Atch 06 - FA2523-10-R-0002 CEV-15D Pollution Prevention Management Plan 1 July 2009 Final

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ATTACHMENT 6

CDRL CEV-15D Pollution Prevention Management Plan

Thule Air Base 3 01 July 2009

TABLE OF CONTENTS

1.0 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

2.0 INTRODUCTION

2.1 Background

3.0 US AIR FORCE P2 PROGRAM GOALS, OBJECTIVES AND STRATEGIES

4.0 THULE AB P2MAP METHODOLOGY AND ORGANIZATION

4.1 Baseline Survey

4.2 Opportunity Assessment

5.0 THULE AIR BASE P2MAP ORGANIZATION

5.1 Management Tasks

5.2 Pollution Prevention Projects

6.0 POLLUTION PREVENTION MANAGEMENT PLANS

6.1 Ozone Depleting Chemicals

6.2 Industrial Toxins

6.3 Hazardous Waste

6.4 Municipal Solid Waste

6.5 (Green) Affirmative Procurement of Environmentally Friendly Products

6.6 Energy Conservation

6.6.1 Electricity

7.0 WATER

8.0 AIR AND WATER POLLUTANT REDUCTION

8.1 Air Pollutant Reduction

8.2 Water Pollutant Reduction

8.2.1 Secondary Containment

8.2.2 Wastewater Treatment

9.0 ACRONYMS

APPENDIX 1: ENVIRONMENTAL PROJECT LIST

APPENDIX 2: PROJECTS RELATED TO ENERGY CONSERVATION

APPENDIX 3: 2009 REVIEW COMMENTS

APPENDIX 4: DISTRIBUTION LIST

Thule Air Base 4 01 July 2009

1.0 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

Title: The title of this document is “Pollution Prevention Management Plan”. The acronym P2P will be used throughout the document.

Classification: The document is unclassified.

Responsibilities: Greenland Contractors, Environmental Engineering (GC/CEE) is the office of primary responsibility for developing and maintaining the P2P. The instruction given in this plan is applicable to all organizations and tenant units at Thule AB. Organizations are authorized to extract and reproduce those sections of the P2P that are essential in the accomplishment of necessary planning and in the preparation of supporting document and reports.

Reviews/Changes: The P2P will be reviewed and updated annually IAW the CDRL and distributed accordingly. A draft is submitted to the requiring office, 21 CES/CEANN, by 1 Nov for review.

Review comments, if any, will be provided by 21 CES/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 is altered.

Distribution: The P2P will be distributed to the organizations listed in the distribution list, APPENDIX 4.

Thule Air Base 5 01 July 2009

2.0 INTRODUCTION

2.1 Background

In accordance with the U.S Air Force Instruction (AFI) 32-7080, Pollution Prevention Program, dated 12 May 1994 and Executive Order (E.O.) 13423—Strengthening Federal Environmental, Energy, and Transportation, this document represents the P2P for Thule AB, Greenland. The Air Force Center for Environmental Excellence (AFCEE) published an Installation Pollution Prevention Program Guide (July 1994) that served as the framework for developing this plan.

Pollution prevention (P2) is an approach to management of hazardous material (HM) and release of pollutants into the environment. P2 emphasizes eliminating or, less preferably, reducing the introduction of HM into the industrial processes, opposed to the former “end-of-pipe” treatment approach. Also, P2 is not disposal through other environmental media; it is not a “trading” of wastes between the air, land, or water.

The hierarchy for implementing P2 actions, from highest to lowest priority, is as follows:

Source Reduction: Reduce or eliminate dependence on HM and reduce waste streams

Recycling: Reuse generated waste or recycle waste that is not reusable

Treatment: Treat waste to render it less harmful, and

Disposal: End-of-pipe management

At Thule AB, source reduction is done as part of the review of projects by Environmental Engineering and the hazmat approval process (section 6.5).

AFI 32-7080 requires bases to have a Qualified Recycling Program (QRP). Thule AB does not have such a program and recycles only a few high-value wastes (aluminium and copper scrap metal and car batteries are recycled via DRMS). Glycol recovery units are being used to recycle product and used oil is burned for energy recovery at the K-plant. An initial assesment report on QRP on Thule AB was prepared by TetraTech in 2008. The QRP requirement of AFI 32-7080 is excluded from the BMC.

At Thule, the options for treatment are very limited. Oil/water separators.can be used to obtain waste for incineration from water-rich POL/water mixtures.

All disposal of hazardous material as hazardous waste takes place through the Defense Reutilization Marketing Office (DRMO).

The Thule AB P2MAP presents specific projects that, when implemented, will meet the U.S. Air Force (USAF) P2 goals for the following program elements:

1. Ozone-Depleting Chemicals (ODC): Protect the earth’s stratospheric ozone layer by eliminating dependence on chlorofluorocarbons (CFCs), halons, and other substances.

2. EPA Industrial Toxics Project 17 Targeted Chemicals (EPA-17): A list of 17 high priority toxic pollutants targeted for reductions by the U.S. Environmental Protection Agency (EPA). http://www.epa.gov/history/topics/programs/01.htm. While the EPA-17 program is outdated it is still referenced in AFI 32-7080.

3. Hazardous Waste (HW): Minimize HW generated by industrial, maintenance and cleanup operations and strive to reduce HW generation at the source.

Thule Air Base 6 01 July 2009

4. Municipal Solid Waste (MSW): Implement cost-effective MSW reduction and recycling programs with an emphasis on source reduction.

5. Affirmative Procurement (AP): Implement an AP program in accordance with the Resource Conservation and Recovery Act (RCRA) Subtitle F, E.O. 13423, and EPA guidelines.

6. Energy Conservation (EC): Implement EC measures as a means to prevent pollution in accordance with E.O. 13423

7. Air and Water Pollutant Reduction: Reduce emissions of pollutants to air and water.

Thule Air Base 7 01 July 2009

3.0 US AIR FORCE P2 PROGRAM GOALS, OBJECTIVES AND

STRATEGIES

Specific goals have been established for each of the seven USAF P2 program elements. Although individual installations may have unique circumstances with regard to meeting the USAF P2 goals, several common objectives can be set to provide compliance with P2 requirements:

• Management Commitment: Installation management support is essential for a successful P2 program. Support is most effectively demonstrated by a formal written policy promoting the P2 program as the first priority for environmental management, addressing continued support, and relying on managers and supervisors to achieve the P2 goals.

• Program Structure: Responsibilities need to be defined at the installation level. At Thule AB, the Thule Base Maintenance Contract (Thule BMC) will be responsible for implementing a majority of the P2 program. This will require a baseline survey to fully implement the program. A 5-year timetable is set for the full implementation of the program and a baseline survey.

• Training Program: The P2 program will only be successful if a comprehensive training program is instituted for senior management personnel, supervisors, and industrial workers.

• Incentive Program: The installation should develop a program to solicit suggestions to improve the P2 program, provide awards for effective P2 initiatives, and promote recognition through installation publications.

Well-defined strategies have been identified to meet the USAF P2 goals. The structure of the Thule AB P2MAP addresses each strategy:

• Establish installation baselines for each P2 program goal

• Conduct opportunity assessments

• Implement the MAP:

- Identify and implement management tasks to establish installation of P2 program

- Document and rank P2 projects, and

- Submit P2 project budget requests

• Monitor and report project progress

Thule Air Base 8 01 July 2009

4.0 THULE AB P2MAP METHODOLOGY AND ORGANIZATION

4.1 Baseline Survey

Establishing an accurate baseline is critical for future evaluation(s) of the P2 program and the success in meeting each program goal. The baseline must be a careful determination of the level of waste generated during a defined baseline year. The information needed to establish accurate baselines for the various P2 categories must be collected, correlated, and evaluated. This requires review of records for all operations, waste disposal records, contractor records, and industrial processes throughout the installation, interviews with personnel and additional investigations required to attempt to fill in any resulting information gaps.

The baseline data for Thule AB were developed from a survey conducted by Midwest Research Institute (MRI) in June 1993 (MRI, 1994). The baseline information, published as the Final Data Report for Thule AB, Greenland, May 1994, includes actual data from 1992, estimates from 1992, and “some information with a less definite time base reflecting current operations”. The data for each USAF goal (ODC, EPA-17, HW, MSW, AP, and EC) obtained from this study will be used as the baseline to measure the effectiveness of:

- (1) Current P2 initiatives already implemented at Thule AB and

- (2) P2 projects (and, to a lesser extent, best management practices [BMPs] identified as part of the opportunity assessment (OA))

4.2 Opportunity Assessment

The method used to identify P2 process improvements or options is referred to as an Opportunity Assessment (OA). This effort assesses all pollutant sources, examines material usage and waste generation by type and volume, and determines the most practical and economical options for reduction. This generally involves examining each process involving a targeted pollutant to determine ways to avoid use or generation of that substance. The OA includes a review of existing installation plans such as the Hazardous Waste Management Plan and Solid Waste Management Plan which identify waste streams. Additional detailed baseline information characterizing material use and waste streams for each process may be gathered concurrently with the assessment process.

Trained installation personnel, contractors, and/or Major Command (MAJCOM) teams may perform OA. The OA team members at Thule Air Base are representing Environmental Engineering, Occupational Safety and Health, Supply, and Engineering. The OA team members will be selected from some of the following listed subjects:

1. Involve people who work directly with the processes and materials of concern. They are most familiar with practices and probably know where changes can be made.

2. Involve members from other organizational elements that may be affected by changes in procedures or practices. Contact your customers - involve other shops and offices.

3. Include people with a wide variety of backgrounds to gain different perspectives and approaches to problem identification and problem solving.

4. Involve suppliers or potential suppliers, if possible. Seek their advice - they are generally looking for new customers or expanded sales and can offer sound advice.

Thule Air Base 9 01 July 2009

The OA is due for an update. This will be based in part on the waste streams identified in the Hazardous Waste Management Plan. The existing documentation for other sources of polution is outdated. For example, the most recent comprehensive survey of air emission pollution prevention is from 1999. MAJCOM assistance will be requested to update the opportunities for pollution prevention and projects identified to obtain the required information to perform such an assessment.

Thule Air Base 10 01 July 2009

5.0 THULE AIR BASE P2MAP ORGANIZATION

5.1 Management Tasks

Development of a P2 program includes implementing a number of management tasks that are ne-cessary to facilitate the P2 process. The tasks are divided into the following categories:

• Policy: Relates to developing internal policies and procedures and defining and assigning roles and responsibilities.

• Inventory Control: Addresses establishing reliable data on HM usage and accurate docu-mentation of installation processes. This information is fundamental to meeting the USAF P2 reduction goals by familiarizing installation personnel with HM use and waste streams and by identifying processes that should be targeted for future P2 opportunities.

• Process: Addresses conducting recurring OAs, identifying priority projects, developing funding requests, planning project implementation, and reporting.

• Training: Addresses developing and implementing a P2 training plan.

5.2 Pollution Prevention Projects

Thule Air Base Initiatives

The USAF Installation Pollution Prevention Program Guide defines information and data for planned P2 projects. Several P2 projects have been planned at Thule Air Base for 2007-2015 and are identified and described in APPENDIX 1.

6.0 POLLUTION PREVENTION MANAGEMENT PLANS

6.1 Ozone Depleting Chemicals

The primary goal in the area of Ozone Depleting Chemicals/Substances is to help protect the earth’s stratospheric ozone layer by eliminating dependence on chlorofluorocarbons, halons, and other substances. The Copenhagen-amended Montreal Protocol (1992) included an accelerated production phase-out schedule with production to cease halons by the end of 1993 and chlorofluorocarbons, carbon tetrachloride, and methyl chloroform by the end of 1995. The Clean Air Act Amendments of 1990 and EPA rules limit United States’ consumption and production of chemicals listed in Table 1.

Thule AB must eliminate the purchases of ODS. In 1992, Thule AB purchased 1,068 lb. of ODS.

Recycled ODS and ODS for mission-critical applications may still be obtained under specified conditions. Because the ODS goal calls for mandatory elimination in purchases, a project's return on investments does not play a role in scheduling projects for implementation.

The following are actions MAJCOMs will take to help eliminate the Air Force’s dependence on and eliminate release of ozone depleting chemicals:

6.1.1 Prohibit the purchase of all Class I ozone-depleting chemicals listed in Table 1 (unless approved by a waiver).

6.1.2 Prohibit the purchase of halons fire extinguishing equipment and ozone depleting chemical air conditioning and refrigeration equipment for ground applications.

6.1.3 Modify operating, training, and testing practices and implement conservation measures such as recovery, recycling, and reuse measures to reduce atmospheric discharges.

Thule Air Base 11 01 July 2009

Table 1:

Class I Ozone Depleting Substances under the Clean Air Act and AFI 32-7086.

Substances marked with italics are only required by the Final Governing Standards for Greenland (FGS, July 2003).

Halocarbon Number

Molecular Formula

Name

CFC-11 CCl3F Trichlorofluoromethane CFC-12 CCl2F2 Dichlorodifluoromethane CFC-113 C2Cl3F3 Trichlorotrifluoroethane CFC-114 C2Cl2F4 Dichlorotetrafluoroethane CFC-115 C2ClF5 Chloropentafluoroethane Halon 1011 CH2BrCl Bromochloromethane Halon 1202 CBr2F2 Dibromodifluoromethane Halon 1211 CF2ClBr Bromochlorodifluoromethane Halon 1301 CF3Br Bromotrifluorometnane Halon 2402 C2F4Br2 Dibromotetrafluoroethane CFC-13 CClF3 Chlorotrifluoromethane CFC-111 C2Cl5F Pentachlorofluoroethane CFC-112 C2Cl4F2 Tetrachlorodifluoroethane CFC-211 C3Cl7F3 Heptachlorofluoropropane CFC-212 C3Cl6F2 Hexachlorodifluoropropane CFC-213 C3Cl5F3 Pentachlorotrifluoropropane CFC-214 C3Cl4F4 Tetrachlorotetrafluoropropane CFC-215 C3Cl3F5 Trichloropentafluoropropane CFC-216 C3Cl2F6 Dichlorohexafluoropropane CFC-217 C3ClF7 Chloroheptafluoropropane Carbon Tetrachlo-ride

CCl4 Tetrachloroethane

Methyl Chloro-form

CHCl3 Trichloroethane (all isomers)

Methyl Bromide CH3Br Bromomethane

Thule Air Base 12 01 July 2009

Table 2:

Class II Ozone Depleting Substances under the Clean Air Act and AFI 32-7086.

Substances marked with italics are only required by the Final Governing Standards for Greenland (FGS, July 2003).

Halocarbon Number

Molecular Formula

Halocarbon Number

Molecular Formula

HCFC-21 CHCl3F HCFC-224 HCFC-22 CHClF2 HCFC-225 HCFC-31 CH2FCl HCFC-

225CA

HCFC-121 C2HCl4F HCFC-

225CB

HCFC-122 C2HCl3F2 HCFC-226 HCFC-123 C2HCl2F3 HCFC-231 HCFC-123b CGFCl2CF3 HCFC-232 HCFC-124 C2HClF4 HCFC-233 HCFC-124b CHFClCF3 HCFC-234 HCFC-131 C2H2Cl3F HCFC-235 HCFC-132 C2H2Cl3F HCFC-241 HCFC-133 C2H2ClF3 HCFC-242 HCFC-141 C2H3Cl2F HCFC-243 HCFC-141b CH3CFCl2 HCFC-244 HCFC-142 C2H3ClF2 HCFC-251 HCFC-142b HCFC-252

HCFC-151 HCFC-253

HCFC-221 HCFC-261

HCFC-222 HCFC-262

HCFC-223 HCFC-271

Table 3:

Account of Class I Ozone Depleting Substances.

Class I Baseline Current

ODS Product Chem. formula April 1997 September 2009 Lbs ODS Lbs ODS

Halon 1211 CF2ClBr 4200 5750

Halon 1301 CF3Br 4254 0

R12 CCl2F2 2491 284

Total Class I 10945 6034

ODS, Class I decrease/baseline - 45%

Compliance with AFI 32-7086 - (NO)

Thule Air Base 13 01 July 2009

Table 4:

Account of Class II Ozone Depleting Substances

Class II Baseline Current

ODS Product Chem. formula April 1997 September 2009 Lbs ODS Lbs ODS

R22 CHF2Cl 1609 1024

R502 49% CHClF2 (R22) 51% CClF2CF3 (R115) 1064 0

R401a

= MP39)

53% CHF2Cl (R22) 34% CHFClCF (R124) 13% CH3CHF2 (R152a) 0 176

Total Class II 4646 1200

ODS, Class II decrease/baseline - 74%

Compliance with AFI 32-7086 - YES

Class I: IAW AFI 32-7086, Para 4.1.1, TAB is not “in compliance” regarding production and use of Class I ODS. The aforementioned paragraph states that all Class I ODS production effectively ended 31 December 1995. In 1995, the U.S. Air Force collected and stocked “their own” supply of Halons. Halon at TAB is only found in the flight line extinguishers (15 ea), as the USAF has not identified a suitable product that can replace the Halons. Quarterly, Fire Protection submits data on the Halons on supply to Engineering that is responsible for reporting to Peterson AFB (CDRL CEO- 2). During the annual fire drills/exercises, the content of the Halon extinguishers are substituted with water. It has been years since Halons was last used at TAB. IAW AFI 32-7086 the procure-ment/trade of Class I ODC is done through Peterson AFB (the USAF’s own stock).

Class II: TAB is in compliance phasing out the Class II ODC; production must be reduced by 35 % by 01 January 2004 and 65% by 01 January 2010.

6.2 Industrial Toxins

AFI 32-7080 implements the EPA’s 17 Industrial Toxics program as part of its Pollution Prevention Program. The EPA’s 17 industrial toxics listed in Table 5 are specifically targeted for reduction.

The EPA-17 covers a broad spectrum of toxics, many of which are volatile organic compounds.

These compounds are commonly found in fuels, paints and solvents.

The EPA-17 program has been replaced by newer programs of EPA; the current list of priority chemicals can be found on http://www.epa.gov/osw/hazard/wastemin/priority.htm and contains 31 different chemcals. However, the AFI 32-7080 continue to reference the EPA-17 program.

Furthermore, the Final Governing Standards, Danish and US federal law prohibits the purchase of any product containing polychlorinated biphenyls (PCBs).

TAB has established a Hazmat Pharmacy. When a request for purchase is made, a Hazardous Material Request Form (AF form 3952 or similar) is forwarded to the Environmental Coordinator

Thule Air Base 14 01 July 2009 and Occupational Safety and Health Coordinator for review. If the pharmacy does not have the item in stock, the Environmental Coordinator researches chemical composition information on the material requested. If the material contains an EPA 17 listed chemical or other harmful derivative (including the most recent list of 31 chemicals), an attempt is made to find an alternative product.

This program has significantly reduced the potential for inadvertent purchase of products containing regulated compounds.

Table 5:

List of 17 priority industrial toxics identified by EPA

EPA-17 Industrial Toxics Benzene Methyl Ethyl Ketone Cadmium & Compounds Methyl Isobutyl Ketone Carbon Tetrachloride Nickel & Compounds Chloroform Tetrachloroethylene Chromium & Compounds Toluene Cyanides Trichloroethane Dichloromethane Trichloroethylene Lead & Compounds Xylene(s) Mercury & Compounds

In most cases, there are known alternatives to EPA-17 priority chemicals or products containing them. For example, electronic thermostats can be used in place of mercury-bearing switches.

Solders containing copper or silver can substitute for solder containing lead, The use of the EPA-17 chemicals at Thule Air Base is very limited. Cadmium is present as rechargeable batteries, and as they are the best rechargeable batteries replacement has turned out to be difficult. Lead solder was in 2007 substituted with lead-free solder. One product containing 55-65% lead “Garlock Style 926” is still being purchased in a small amount. The product is used for lubricating a compressor, and is required by the manufacture.

The fluorescent light bulbs at Thule AB contain mercury in different concentrations depending on the age of the fluorescent bulb. When normal maintenance or replacement is scheduled, old fluorescent bulbs with higher concentration are replaced with bulbs at a lower concentration as they are the only ones purchased. Even though mercury in fluorescent bulbs is a problem, the solution is not to stop using energy-efficient fluorescent bulbs, but to replace with more environmentally friendly bulbs.

Light fixtures manufactured before 1974 are likely to have ballasts containing PCB, and light fixtures of this type are still in use at various locations at Thule Air Base. When maintenance or upgrading of a facility is performed the ballasts are replaced. All high voltage cables installed at BMEWS before 1980 contain PCB in solid form similar to the ballasts from light fixtures. Purchase of any product containing PCB is not allowed at Thule AB.

6.3 Hazardous Waste

TAB generates limited quantities of hazardous waste (HW) as a result of maintenance and cleaning operations. TAB is responsible for categorizing HW generated, ensuring that HW is managed and stored in accordance with state and federal regulations, and all disposal shipments are in accordance with state and federal regulations. The Defense Reutilization Marketing Office (DRMO)

Thule Air Base 15 01 July 2009 is responsible for ensuring that the off-site treatment, storage, and disposal (TSD) facilities to which TAB may ship wastes are operated in compliance with RCRA.

HW such as lead acid and gel-cell batteries, spent fluorescent tubes, PCB containing electrical equipment and spent solvent are managed IAW the Hazardous Waste Management Program (CDRL CEV-15) and reported in the Hazardous Waste Report (CDRL CEV-14).

The following treatments can be applied to reduce the amount of hazardous waste

6.3.1 Treatment Technologies

The treatment technologies listed below are provided as baseline treatment/disposal technologies for the use of determining suitability of host nation disposal alternatives. These technologies should not be implemented without consultation with the Environmental Executive Agent, or the Combatant Commander, if there is no Environmental Executive Agent. All hazardous waste generated on Thule AB is currently being disposed of via DRMO/DRMS.

Fuel substitution (Organics) Units are operated so that destruction of hazardous constituents are at least as efficient, and hazardous emissions are no greater than those produced by incineration.

Biodegradation of Organics Wastes are degraded by microbial action. Such units will be operated under aerobic or anaerobic conditions so that the concentrations of a representative compound or indicator parameter (e.g., total organic carbon) has been substantially reduced in concentration. The level to which biodegradation must occur and the process time vary depending on the hazardous waste being biodegraded.

Recovery of Organics Wastes are treated to recover organic compounds. This will be done using, but not limited to, one or more of the following technologies: distillation; thin film evaporation; steam stripping; carbon adsorption; critical fluid extraction; liquid extraction; precipitation/crystallization or phase separation techniques such as decantation, filtration and centrifugation when used in conjunction with one of the above techniques.

Chemical Degradation of Organics The wastes are chemically degraded in such a manner that hazardous constituents are destroyed and harmful emissions controlled.

Stabilization or Fixation of Heavy Metals Wastes are treated in such a way that soluble heavy metals are fixed by oxidation/reduction, or by some other means which renders the metals immobile in a landfill environment.

Recovery of Heavy Metals Wastes are treated to recover the metal fraction by thermal processing, precipitation, exchange, carbon absorption, or other techniques that yield non-hazardous levels of heavy metals in the residuals.

Reactives Any treatment that changes the chemical or physical composition of a material such that it no longer exhibits the characteristic for reactivity defined in FGS Chapter 20 (Appendix 1).

Corrosives

Thule Air Base 16 01 July 2009

Corrosive wastes, as defined in FGS Chapter 20, will be neutralized to a pH value between 6.0 and

9.0. Other acceptable treatments include recovery, incineration, chemical or electrolytic oxidation, chemical reduction, or stabilization.

6.4 Municipal Solid Waste

Municipal Solid Waste is the largest fraction of waste generated at TAB. Thule AB has 12 ea 8 m3 dumpsters and 82 ea 6 m3 dumpsters. Dumpsters are emptied weekly or when necessary and transported to the landfill.

Purchasing of materials is also a way to limit wastes. Prior to purchase of materials TAB will research for health hazards, acute hazards, EPA 17 listing, and amount needed, purchasing alternatives, packaging, etc. GC/OSH has hazmat approval documents on file.

Recycling efforts have decreased the amount of solid waste refuse generated. Materials that are recycled at TAB include toner cartridges from printers and copiers, copper, aluminium, and vehicle batteries.

Opportunity Assessments will be used to research additional recycling opportunities and to map waste streams and minimize waste disposal to the landfill.

Materials used for operation and maintenance of the site are continually inventoried to ensure their complete use. Expiration dates, properly sealing containers, and using open containers completely before opening a new one are key issues. Monitoring of this area reduces the amount of solid waste generated and prevents the potential disposal of a hazardous waste in the municipal solid waste stream.

General Handling and Issue of Batteries The handling of batteries is IAW the Solid Waste Management Plan, CDRL CEV-15E and the Hazardous Waste Management Plan, CDRL CEV-15B.

Disposal of Vehicles Batteries All unserviceable batteries will be turned in through the Defense Reutilization and Marketing Office (DRMO) Section at Thule Air Base. Shipping boxes will be obtained from the DRMO Section in the quantity required. Boxes will be custom made in sizes that will hold no more than 2 layers of batteries in height and will be lined inside with heavy gage plastic. The vehicle batteries are recycled by the DRMS after shipment from Thule.

6.5 (Green) Affirmative Procurement of Environmentally Friendly Products Air Force installations are required to implement affirmative procurement programs for materials with recycled content according to Resource Conservation and Recovery Act, Subtitle F (Section 6002) and E.O. 13423, Strengthening Federal Environmental, Energy, and Transportation.

Air Force Instruction 32-7080, Pollution Prevention Program, lists the following items to be included in the Affirmative Procurement Program: paper, retread tires, building insulation, cement/concrete containing fly ash, and re-refined oils. The BMC does not reference E.O. 13423.

The U.S. General Services Administration (GSA) Federal Supply Service can be used for purchasing Affirmative products and as a guideline. GSA offers its consumers the option to purchase quality environmentally oriented products. Office items like laser/copy paper, envelopes, boxes, notebooks, index cards, labels, toner cartridges and file folders. Other items include toilet paper and paper towels, some of which are unbleached and contain 100% post-consumer materials.

Thule Air Base 17 01 July 2009

An affirmative procurement program is implemented for US purchases IAW the Thule AB BMC supply regulations. Purchase of Environmental Protection Agency (EPA) designated items through US sources complies with the Thule AB Affirmative Procurement Plan (CDRL CEV-15H).

Exceptions are justified and documented. This requirement does not apply to non-appropriated funds purchases that, if any, will be separately identified.

The TAB Hazmat Program is tasked with reviewing all hazardous material purchases. AF form 3952 or similar is used for the review. Manufacturer’s Material Safety Data Sheets (MSDS) for purchase requests are reviewed for constituents.

When a hazardous material is required in a shop, an authorization process must be initiated, if the material is not previously authorized or if the shop exceeds the authorization limit. If a shop is authorized to use a product for a specific process and the authorization limit is not exceeded, the shop is not required to consult the Occupational, Safety and Health (OSH) function for approval and authorization.

Detailed information about the EMIS system can be obtained in the Air Force Environmental Management Information System – User’s Guide and the AF-EMIS Student Handbook.

Product Evaluation The product will be evaluated within the following areas as a minimum.

• Material information

• Process information to include information such as:

- Amount of material required/requested and amount used per task

- Duration and frequency of task

- Personnel Protective Equipment

- Generation of waste

Substitution Efforts If a product causes unnecessary exposures to employees, a substitution effort will be initiated in cooperation between the shop requesting the hazardous material and the OSH function.

If a product is creating unnecessary hazardous waste or other wastes, which cannot be drained to the sanitary sewer or disposed at the sanitary landfill, a substitution effort will be initiated in cooperation between the shop requesting the hazardous material and Environmental Engineering.

Assessments within the following areas are initiated

• Occupational safety and health issues

• Technical processes

• Environmental regulations

Minimization Efforts

TAB will reduce the use of hazardous materials where practical through resource recovery, recycling, source reduction, acquisition, or other minimization strategies.

Thule Air Base 18 01 July 2009

6.6 Energy Conservation

All Air Force installations are encouraged to implement energy conservation as a means of pollution prevention according to E.O. 13423, Strengthening Federal Environmental, Energy, and Transportation.

An Air Force goal was initially set up in 1985 calling for a 10% reduction from 1985 to 1995 and later adjusted by Executive Orders in 1991 and 1994 setting new goals for federal buildings. The new goals were extended to cover the period from 1985 through 2005, calling for a 30% reduction in energy conservation. At Thule AB, these goals were achieved relatively early as a more efficient power plant (M-plant) started operating in FY-87 and the new radar was put on line in FY-87.

Thule Air Base has succeeded in decreasing the energy consumption significantly due to new technology, consolidation efforts, etc. At the end of FY-05, the Federal goal was a 20% reduction and Thule achieved a 40.4% reduction.

With the Energy Policy Act of 2005, the Congress amended the National Energy Conservation Act to establish a new Federal Energy Conservation Program for the period 2006 through 2015. This program calls for a 30% reduction by 2015 as compared with 2003.

By the end of 2006, the new Federal program called for a 2% reduction and Thule achieved a 4.0% reduction.

Energy spent on Thule AB is measured by the amount of fuel consumed (expressed in British Thermal Units = BTUs) for heating and power production. The amount of fuel is compensated for heated square footage and fluctuations in outdoor temperature. Calculations are made every month and averaged to an annual value.

The combustion sources at Thule AB consist of diesel generators, diesel emergency generators, portable diesel generators, diesel fire pumps, boilers, and furnaces. All diesel combustion units at Thule AB use JP-8 for fuel. Thule AB has aboveground storage tanks (AST) for gasoline, JP-8 and used oil.

The Energy Conservation Task Group meeting is held twice a year in April and October (ref. TABI 32-107 Utilities Management and Conservation). There are presently 19 projects related to energy conservation, which are listed in Appendix 2.

In addition to these projects, the following general Energy Conservation Proposals are recommended:

• Continue Main Base Consolidation

• Continue BMEWS Consolidation

• Install High Efficiency Lighting

• Install ON/OFF Switches

• Install Occupancy Light Switches

• Specify High Efficiency Motors

• Improve Heating Controls

6.6.1 Electricity

At Thule Air Base, light motion sensors on lighting were installed during a pilot project in 1996. The outcome of the project was 67% energy savings on corridor lighting in one dormitory (flattop). From 1997, motion sensors were installed in all flattops and several office buildings. When replacing electrical installations in flattops and offices, sensors are automatically installed.

Thule Air Base 19 01 July 2009

Streetlights were replaced in 2003 with a new energy saving system including energy saving light bulbs and a photoelectric sensor placed at Bldg. #97. The sensor is adjusted to turn off the light responding to even small amounts of daylight at the beginning of February.

During the winter season, vehicles will use 3 kW nominal hot-plugs in most places instead of idling.

Lighting throughout the site is kept at the minimum required to ensure safety of personnel.

7.0 WATER

Drinking water is used for various purposes at TAB, where the total annual water consumption is approximately 72.5 million gallons.

To reduce water consumption at TAB some major improvements are listed below:

• To prevent water pipes from freezing during the winter season, tap water is left running in many buildings due to old pipes with insufficient insulation and defect heat tracing. Cost savings by continuing replacement of black steel pipes will reduce water consumption by closing taps after use in the buildings (pipes will not freeze when insulation and heat tracing is sufficient).

• Feed water used in the heating system can be reduced by more than 50% if condensate water is returned to the heating plants.

• In an unknown number of buildings steam condensate is lead to the sewage. An attempt to minimize the losses by installing feed water pump in one building reduced the loss of condensate water from 10,000 to approximately 5,000 gallons. It is estimated that the total loss of condensate water can be brought down to only 3,500 gallons per day, which is an acceptable level.

8.0 AIR AND WATER POLLUTANT REDUCTION

8.1 Air Pollutant Reduction

Several operations at Thule AB generate air emissions in the form of criteria pollutants and hazardous air pollutants. Criteria pollutants include those compounds for which National Ambient Air Quality Standards (NAAQS) have been established and include particulate matter less than 10 microns in diameter (PM

), sulfur dioxide (SO

), nitrogen oxides (NO x ), carbon monoxide (CO), ozone (O ), and lead (Pb). Volatile organic compounds (VOC) and NO x are the regulated compounds for the criteria pollutant ozone. Hazardous air pollutants include those pollutants specifically listed by the U.S. Environmental Protection Agency (EPA) pursuant to Title III of the 1990 Clean Air Act Amendments (CAAA). The federal list of hazardous air pollutants (HAP) was included in Section 112(b) (3) of the CAAA and amended by EPA on 18 June 1996. The criteria pollutant lead is also a designated HAP.

The emission-generating activities at Thule AB can be categorized as stationary and mobile sources.

Stationary sources can emit fugitive and/or stack emissions. Fugitive emissions are those that do not pass through a stack, vent, or other functionally equivalent opening. An example is VOC loss from fuel storage tanks; the tank loses VOC through tank vents and fugitive losses occur during refueling activities. Stack emissions include units such as combustion sources (e.g., boilers and generators). This inventory also includes the use of ozone depleting substances (ODS).

The combustion sources at Thule AB consist of diesel emergency generators, portable diesel generators, diesel fire pumps, natural gas boilers, water heaters, and furnaces. All diesel

Thule Air Base 20 01 July 2009 combustion units at Thule AB use JP-8 for fuel. In addition, there is a fire fighting training area, a dry cleaning facility and a rock crusher. Thule AB has aboveground storage tanks (AST) for gasoline, JP-8 and used oil.

8.2 Water Pollutant Reduction

8.2.1 Secondary Containment

In accordance with FGS all organizational tanks containing over 50,000 gallons must be provided with a secondary containment area.

Bulk storage tanks and hydrant tanks at TAB are provided with dikes supported by a two-layer membrane and liner. The dikes were established during the period from 2000 to 2004. There is no water run off from the dikes.

Bulk storage tanks at BMEWS are provided with a secondary containment, similar to double walled tanks. Water is removed from a drain valve.

Other organizational tanks are surrounded by a dirt dike.

All new tanks are doubled walled.

Removal of dike water is carried out by CE Operations and Maintenance.

Records must be kept that indicate all water removed from containment dikes was visually inspected for the presence of contamination, typically a sheen of fuel. CEE will conduct all visual inspections and maintain the records.

Water with sheen must be vacuumed out and discharged into an oil/water separator. At the Bulk Storage Tanks (BST) on the North Tank Farm, “oil only” absorbent beam must be used around the pump wells.

If there is no visible oil film on the surface of the dike water, it is permitted to dispose of the dike water into the nearby creek, without passing it through an oil/water separator. The Tank Farm personnel must obtain approval for this procedure by CEE.

8.2.2 Wastewater Treatment

There is no wastewater treatment at TAB. To eliminate hazardous waste in the wastewater, oil and water separators are installed in the maintenance shops and hazardous material generated is collected at the Hazardous Waste Accumulation Points.

For further treatment of the wastewater, a wastewater plant is suggested and four alternatives will be able to meet the effluent demands of the Final Governing Standards.

The wastewater treatment plant is designed for a population equivalent of 1.600 PE at 10°C. The load was estimated on the background of the samples taken for characterization of the wastewater in September 2004 and of the production of drinking water.

The recommended activated sludge plant is designed for stabilized sludge, so the total sludge age in the treatment plant is greater than necessary for meeting the effluent requirements for BOD removal. In fact the plant will be able to remove part of the nitrogen as well, which makes the size of the plant more than sufficient. Therefore it is not a question of whether the plant can meet the effluent requirements during variation in load but of whether the produced activated sludge from the plant is stabilized properly.

For the design of the wastewater treatment in the detailed project phase, it is important to define the maximum load to the treatment plant by measuring the daily flow and the hourly peak flow of

Thule Air Base 21 01 July 2009 wastewater during high season at Bldg. #984. It is also important to register the variation of the temperature of the wastewater, especially during the winter, to decide the minimum and maximum temperature of the wastewater.

Removal/Precipitation of Metals

The metals in the wastewater will to an extent be precipitated/bonded to the sludge and it is therefore expected that the metal content will drop and thereby comply with the FGS on the discharge on metal containing wastewater to surface waters.

Sludge

Prior to deposit at the landfill, the sludge must be stabilized according to the FGS to ensure that odors or other nuisances do not occur. For this reason, the stabilization process is included in the wastewater treatment proposals.

It is assumed that the amount of sludge/compost produced annually does not exceed 5000 tons as mentioned, among others, in section C7.3.16 in the FGS.

The classification of the sludge as Class A or B compost with respect to the use for agricultural applications is considered to be irrelevant. If, however, the compost can be classified as Class A compost there is no restrictions on the use.

9.0 ACRONYMS

Thule Air Base 22 01 July 2009

12 SWS 12th Space Warning Squadron, Thule Air Base, Greenland 21 SW 21st Space Wing, Peterson AFB, Colorado 821 ABG 821st Air Base Group 821 SPTS 821st Support Squadron

AB Air Base AFB Air Force Base AFCEE Air Force Center for Environmental Excellence AFI Air Force Instruction AP Affirmative Procurement AST Above-ground Storage Tank

BMC Base Maintenance Contract BMEWS Ballistic Missile Early Warning System BMP Best management practice BOD Biochemical oxygen demand BST Bulk Storage Tank Btu British Thermal Unit

CAAA Clean Air Act Amendment CDRL Contract Data Requirement List CE Civil Engineering CEE Environmental Engineering CES Civil Engineering Squadron CEANN Environmental Office CFC Chlorofluorocarbon

DRMO Defense Reutilization and Marketing Organization (GC/LGDRM)

EC Energy conservation E.O. Executive Order EMIS Environmental Management Information System EPA U.S. Environmental Protection Agency EPA-17 EPA Industrial Toxics Project 17 Targeted Chemicals EPC Environmental Protection Committee

FGS Final Governing Standards FY Fiscal Year

GC Greenland Contractors GSA General Services Administration

HAP Hazardous Air Pollutants HM Hazardous Material HW Hazardous Waste

MAJCOM Major Command MAP Management Action Plan MRI Midwest Research Institute MSDS Material Safety Data Sheet MSW Municipal solid waste

N/A Not Applicable NAAQS National Ambient Air Quality Standards

OA Opportunity assessment ODC Ozone-depleting chemical

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ODS Ozone-depleting Substances OFEE Office of the Federal Environmental Executive OSH Occupational Health & Safety OPR Office of primary responsibility

P2 Pollution Prevention P2MAP Pollution Prevention Management Action Plan PCB Polychlorinated Biphenyl POL Petroleum, oils, and lubricants

RCRA Resource Conservation and Recovery Act, as amended

TAB Thule Air Base TSD Treatment, Storage, and Disposal

USAF United States Air Force

VOC Volatile Organic Compound

Thule Air Base 24 01 July 2009

APPENDIX 1: ENVIRONMENTAL PROJECT LIST

FY Project Nr Project Title Estimate (USD)

FUNDED WWCX300046 LANDFILL FACE STABILIZATION 4500000

FUNDED WWCX40-0005 IMPLEMENT CROSS CONNECTION SURVEY 64000

2010 WWCX368245 POL REMEDIATION, M-PLANT LANDFARMING 200000

2010 WWCX444410 SCRAP METAL CLEANUP

2010 WWCX999910 SIGNS ON RECREATIONAL TRAILS

2010 WWCX777710 UST CLOSURE

2010 WWCX111110 PRELIMINARY ASSESSMENT/SITE INVESTIGATION

2010 WWCX400010 QRP BUSINESS PLAN

2010 WWCX222210 TANK INVENTORY

2011 WWCX09-1014 INADEQUATE CONTAINMENT (BMEWS) 40000

2011 WWCX888811 TANK 34 REPLACEMENT

2012 WWCX111112 SITE CHARACTERIZATION/HEALTH DETERMINATION

2015 WWCX030515 ENVIRONMENTAL REVIEW Wastewater Treatment Plant 35000

- WWCX030515 P-MOUNTAIN CLEAN-UP (FUEL SPILL)

Thule Air Base 25 01 July 2009

APPENDIX 2: PROJECTS RELATED TO ENERGY CONSERVATION

WWCX 94-1010

Replace Steam/Condensate

Lines, Ph 5

Improved insulation. Phases 1, 2, 3, and 4 of this project are com-pleted. Ph. 5 is scheduled for construction in 2012. Estimated an-nual energy saving: $150,000.

WWCX 97-1014

Replace Sewage Lines, Ph 2

Improved insulation will generate energy savings. Phase 1 of this project has been completed. Phase 2 (of 4 phases) is scheduled for construction in 2014. Estimated annual energy saving: $164,000.

WWCX 07-1034

Upgrade Water Distribution, Ph 5

Improved insulation will generate energy savings. Estimated annual energy saving: $180,000. The first four phases of the project have been completed. Phase 5 (of 7 phases) is scheduled for construc-tion in 2013.

WWCX 88-0069

Repair Roofs Base Wide, Ph 4

Improved insulation will generate energy savings. This project con-sists of five phases of which the first three have been executed. The projects will improve the insulation of the roofs. Phase 4 is sche-duled for construction in 2014. Estimated annual energy saving:

$112,000.

WWCX 03-1003

Repair Heating Systems, Ph 1

The project will replace the 30-55 year old heating and ventilation systems in buildings, which we will continue to use for many years.

Improved efficiency and new controls will provide great energy sav-ings. Phase1 is scheduled for construction in 2010. The estimated annual energy saving is $300,000.

WWCX 01-1013

Replace HVAC, BMEWS

The project will alter heating, ventilation, chilled water, cooling, and heat dissipation systems in Bldg #4002 at BMEWS. Existing sys-tems are more than 45 years old and designed for no longer existing radar and computer systems. A new design is required before worn out components are replaced. Scheduled for construction in 2012.

Estimated annual energy saving: $70,000.

Thule Air Base 26 01 July 2009

WWCX 06-1297

Upgrade Flattop 252

Some of these projects provide significantly improved insulation.

Estimated annual energy saving: $20,000.Scheduled in 2013

WWCX 03-1004A

Energy Monitoring and

Control System (EMCS)

The project will provide base wide monitoring and control of ventila-tion in selected buildings, building temperatures, lighting in selected buildings, steam trap performance, and heat tracing cables on water and sewage lines. The project is a candidate for the MILCON Ener-gy Conservation Investment Program (ECIP). Scheduled for execu-tion in 2011. Estimated annual energy saving: $1,718,000. The project has also been submitted as a candidate for the AFSO21 pro-gram with execution in FY-12.

WWCX 09-1011

Replace M-Plant

Cooling Water Systems

The project will expand the existing system for recovery of waste heat in the M-Plant cooling water systems for heating hangars 9 and 10 and possibly more buildings in the close vicinity. The project is a candidate for the AFSO21 program and scheduled for execution in FY-12. Estimated annual energy saving: $1,200,000.

WWCX 06-1078B

Energy Efficient Lighting, Exit Lights PA B

The project will replace exit light fixtures using incandescent bulbs with high efficiency exit fixtures using LEDs. RM project scheduled for execution in FY-10. The project is also a candidate for the AF- SO21 program, scheduled for execution in FY-10. Estimated annual energy saving: $51,100.

WWCX 03-1004B

Energy Monitoring & Control Sys-tem (EMCS) Expansion

The project will expand the EMCS project assumed constructed in FY-10 with monitoring and controls in a large number of buildings on base. The project is a candidate for the AFSO21 program, sche-duled for execution in FY10. Estimated annual energy saving:

$1,000,000.

WWCX 03-3001

Replace Standby Power Plant, BMEWS

This is an essential project for BMEWS, as it will allow closure of Bldgs #4012 and #4016. Estimated annual savings: $134,000. Ex-ecute in 2015+.

WWCX 05-3001

Power Plant Upgrade, M-Plant

Improves M-Plant total efficiency from 50% to 75%. Estimated an-nual energy saving: $3,200,000. Execute in 2014.

Thule Air Base 27 01 July 2009

WWCX 04-3003

Consolidated Services

Facility

The project will consolidate Services facilities in a single large energy efficient building. Existing Services facilities are cur-rently scattered across base in 9 individual buildings. Esti-mated annual energy saving: $67,500. Execute in 2019.

WWCX 05-3002

Consolidated Administration

Services

The project will consolidate administrative facilities in a single large energy efficient building. Existing administrative facilities are currently scattered across base in 8 individual buildings.

Estimated annual energy saving: $30,000. Execute in 2018.

WWCX 04-3004

Fitness Center

The project will provide a new energy efficient physical fitness facility to replace the existing Fitness and Sports Center. Es-timated annual energy saving: $25,000. Execute in 2017.

WWCX 09-1067

Repair Flattop 131

This project is scheduled in FY12. Some of these projects pro-vide significantly improved insulation. Estimated annual energy saving: $20,000.

WWCX 11-3001

Enlisted Dorm,Ph 2

(Dorm MCP, PA $77,300) Will replace flattops. Estimated annuals savings: $100,000 Execute in 2014.

WWCX 12-3001

Enlisted Dorm Ph3

(Dorm MCP, PA $77,300)

Execute in 2015.

WWCX 12-3001

Enlisted Dorm Ph1

(Dorm MCP, PA $51,600)

Execute in 2016.

WWCX 14-3001

Enlisted Dorm Ph 4

(Dorm MCP, PA $81,400)

Execute in 2017.

WWCX 15-3001

Enlisted Dorm Ph5

(Dorm MCP, PA $82,800)

Execute in 2018.

WWCX 16-3001

Enlisted Dorm Ph 6

(Dorm MCP, PA $85,900)

Execute in 2019.

WWCX 17-3001 Enlisted Dorm Ph 7

(Dorm MCP, PA $85,200)

Execute in 2020.

Thule Air Base 28 01 July 2009

APPENDIX 3: 2009 REVIEW COMMENTS

Item# Office Symbol

Org Name of Commenter

Page# Para# Critical, Substantive or Administrative

Comment Rationale Accept/Modify/Reject Rationale

1 CEANN 21 CES Chase 5 2.1, 2nd para., 1st sentence

S Add to end of sentence,"and release of pollutants into the environment."

Per AFI 32-7080, Ch.2, Section 2.1 Accept Suggested text has been added

2 CEANN 21 CES Chase 5 2.1, 3nd para., S Source Reduction: change "to" to "and". Recycling: insert "generated" between "Reuse" and "waste"

Per AFI 32-7080, Ch.2, Section 2.1 Accept The suggested changes has made in…