Atch 05 - FA2523-10-R-0002 CEV-15B Hazardous Waste Management Plan 1 July 2009 Final

Contract

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No. FA2523

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GREENLAND

Chief of Envir

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CDRL CEV-

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ATTACHMENT 5

CDRL CEV-15B Hazardous Waste Management Plan

Thule Air Base 3 01 July 2009

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):

4.2 Listed Waste:

4.2.1 F-list (F001-F005)

4.2.2 K-list:

4.2.3 P-list

4.2.4 U-list:

4.3 Waste Mixtures

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 4 01 July 2009

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 HANDLING PROCEDURES

APPENDIX 5: TURN-IN DOCUMENTS

APPENDIX 6: EMPTY CONTAINER MANAGEMENT FOR HWSA

APPENDIX 7: LOGBOOKS FOR HWSA

APPENDIX 8: INSPECTION CHECK LIST FOR HWAP/HWSA

APPENDIX 9: CLOSURE PLAN

APPENDIX 10: DRUM / SMALL ITEM SHEET

APPENDIX 11: NEW HWAP CHECK LIST

APPENDIX 12: 2009 REVIEW COMMENTS

APPENDIX 13: DISTRIBUTION LIST

Thule Air Base 5 01 July 2009

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 13.

Thule Air Base 6 01 July 2009

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

Thule Air Base 7 01 July 2009

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 8 01 July 2009

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 Greenlandic Government (GG) 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 situation 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 (AFI 32-7086, Hazardous Materials Management (HAZMART)).

3.7 GC Environmental Engineering, GC/CEEE

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.

Thule Air Base 9 01 July 2009

• 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 include:

• 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 have received hazardous waste handling training.

It is the obligation of any generator of Hazardous Waste to allocate the needed facility and manpower. This includes the time required for participation in training courses.

Contractors, including short term contractors, typically work at Thule AB during the summer.

Training these contractors to meet all requirements of this plan will be accomplished during orientation/pre-construction meetings by the Chief of Environmental Engineering or alternate.

GC will support contractors with basic services such as labels, spill kits etc. If a contractor generates hazardous waste, weekly inspections will be conducted.

Thule Air Base 10 01 July 2009

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 11 01 July 2009

Outdated HM being stored for use and maintained beyond its shelf life, or due to a mission change, is no longer required. Thule AB normally downgrades this type of material to hazardous waste and it must be turned in to the DRMO as such. This is according to guidelines from DRMO, Norfolk who no longer has the capacity to handle HM and to ensure the HM to be used or resold. The only items shipped as HM are batteries from cars, trucks, UPS etc. that will be recycled.

4.1 Characterization of Waste

There are four Hazardous Waste characteristics. If a waste exhibits one or more of the four 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

4.1.1 Ignitable Waste (D001):

A solid waste exhibits the characteristic of ignitability if a representative sample of the waste has any of the following properties:

• It is a liquid, other than an aqueous solution containing less than 24 percent alcohol by volume and has a flash point less than 60°C (140°F), as determined by a Pensky-Martens Closed Cup Tester, using the test method specified in ASTM Standard D-93-79 or D-93-80 or a Setaflash Closed Cup Tester, using the test method specified in ASTM Standard D-3278-78 or as determined by an equivalent test method.

• It is not a liquid and is capable, under standard temperature and pressure, of causing fire through friction, absorption of moisture or spontaneous chemical changes and, when ignited, burns so vigorously and persistently that it creates a hazard.

• It is an ignitable compressed gas as determined by appropriate test methods or USEPA.

• It is an oxidizer.

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

Thule Air Base 12 01 July 2009

4.1.2 Corrosive Waste (D002):

Waste is corrosive if:

• It has a pH of less than 2

• It has a pH of greater than 12.5

• It is a liquid and corrodes steel (SAE 1020) at a rate greater than 6.35 mm (0.250 inch) per year at a test temperature of 55°C (130°F) as determined by the test method specified in NACE (National Association of Corrosion Engineers) Standard TM-01-69 as standardized in "Test Methods for the Evaluation of Solid Waste, Physical/Chemical Methods”

Strong acids such as battery acid and hydrochloric acid

Bases such as 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. A solid waste exhibits the characteristic of reactivity if a representative sample of the waste has any of the following properties:

• It is normally unstable and undergoes violent change readily without detonating.

• It reacts violently with water.

• It forms potentially explosive mixtures with water.

• When mixed with water, it generates toxic gases, vapors, or fumes in a quantity sufficient to present a danger to human health or the environment.

• It is a cyanide or sulfide bearing waste which, when exposed to pH conditions between 2 and 12.5, can generate toxic gases, vapors or fumes in a quantity sufficient to present a danger to human health or the environment.

• It is capable of detonation or explosive reaction if it is subjected to a strong initiating source or if heated under confinement.

• It is readily capable of detonation or explosive decomposition or reaction at standard temperature and pressure.

• It is a forbidden explosive.

Unexploded Ordenance (UXO) and flares

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.

Thule Air Base 13 01 July 2009

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 14 01 July 2009

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 are certain unused acutely hazardous commercial chemical products. These are rarely found on Thule.

Special chemicals such as medical supplies

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.

Chemicals such as acetone, ethyl ether, and methanol

Thule Air Base 15 01 July 2009

4.3 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.

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 16 01 July 2009

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.

An HWAP may be used to accumulate no more than 55 gallons of hazardous waste, or 1 quarter 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. Must accumulate no more than 208 liters (55 gallons) of hazardous waste, or 1 liter (1 quarter) of acute hazardous waste4, from each waste stream.

3. The hazardous waste generator must identify a primary and an alternate HWAP manager.

An appointment letter must be sent to GC Environmental Engineering, Fire Protection and DRMO. The appointment letter has to be renewed within 30 days 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. Each HWAP must be designed and operated to provide appropriate segregation for different waste streams, including those, which are chemically incompatible.

6. 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 17 01 July 2009

7. Signs:

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

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

• Each HWAP will have warning signs (National Fire Protection Association or appropriate international sign) appropriate for the waste being accumulated at that site.

8. 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.

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

10. When amounts in paragraph 5.1.1.2 are met or the container is 90% filled, the container must be transferred to a HWSA within five working days. 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. Emergency telephone or radio must be available at or near the HWAP (i.e. a phone in a nearby office is sufficient).

17. Appropriate spill absorbent for the waste stored.

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

19. The HWAP must be orderly and not contain items or materials that are not hazardous waste (exception: the accumulation of drainable batteries for recycling is permitted in bldg.

580 even though the batteries are considered Hazardous Material and not waste).

20. The Hazardous Waste Management Plan must be accessible at the HWAP.

21. The HWAP must be inspected at least once every quarter by GC Environmental Engineering.

22. The schedule for inspection of well managed HWAPs can be reduced by GC Environmental Engineering to two times per year.

23. FGS C6.3.5, Recordkeeping Requirements must be met.

24. FGS C6.3.5, personal training requirements must be met.

25. FGS C6.3.5.1, (Turn-in documents) requirements must be met.

26. FGS C6.3.5.5, (Manifests) requirements must be met.

27. FGS C6.3.5.6, (Waste Characterization) requirements must be met.

Thule Air Base 18 01 July 2009

5.1.2 Documentation for the HWAP

1. Training records for all HWAP managers and POCs must be available.

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

3. Inventory for all items in the HWAP.

4. Turn-in documentation (forms DRMS 1348-1A and DD 1930 and analysis results/MSDS information for recurrent waste stream/waste characterization) for the last three years must be kept on file at the DRMO office, bldg. 935.

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:

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

• Bldg #552 and nearby yard – HW pending analysis. The Yard is used for HW from special activities and products (e.g. transformers pending analysis for PCB). Operated by

DRMO.

• Bldg. #935 - Central HWSA

• Yard outside Bldg. #580 - Inactive

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 who 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 19 01 July 2009

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 be 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 20 01 July 2009

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 21 01 July 2009

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, e.g. D001)

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: Date of sampling

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 22 01 July 2009

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 or waste oil truck

“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

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Thule Air Base 24 01 July 2009

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 6.

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.

8. Contact GC/CEE for funding.

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 25 01 July 2009

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 26 01 July 2009

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. A notification is sent to the supervisor/ superintendent when a course is scheduled. The training must be conducted by qualified trainers who have completed an instructor training program in the subject, have comparable academic credentials, or experience.

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 27 01 July 2009

APPENDICES

Thule Air Base 28 01 July 2009

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 29 01 July 2009

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 30 01 July 2009

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

LIST OF RECURRING INDUSTRIAL GENERATED HAZARDOUS WASTE STREAMS

Type of Waste Waste Stream

Code Sources (facility number) Disposal

Oil Rags HWAP-01 563, 580, 606, 1391, 1401, 4002 DRMO Rags with Solvent HWAP-02 113, 571, 580 DRMO Used Adsorbent HWAP-03 Basewide DRMO Empty Aerosol Spray Cans

HWAP-04 Basewide DRMO

Batteries, Misc. HWAP-05 Basewide DRMO Flourescent Light Bulbs HWAP-06 Basewide DRMO Paint (oil-based) HWAP-07 571, 801 DRMO Paint (latex) HWAP-08 571, 801 DRMO Paint related material (Thinner)

HWAP-09 571, 580, 801 DRMO

Aerosol filter (paint can puncture)

HWAP-10 580 DRMO

Used oil filters vehicle HWAP-11 580 DRMO Used fuel filters, vehicle HWAP-12 580 DRMO Drained fuel filters, fuel operations

HWAP-13 1401 DRMO

Drained oil filters, power production

HWAP-14 1401 DRMO

Antifreeze, non-recoverable

HWAP-15 580 DRMO

Potash, used oil incineration

HWAP-16 1401 DRMO

Break Fluid HWAP-17 580 DRMO PCB ballasts, solid HWAP-18 551 DRMO Old Mercury Switches HWAP-19 551 DRMO Dry Cleaning Sludge HWAP-20 237 DRMO Lead Solder HWAP-21 113 DRMO Medical Supplies past expiration date

HWAP-22 118 DRMO

Dentist Waste (amalgam)

HWAP-23 118 DRMO

Thule Air Base 31 01 July 2009

Type of Waste Waste Stream Code

Sources (facility number) Disposal

Radioactive Smoke Detectors

HWAP-24 113 DRMO

Construction Materials (Asbestos)

ASB-01 Basewide Asbestos Landfill

Other Materials (Asbestos)

ASB-02 Basewide Asbestos Landfill

Contaminated soil, volatile fuel

SOIL-01 Basewide Disposal site section A (landfarming)

Contaminated soil, machine oil and similar.

SOIL-02 Basewide Disposal site section B (landfarming)

Contaminated soil, lubricants

SOIL-03 Basewide Disposal site section C (landfarming)

BST, Tank bottoms POLW-01 Tank Farm North Incineration, K-plant BST, Tank rinsate POLW-02 Tank Farm North Oil-water separator POL water, spill incidents

POLW-03 Basewide Oil-water separator

Break Pad Washing Water (vehicles)

POLW-04 580 DRMO

Washing ramp water, vehicles

POLW-05 Basewide Oil-water separator

POL water, oil-water separator maintenance

POLW-06 Basewide Oil-water separator

Oil-Water Separator Sludge

POLW-07 Basewide DRMO

Waste oil, recyclable (Oil water separators)

POLW-08 Basewide Incineration, K-plant

Waste Oil, Recycable (Accumulated)

POLW-09 Basewide Incineration, K-plant

Waste Fuel, Reclaimable

POLW-10 604, 614, 617, 1307 Ground Fuel

Used Hydraulic Oil POLW-11 563, 580, 604 DRMO

Waste from different sources that is part of the same waste stream may be mixed prior to disposal. When DRMO is listed as disposal method the waste is annually shipped to Norfolk, Virginia as hazardous waste.

Batteries (HWAP-05)

The waste stream consists of collected batteries of mixed types. The HWSA manager sorts the batteries, turn them in to the DRMO, and secure them against short-circuiting prior to shipping.

The following battery waste streams are established in the HWSA:

Rechargeable gel cell batteries (HWAP-05A)

Alkaline batteries (HWAP-05B)

Thule Air Base 32 01 July 2009

Lithium batteries (Li-SO2) (HWAP-05C)

Rechargeable nickel-cadmium (NiCad) batteries (HWAP-05D)

Mercury batteries (HWAP-05E)

Silver batteries (HWAP-05F)

Drainable batteries are recyclable and are treated as HM and turned in as such. Only batteries which are not recycled must be managed as HW.

Contaminated Soil (SOIL-01, SOIL-02 and SOIL-03)

A protected area west of hangar 1 and 2 has been selected for contaminated soil disposal. Here the soil is awaiting landfarming projects. The disposal site is divided into 4 sections

Section A is used for soil contaminated with volatiles such as diesel fuel or gas.

Section B is used for soil contaminated with non-volatile oil such as machine oil and sand from oil water separator sand traps.

Section C is used for soil contaminated with lubricants such as hydraulic oil, gear oil etc.

Section D is reserved for contingency storage of a large amount of soil.

When disposing contaminated soil it typically happens after a spill incident. The date and type of spill is noted and the pile identified with GPS coordinates in an inventory that is being maintained in GC Environmental Engineering. No disposal will occur without the approval of GC Environmental Engineering.

Oil water separators

Various POL water waste streams are disposed by means of an oil water separator. The POL part is incinerated at the K-Plant and the water is discharged IAW with The Storm Water Management and Slug Management Plans.

Incineration, K-Plant

Used oil and other…