Atch 05 - FA2523-11-R-0001 CDRL CEV-15J Slug Mgmt Plan 01 Jul 2009 Final

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ATTACHMENT 05

CDRL CEV-15J Slug Management Plan

Thule Air Base, Greenland 3/23 01 July 2009

TABLE OF CONTENTS

1 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

2 REGULATORY BACKGROUND

2.1 Purpose

2.2 Scope

2.3 Regulatory Overview

3 ORGANIZATIONS AND RESPONSIBILITIES

3.1 Installation Commander, 821 ABG/CC

3.2 Danish Liaison Officer, DLO

3.3 Occupational Safety & Health, GC/CEOSH

3.4 Civil Engineering, GC/CE

3.5 Environmental Engineering, GC/CEEE

3.6 Utilities and Facilities Maintenance, GC/OMUFM

3.7 Fire Protection, GC/AMF

4 IDENTIFICATION OF POTENTIAL SPILLS AND DISCHARGES THAT CAN

INFLUENCE THE SANITARY WASTEWATER SYSTEM

4.1 Introduction

4.2 Facility Layout of the Sanitary Wastewater System (SWWS)

4.3 Discharge Practices

4.3.1 Discharges of sanitary wastewater collected by truck

4.3.2 Water from boilers and heating system

4.3.3 Water from washing of aircrafts/vehicles

4.3.4 Water from the laundry shop

4.3.5 Water from parts washers

4.3.6 Discard of water from swimming pool

4.3.7 Intrusion of Storm Water

4.4 Storage of Chemicals, toxic organic pollutants and solvents

4.5 Floor Drains

4.5.1 Bldg. 118 – Hospital

4.5.2 Bldg. 107 – Dundas Buffet Restaurant

4.5.3 Bldg. 4016 – Power Plant, J-site

4.5.4 Bldg. 236 – TOW Club

4.6 Conclusion

5 SLUG MANAGEMENT AND OPERATIONS

5.1 Discharge Practice and Non-routine Batch Discharges

5.1.1 Practice for recurring discharges from installation

5.1.2 Discharge practice for trucked and hauled waste

5.1.3 Discharge practice for trucked sanitary wastewater

5.1.4 Intentionally non-routine batch discharge

Thule Air Base, Greenland 4/23 01 July 2009

5.1.5 Discharge of surface water to the SWWS

5.2 Handling of Chemicals and Control of Toxic Organic Pollutants and Solvents 13

5.2.1 Rooms with floor drain directly to the SWWS

5.2.2 Rooms with floor drain indirectly to the SWWS

5.3 Buildings, Containment Structures and Equipment

5.3.1 Planning of new building, containment structures and equipment

5.3.2 Inspection and maintenance of the SWWS

5.3.3 Oil/water Separators

5.3.4 Sand/Grease Traps

5.3.5 Cross Connections

5.4 Prevention of Accidental Spill

5.5 Emergency Response

5.6 Notification

5.7 Employee Training

5.8 Sludge Disposal

6 EFFLUENT MONITORING

7 WATER POLLUTION COMPLAINTS

APPENDIX 1: DEFINITIONS

APPENDIX 2: SEWAGE SYSTEM

APPENDIX 3: REVIEW COMMENTS 2009

APPENDIX 4: DISTRIBUTION LIST

Thule Air Base, Greenland 5/23 01 July 2009

1 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

Title: The title of this document is “Slug Management Plan” CDRL CEV-15J. The acronym SMP is used throughout the document.

Classification: The document is unclassified.

Responsibilities: Greenland Contractors, Environmental Engineering (GC/CEEE) is the office of primary responsibility for developing and maintaining the SMP. 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 SMP that are essential in the accomplishment of necessary planning and in the preparation of supporting documents and reports.

Reviews/changes: The SMP will be reviewed and updated annually IAW the CDRL and distributed accordingly. A draft is submitted to 21 CES/CEANN by 1 Nov for review. Review comments, if any, will be provided 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 to the organizations listed in the distribution list, APPENDIX 4.

Thule Air Base, Greenland 6/23 01 July 2009

2 REGULATORY BACKGROUND

2.1 Purpose

The purpose of this plan is to provide detailed instructions for spills and batch discharges (slugs) prevention and control for all installation personnel at Thule AB.

As the wastewater system is not constantly used for drainage of storm water, the limitations of this plan are circumstances that potentially can have influence on the wastewater system.

Circumstances related to surface water can be found in the Storm Water Management Plan, CDRL CEV-15G.

Likewise, as no wastewater treatment plant has been installed there are no possibilities to control the quality of the discharged wastewater. A control system is being implemented but not as a part of this plan.

2.2 Scope

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

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

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

• Storm Water Management Plan, CDRL CEV–15G

• Hazardous Waste Management Plan, CDRL CEV-15B

• Hazardous Material Management Plan

2.3 Regulatory Overview

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

In accordance with the Final Governing Standards for the Environmental Protection by United States Forces in Greenland (FGS-GL) 24 July 2003 C4.3.2.1.6: “Activities or installations that have a significant potential for spills or batch discharges will develop a slug prevention plan”.

The Clean Water Act (CWA) requires industrial facilities to reduce, minimize, or eliminate sources of pollution exposed to storm water runoff. The goals of the CWA are to make the rivers, lakes and streams fishable, swimmable and drinkable.

Thule Air Base, Greenland 7/23 01 July 2009

3 ORGANIZATIONS AND RESPONSIBILITIES

In order to ensure that spills and batch discharges (slugs) are handled in an environmentally correct manner, it is important that personnel are fully aware of their responsibilities in the SMP.

The following outlines responsibilities:

3.1 Installation Commander, 821 ABG/CC

The Installation Commander has the overall responsibility for the management of the SMP at Thule AB. The responsibility is implemented through the base Environmental Protection Committee (EPC), of which the Installation Commander is the chairperson. The EPC is responsible for reviewing the SMP prior to finalization of the yearly review and/or any other updates of the plan and prior to approval by the Installation Commander.

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

3.2 Danish Liaison Officer, DLO

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

3.3 Occupational Safety & Health, GC/CEOSH

The Occupational Safety & Health office performs safety and health inspections.

3.4 Civil Engineering, GC/CE

The Civil Engineering office is responsible for the establishment of procedures to ensure that GC Environmental Engineering reviews all projects. This includes the responsibility to secure that all relevant environmental information is available for the review.

3.5 Environmental Engineering, GC/CEEE

Environmental Engineering is responsible for developing, updating, and implementing the SMP.

3.6 Utilities and Facilities Maintenance, GC/OMUFM

The responsibility of GC/OMUFM stated as the Domestic Wastewater Treatment System (DWTS) in the FGS:

• Batch Discharges of trucked wastewater.

• Inspection and maintenance of the wastewater pipe system.

3.7 Fire Protection, GC/AMF

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

Thule Air Base, Greenland 8/23 01 July 2009

4 IDENTIFICATION OF POTENTIAL SPILLS AND DISCHARGES

THAT CAN INFLUENCE THE SANITARY WASTEWATER SYSTEM

4.1 Introduction

A plan for Spills and Batch Discharges is required by C4.3.2.1.6 of the FGS. Activities or installations that have a significant potential for spills or batch discharges (into the Wastewater System) will develop a slug prevention plan. Each plan must contain the following minimum requirements:

• Description of discharge practices, including non-routine batch discharges.

• Description of stored chemicals.

• Plan for immediately notifying the Domestic Wastewater Treatment System (DWTS) of slug discharges and discharges that violate prohibitions under this section, including procedures for subsequent written notification within five days.

• Necessary practices to prevent accidental spills. This would include proper inspection and maintenance of storage areas, handling and transfer of materials, loading and unloading operations, control of plant site runoff, and worker training.

• Proper procedures for building containment structures or equipment.

• Necessary measures to control toxic organic pollutants and solvents.

• Proper procedures and equipment for emergency response, and any subsequent plans necessary to limit damage suffered by the treatment plant or the environment.

4.2 Facility Layout of the Sanitary Wastewater System (SWWS)

Thule AB is situated in an area with an extremely low population density approx. 25 miles from the nearest village. The climate is high arctic desert. Due to very low temperatures, the Sanitary Wastewater System (SWWS) has unconventionally been made of insulated black steel pipes situated above ground with heat tracing.

On base, the sewage runs gravitationally through the system to Bldg. 984, where it is discharged through an underwater pipeline into the North Star Bay.

At BMEWS, wastewater is led to a septic tank, from where it is dispersed over a mountainside.

Beside the fixed SWWS, wastewater from Det-3 and Bldg. 107, 561, 563, 580, 605, 651, 754, 760, 1201, 1408, and 1411 is collected in a tank. A special truck collects the contents. The contents are discharged into the SWWS at Bldg. 984.

The majority of water led to the SWWS originates from household sources like showers, washrooms, washing clothes and kitchens. The only direct drainages from floors outside the dormitories are in Bldg. 107, 118, 236 and 4016. In all other situations, the water is by pump or manually poured into the SWWS.

No Storm Water leads to the SWWS.

Consult Appendix 2 for a diagram of the SWWS on the main base.

Thule Air Base, Greenland 9/23 01 July 2009

4.3 Discharge Practices

The main discharges made to the SWWS are what can be expected for at place where 700 people are living and with some craftsman-like activities but without any industrial activities.

The discharges – recurring or not recurring are:

4.3.1 Discharges of sanitary wastewater collected by truck

Some of the wastewater is transported by truck, as mentioned in section 4.2.

4.3.2 Water from boilers and heating system

On main base, the primary source of heating originates from a system of high-pressure steam that is produced in three different places: Bldg. 1391, 241, and 341. Due to high levels of impurities in the boiler water, it is necessary to replace the water and discharge to the SWWS.

To prevent corrosion, a number of additives are used and subsequent discharged into the

SWWS.

Further heating is produced on low-pressure systems at Bldg. 1401, 1824 and 4016. From those places, only small amounts of boiler water are expected to be discharged to the SWWS – primarily in case of maintenance of the systems.

4.3.3 Water from washing of aircrafts/vehicles

Aircrafts are not washed at Thule AB, except for the small helicopter operated by Air Greenland.

The helicopter is washed in HG-4 (Bldg. 606), where the water is led through an oil/water separator to the sewage system.

Vehicles are washed at the following facilities: Bldg. 580, Bldg. 836, Bldg. 622, and Bldg. 1408 plus an outdoor wash ramp near the harbor (no facility number assigned). In all facilities, the waste is led through to an oil/water separator. From there the water is discharged through the sewage system for all facilities except for the outdoor wash ramp near the harbor, where the water is discharged directly to the North Star Bay and at Bldg. 836, where the water is led through an oil/water separator to the Storm Water Drainage System.

One oil/water separator is located at the Crash Fire Rescue Training Facility at Perimeter Road.

The oil/water separator is only operated when the Fire Department performs aircraft crash exercises. Used fire water is led through the oil/water separator to the Storm Water Drainage System.

Another oil/water separator is included in the mobile Brita filter system.

Finally, two oil/water separators are non-functional and abandoned. They are located at Bldg.

2405 and at the Tank Farm South.

The problem related to vehicle washing is, that emulsifying soap will disperse the oil and water – hereby removing the intended effect of the gravitational oil/water separator. Additionally the water from washing of cars will have a large content of suspended material.

During ESOHCAMP in August 2009, finding WWM-004 was identified for use of Simple Green (emulsifying soap). The use of Simple Green is discontinued for all waters going into an oil/water

Thule Air Base, Greenland 10/23 01 July 2009 separator. Thule AB is in the process of identifying and purchasing a non-emulsifying soap. In the interim vehicles are cleaned only with water.

4.3.4 Water from the laundry shop

In the laundry shop, Bldg. 237, clothes are rinsed or washed. The rinsing process is designated as a dry-cleaning process, where methylene chloride is used. Residuals from the rinsing process are required to be treated as hazardous waste and collected for disposal to ensure nothing is introduced to the SWWS.

Conventional detergents are used for the washing process. Water from the washing process is led to the SWWS directly from the machines. In case of spillage, the water will be recovered in a drain, from which the water will be pumped to the SWWS.

4.3.5 Water from parts washers

At Thule AB, there are 2 parts washers. They are located in Bldg. 580 and 4016.

The water from Bldg. 580 is led to an oil/water separator and to the SWWS. The water from Bldg. 4016 is led directly to the sewage system and any remaining slug is transferred to storage drums.

4.3.6 Discard of water from swimming pool

During the summer 2006, an endless pool was installed at the Sport and Fitness Center in Bldg.

608. From here, a small amount of water is introduced to the SWWS.

Beside the normal use of chlorine, the water is sanitized using a treatment filter that releases small quantities of copper and silver.

4.3.7 Intrusion of Storm Water

Although the SWWS is segregated from the Storm Water Drainage System, the division might be compromised. The pipes of the SWWS are situated in the ditches and culverts that form the Storm Water Drainage System. As the segregation between the SWWS and the Storm Water Drainage System is the guarantee against unintended pollutants that have been washed off by the surface water, it is important to keep the SWWS without leaks.

4.4 Storage of Chemicals, toxic organic pollutants and solvents Handling and storage of hazardous materials are at Thule AB managed by the Hazardous Material Management Plan. Major storages are kept in Bldg. 555, 580, 605, 629, 801, 1391, and 4002.

Handling and storage of hazardous waste at Thule AB is managed by the Hazardous Waste Management Plan (CDRL CEV-15B). Major storages are kept in Bldg. 552, 563, 604, and 935.

The potential of accidental spillage of chemicals that might contaminate the SWWS is where sumps and floor drains are leading directly to the SWWS. In all other cases, the chemicals have to be manually poured or pumped into the drains.

4.5 Floor Drains

As mentioned in section 4.2, the only direct drainages into the SWWS from floors outside the dormitories are in Bldg. 107, 118, 236, and 4016. Special interest has to be made to these locations, as they are the only places where accidental releases of chemicals can occur.

Thule Air Base, Greenland 11/23 01 July 2009

4.5.1 Bldg. 118 – Hospital

Beside the drainages at the showers – for both staff and patients – there is a floor drain in the decontamination room. Despite designated as a decontamination room, the room is not used for decontamination purposes. All decontamination incidents are instead handled by the Fire Department on location in a mobile emergency system. The system collects all decontamination water for hazardous waste characterization.

4.5.2 Bldg. 107 – Dundas Buffet Restaurant

In the kitchen in Bldg 107 several floor drains are installed. From the floor-drain, water is led to a grease trap, where grease and other low-density liquids with low solubility in water can be withheld. The water is subsequently discharged to the SWWS.

4.5.3 Bldg. 4016 – Power Plant, J-site

At the auxiliary power plant at J-site, a sump is located in a room containing a parts washer. The sump is drained directly to the SWWS – without an oil/water separator. Furthermore, there is a storage of POL and hazard materials. The waste is stored in four 55-gallon steel and plastic drums situated horizontally and with secondary containment to collect spillage of chemicals.

4.5.4 Bldg. 236 – TOW Club

Water discharged to the SWWS through the floor drains in the kitchen is also led through a grease interceptor.

4.6 Conclusion

The SWWS at Thule AB is very unusual as it is situated above the ground. At the same time, it is totally segregated from the Storm Water Drainage System. Hereby it is eliminated that outdoor spills of chemicals, POL and other contaminants might run off into the SWWS – except for the possibility that it might enter through a leakage during the short period, where the storm drains are flooded and hereby partly submerging the SWWS.

In terms of chemicals as Hazardous Materials, Hazardous Waste and POL, there is no immediate risk for contamination of the SWWS. The major storage facilities do not have a floor drain where a potential spillage can enter the SWWS. The only possibility for contamination of the SWWS by chemicals will be discharges through sinks and toilets or spillage through the few floor drains.

Thule Air Base, Greenland 12/23 01 July 2009

5 SLUG MANAGEMENT AND OPERATIONS

Based on the analyses in section 5, the following management and operation plan is established.

5.1 Discharge Practice and Non-routine Batch Discharges

The main risk of damaging the SWWS or the recipient comes from the different routine discharges and non-routine batch discharges.

5.1.1 Practice for recurring discharges from installation

As mentioned in paragraph 5.3, there are several recurring discharges from installation.

The requirements are as follows.

Hazardous Materials has to be handled in accordance with the Hazardous Material Management Plan.

Hazardous Waste has to be handled in accordance with the Hazardous Waste Management Plan (CDRL CEV-15B)

Other types of discharges are listed in FGS Chapter 4.3.1, 4.3.2 and 4.3.3.

5.1.2 Discharge practice for trucked and hauled waste

According to the FGS, C4.3.2.1.7: “The discharge of trucked and hauled waste into the DWTS, except at locations specified by the DWTS operator is prohibited”.

As there is no wastewater treatment plant on Thule AB, the only function responsible for the SWWS is GC Utilities and Facilities Maintenance. As such, GC Utilities and Facilities Maintenance has the right to specify discharge of trucked and hauled waste. To prevent damage on the environment beside wastewater all discharge of trucked and hauled waste have to be done after consultation with GC Environmental Engineering.

The FGS, Chapter 4.3.3 includes the general requirements for the discharged batch. GC Utilities and Facilities Maintenance must retain records of the discharge for three years.

5.1.3 Discharge practice for trucked sanitary wastewater

As mentioned in paragraph 4.2, an amount of the collected wastewater is not transported by the SWWS but by truck to Bldg. 984, where it is discharged into the SWWS by the grit system. The same procedure is used for materials collected from septic tanks.

There is no limitation on the amount of trucked wastewater and no record has to be made, as long as the discharge is measured as a part of the ongoing registration of wastewater.

5.1.4 Intentionally non-routine batch discharge

Intentionally non-routine batch discharges, e.g. when water from a boiler is discharged due to maintenance, it is recorded IAW GC Utilities and Facilities Maintenance instructions.

5.1.5 Discharge of surface water to the SWWS

A special form of non-routine batch discharge is the use of the SWWS to discharge surface water. As previously stated, spill prevention is based on the segregation of the SWWS from the Storm Water Drainage System.

Thule Air Base, Greenland 13/23 01 July 2009

To eliminate the risk of spill, the general rules stated in 5.1.4 are expanded with the following requirements:

• All temporary discharge of surface water into the SWWS has to be by pump.

• The pumping process must be supervised.

• In case of a nearby spillage, the discharge must be stopped immediately.

5.2 Handling of Chemicals and Control of Toxic Organic Pollutants and Solvents Hazardous Material Management Plan and Hazardous Waste Management Plan (CDRL CEV- 15B) govern handling of hazardous substances.

5.2.1 Rooms with floor drain directly to the SWWS

In areas with a floor drain and storage of hazardous substances or POL, the rules outlined in the Spill Prevention and Response Plan have to be observed.

5.2.2 Rooms with floor drain indirectly to the SWWS

In areas, where water from floor drains is pumped to the SWWS:

• In case a spill occur during pump operation, the pump must be stopped immediately and spill response initiated.

5.3 Buildings, Containment Structures and Equipment

5.3.1 Planning of new building, containment structures and equipment When designing a new building, containment structures and equipment, it is essential to ensure no spill is led through the SWWS.

The measures are:

• To build structures that contains large storages of pollutants in a way with no direct access to the SWWS.

• To keep showers, toilets and other drains in parts of the building, where no pollutants are stored.

• To secure drains from areas where pollutants are stored by installing a pump that discharges the wastewater to the SWWS, that can be stopped in case of an accident or preferable only is operated when conditions has been checked.

• To keep pollutants in areas with floor drains in secondary containments.

To secure that a proper measure has been chosen, all projects have to be reviewed by GC Environmental Engineering.

5.3.2 Inspection and maintenance of the SWWS

Inspection and maintenance of the SWWS is the responsibility of GC Utilities and Facilities Maintenance and part of the maintenance program at Thule AB.

The maintenance of the SWWS is important as the segregation between the SWWS and the Storm Water Drainage System is a major part of the safety measures against pollution of the SWWS with spilled materials.

Thule Air Base, Greenland 14/23 01 July 2009

5.3.3 Oil/water Separators

The discharge of petroleum oil, non-biodegradable cutting oil, and products of mineral oil origin is prohibited. In places where oil is removed from objects with water and soap, e.g. where cars are washed, an oil/water separator system has been installed to withhold the oil.

The Facility Manager requests maintenance if required outside normal routine. GC Utilities and Facilities Maintenance is responsible for the maintenance of the oil/water separators.

5.3.4 Sand/Grease Traps

The discharge of solid or viscous pollutants that might obstruct the SWWS is prohibited.

The Facility Manager requests maintenance if required outside normal routine. GC Utilities and Facilities Maintenance is responsible for the maintenance of the sand/grease separators.

5.3.5 Cross Connections

Cross connections between the SWWS and the drinking water system is a problem related to drinking water. The Backflow Prevention Program includes control and removal of cross connections in accordance with AFI 32-1066, and is not a part of this plan.

5.4 Prevention of Accidental Spill

As many times previously mentioned the backbone of spill prevention in relations to the SWWS is the segregation. A description of correct handling of hazardous materials is stated under 6.2, but there are other types of unwanted materials as listed in FGS Chapter 4.3.1, 4.3.2 and 4.3.3.

From the perspective of the SWWS, they have to be treated like hazardous substances.

More information on prevention of accidental spill is included in the Hazardous Waste Management Plan (CDRL CEV-15B) and the Spill Prevention and Response Plan (CDRL CEV- 15C).

5.5 Emergency Response

Emergency Response procedures are included in the Spill Prevention and Response Plan

(CDRL CEV-15C).

Non-routine discharge of wastewater is approved by GC Environmental Engineering.

5.6 Notification

In case of an unintended discharge, notification will be given to the Consolidated Communications Center (alarm center) who will notify key personnel IAW rosters.

Environmental incidents are reported and investigated IAW SW Instruction 32-302 paragraphs 3.7.2, 4.1.2, 4.1.3, 4.1.4, 4.1.5, 4.1.7, 4.2.2, 4.2.3, 4.2.4, 4.2.5, 4.3.2, 4.3.3, 4.3.4, Attachment 1, 2, and HQAFSPC/A7AQ letter dated 7 Nov 2007. Initial reports are made to 821 ABG/CC and 21 CES/CEANN within 24 hours.

For Category 3, the EIBB report and NOTAM are completed IAW 21 SW Instruction 32-302 Attachment 1 and 2, within 7 days after the investigation is completed. The investigation documents are signed and forwarded to 821 ABG/CC and 21 CES/CEAN within 7 days of its completion. Reports must be received within 17 days of the investigation commencement.

Thule Air Base, Greenland 15/23 01 July 2009

For Category 4, an internal investigation consisting of a one page summary report or NOTAM is performed IAW 21 SW Instruction 32-302 Attachment 2. The investigation documents are forwarded to 821 ABG/CC and 21 CES/CEANN within 10 days.

As requested by 821 ABG/CC a waiver from performing an EIBB is submitted within 7 days of the incident, or an EIIB category lesser than the parameters is requested within 24 hours of the incident. Any waiver request is submitted to 821 ABG/CC and 21 CES/CEANN.

HQAFSPC/A7AQ letter dated 7 Nov 2007 waives the requirement to report sewage spills smaller than 110 gallons.

5.7 Employee Training

GC personnel and contractors who handle hazardous substances or perform activities that could contribute to spill or batch discharges should be trained in appropriate Best Management Practices by the individual shop. Such training should emphasize pollution prevention, awareness of possible pollution sources and local measures to contain spillage in a way that makes it possible to contain the spillage, e.g. how to stop pumps that discharges water from floors into the SWWS.

GC Environmental Engineering training programs include:

• Hazardous Waste Handling, in accordance with “Hazardous Waste Management Plan

(CDRL CEV-15B)”

• Chemical Hazard Communication, in accordance with “Hazardous Material Plan”

• Spill Response Training, in accordance with “Spill Prevention & Response Plan (CDRL

CEV-15C)”

Scheduled training dates are communicated through GC’s Personnel Department, and sign up is available for everyone through GC’s intranet.

The individual participant will receive a certificate from GC Environmental Engineering. GC Environmental Engineering will keep a record of the training for 3 years.

5.8 Sludge Disposal

A wastewater treatment plant is not been installed at Thule AB, therefore, no wastewater treatment sludge is produced.

Thule Air Base, Greenland 16/23 01 July 2009

6 EFFLUENT MONITORING

The daily volume of direct effluent discharge from Bldg. 984 to North Star Bay is monitored by an open channel flow meter based on standardized Venturi flume principles. The flow meter was installed in January 2009.

IAW FGS, Table C4.T2, sampling of effluent is performed monthly at Bldg. 984. A 24-hour time proportional composite sample consisting of 24 aliquots is collected by automatic sampling equipment. Alternately, a grab sample is collected manually.

IAW FGS, Paragraph C4.3.1.3 the monthly collected effluent samples are tested for conventional pollutants as pH, Total Suspended Solids (TSS) and Biochemical Oxygen Demand

(BOD5).

IAW FGS, Paragraph C4.3.1.4 the records on date, time and exact place of sampling and testing, analyst, test results, procedures and daily volume are retained for at least three years.

Thule Air Base, Greenland 17/23 01 July 2009

7 WATER POLLUTION COMPLAINTS

In general, USAF remains current with Greenland environmental activities and regulations IAW Statement of Work, Paragraph 18.11.

All official environmental correspondence sent to organizations outside of the 21 SW is approved by 821 ABG/CC and 21CES/CEANN prior to release. In addition, copies of all official incoming environmental correspondence are forwarded to 821 ABG/CC and 21 CES/CEANN within five days of receipt.

IAW FGS, Paragraph C4.3.1.5 and C4.3.2.2, water pollution complaints from individuals or host nation water pollution control authorities are investigated, involving the Environmental Executive Agent, as appropriate.

All correspondence and investigations are documented and records are retained for ten years.

So far, no complaints are received.

Thule Air Base, Greenland 18/23 01 July 2009

APPENDICES

Thule Air Base, Greenland 19/23 01 July 2009

APPENDIX 1: DEFINITIONS

Thule AB

Thule Air Base

DWTS Domestic Wastewater Treatment System

Any DoD or host nation facility designed to treat wastewater before discharging to waters of the host nation and in which the majority of such wastewater is made of domestic sewage.

SWWS Sanitary Wastewater System; defined as the existing piping system for wastewater on Thule AB

Seasonal Contractors A company awarded a contract by the government for construction or repair projects. Usually projects performed during the summer season at Thule AB.

Tenant Units These are other organizations assigned to Thule Air Base, which occupy some base facilities.

Process Wastewater Any water originated from manufacturing processes – including water coming from military installations

New sources A source built or substantially modified on or after 1 October 1994, that directly or indirectly discharges pollutants to the wastewater system

Substantial Modification Any modification to a facility the cost of which exceeds $1,000,000, regardless of the funding source

Waters of the Host Nation Surface waters including the territorial seas recognized under customary international law

Hazardous substances

A substance that is defined as either hazardous materials or hazardous waste in accordance with Appendix 1 of the FGS

EPC

Environmental Protecting Committee

Facility Manager An individual appointed to a facility/building whose primary responsibility is to ensure the facility is kept in a good state of repair. This includes ice and snow removal in front of doorways, stairways, ramps etc. during the winter.

Thule Air Base, Greenland 20/23 01 July 2009

APPENDIX 2: SEWAGE SYSTEM

Thule Air Base, Greenland 21/23 01 July 2009

APPENDIX 3: REVIEW COMMENTS 2009

Item# O ffice S ymbol

O rg Name of Commenter

P ag e# P ara# Critical , S ubs tantive or Adminis trative

Comment Rationale Accept/Modify/Rejec t Rationale

1 CEA NN 21 CES DeGarmo 9 4.3.3 C A dd: Us e Non-em uls ify ing s oap for vehic le was hing.

A c c ept S ec t ion 4.3.3 is updated. Thule A B is in proc es s of identify ing and purc has ing a non-em uls ify ing s oap.

In the interim vehic les are c leaned only w ith water.

2 CEA NN 21 CES DeGarmo 10 4,5 C S hould c ons ider us e of tem porary drain c overs for us e when c hem ic als m ay s pill. The c overs c an be rem oved for floor c leaning and other ac t ivit ies requiring us e of the drain.

FG S C4.3.2.1.6.4. This will prevent ac c idents from entering the outs ide waterway s .

M odify S ec t ion 4.5 has not been updated, but s ec t ion 5.2.1 s pec ifies that proc edures are out lined in the S pill P revention and Res pons e P lan.

3 CEA NN 21 CES DeGarmo 10 4.5.1 C Can this water be c ollec ted? Thule needs to c ollec t this water. The hos pita l dec ontam ination water c an get any th ing from haz ardous m aterials to b iologic al agents into it that y ou don’t want to re leas e bac k into the environm ent. Thule needs to s am ple th is water before it is re leas ed or c ollec ted at haz ardous was te.

FG S C4.3.1.2.3 A c c ept S ec t ion 4.5.1 is updated. A ll dec ontam inat ion inc idents are handled by the F ire Departm ent on loc ation in a m obile em ergenc y s y s tem . The s y s tem c ollec ts a ll dec ontam inat ion water for haz ardous was te c harac teriz at ion.

4 CEA NN 21 CES DeGarmo 14 5,6 C A dd not ific at ion proc edures to this p lan for s ewage s pill a t or above 110 gallons as required by E nvironm ent Inc ident Inves t igat ion B oard (E IIB ) P roc edure P olic y M em o (HQ A FS P C/A 7CV P olic y P 06004V ).

A nd let ter dated 7 Nov 07 waiver that waives the requirem ent to report s ewage s pills s m aller than 110 gallons .

E nvironm ent Inc ident Inves t igat ion B oard (E IIB ) P roc edure P olic y M em o (HQ A FS P C/A 7CV P olic y P 06004V ). A nd let ter dated 7 Nov 07 waiver that waives the requirem ent to report s ewage s pills s m aller than 110 gallons .

A c c ept S ec t ion 5.6 is updated to inc lude proc edures for s ewage s pill a t or above 110 gallons .

5 CEA NN 21 CES Se ig e le 9 4.3.4 C W hat c hem ic als of c onc ern are c om ing from the “rins ing” proc es s that would require their d is pos al as a haz ardous was te? W ouldn’t there be s im ilar c hem ic als generated in the “was hing” proc es s ? A nd if s o, why wouldn’t thes e c hem ic als als o be d is pos ed of as a haz ardous was te?

FG S C6 A c c ept S ec t ion 4.3.4 is updated. The rins ing proc es s is des ignated as a dry -c leaning proc es s , where m ethy lene c hloride is us ed. O nly c onvent ional detergents are us ed for the was hing proc es s .

6 CEA NN 21 CES Se ig e le 10 4.3.5 C Lis t the c ontam inants from the parts was hers that would be ex pec ted to be introduc ed into the S W W S and their es t im ated quant it ies . W hat is the “rem aining s lug” that is being referenc ed here?

A c c ept The parts was her was te and s lug w ill be c harac teriz ed.

Thule Air Base, Greenland 22/23 01 July 2009

Item# O ffice S ymbol

O rg Name of Commenter

P ag e# P ara# Critical , S ubs tantive or Adminis trative

Comment Rationale Accept/Modify/Rejec t Rationale

7 CEA NN 21 CES DeGarmo 10 4.3.5 C Charac teriz e parts was her was te. If HW , c ollec t d is c harge and dis pos e as HW .

FG S C6: D is c harge from B 4016 goes direc t ly to environm ent when dis c harged over c liff. This

A c c ept The parts was her was te and s lug w ill be c harac teriz ed.

8 CEA NN 21 CES Se ig e le 10 4,4 C Third paragraph m ent ions that in c erta in fac ilit ies there is a potent ia l for a s pill to enter a floor drain and s um p that leads direc tly to the S W W S ; rec om m end (rem ovable) floor drain c overs be ins talled and a s hallow berm be ins talled around the s um p pits to prevent ac c idental re leas es from entering the S W W S .

FG S C6 M odify S ec t ion 4.4 has not been updated, but s ec tion 5.2.1 s pec ifies that proc edures are outlined in the S pill P revent ion and Res pons e P lan.

9 CEA NN 21 CES Se ig e le 10 4,5 S Rec om m end ex pla in ing what is m eant by “ S pec ia l interes t has been m ade to thes e loc ations “.

S elf ex plained M odify S ec t ion 4.5 has not been updated, but s ec tion 5.2.1 s pec ifies that proc edures are outlined in the S pill P revent ion and Res pons e P lan.

10 CEA NN 21 CES DeGarmo 9 4.3.1 S S ec t ion m entions that was tewater trans ported by t ruc k is m ent ioned in s ec tion 5.2, but 5.2 does not dis c us s t rans ported was te.

S elf ex plained A c c ept S ec t ion 4.3.1 is updated w ith c orrec t referenc e (4.2 ins tead of 5.2).

11 CEA NN 21 CES DeGarmo 12 5.1.3 S S ec t ion m entions that was tewater trans ported by t ruc k is m ent ioned in s ec tion 5.2, but 5.2 does not dis c us s t rans ported was te.

S elf ex plained A c c ept S ec t ion 5.1.3 is updated w ith c orrec t referenc e (4.2 ins tead of 5.2).

12 CEA NN 21 CES DeGarmo N/A N/A C A dd to plan m onitoring to determ ine if effluents have ex c eeded thos e lim its .

FG S C4.3.1 dis c us s es effluent lim its , but the plan does not s pec ify any m onitoring to determ ine if effluents have ex c eeded thos e lim its .

A c c ept S ec t ion 6 is added to the plan.

E ffluent s am ples are tes ted for c onventional pollutants as pH, Total S us pended S olids (TS S ) and B ioc hem ic al O x y gen Dem and (B O D5) to determ ine if effluents have ex c eeded lim its .

13 CEA NN 21 CES DeGarmo N/A N/A C A dd to plan m onitoring frequenc ies as required by F G S .

FG S , Table C4.T2.

M onitoring Requirem ents requires m onitoring at s pec ified frequenc ies bas ed on M G D of effluent, but the plan does not

A c c ept S ec t ion 6 is added to the plan.

E ffluent s am ples are tes ted m onthly bas ed on M G D of effluent .

14 CEA NN 21 CES DeGarmo N/A N/A C A dd to plan a s y s tem to inves t igate water pollut ion c om plaints as required by F G S .

FG S S ec t ions C4.3.1.5 and C4.3.2.2 s pec ify that a s y s tem for inves t igat ing water pollut ion c om plaints from individuals or hos t nation water pollut ion c ontrol authorit ies w ill be es tablis hed, involvingthe E nvironm ental E x ec ut ive A gent, as appropriate.

A c c ept S ec t ion 7 is added to the plan.

S y s tem is s pec ified to inves tigate water pollut ion c om plaints .

Thule Air Base, Greenland 23/23 01 July 2009

APPENDIX 4: DISTRIBUTION LIST

The PDF document is distributed via email IAW CDRL Summary list.

Distributed in PDF format

21 Space Wing

21 CES/CEANN

William.ritchie@peterson.af.mil Todd.degarmo@peterson.af.mil

21 SW/PMD 21sw.pmd.thule@peterson.af.mil

821 Air Base Group 821 ABG/CC Commander

821SPTS.PM@thule.af.mil

821 Support Squadron 821 SPTS/CE Flight Commander

821SPTS.CE@thule.af.mil

Greenland Contractors, Thule Air Base

All GC organizations (on GC LAN)