponds, and lagoons are typically used for remote secondary containment. When small quantities of floating material are involved, permanently installed oil booms and weirs with oil baffles can be installed in ditches and small waterways as remote secondary containment.

In designing and evaluating secondary containment, the following factors must be addressed:

- The construction material of the containment must be impervious to, and compatible with, the spill substance. Concrete, asphalt, and clay are the most common materials.

- Secondary containment exposed to rain must be able to accommodate maximum spill quantity plus storm water.

- Drainage from diked storage areas or other forms of secondary containment will be pumped away.