Atch 08 - FA2523-11-R-0001 Executive Summary 24 Jul 2003

EXECUTIVE SUMMARY

of the

FINAL GOVERNING STANDARDS

for

United States Forces in Greenland

(FGS-GL)

Prepared by

Headquarters Air Force Space Command Department of Defense Environmental Executive Agent for Greenland

24 July 2003

Renée Typewritten Text

ATTACHMENT 08

Executive Summary 2 24 July 2003 Greenland FGS

EXECUTIVE SUMMARY

The purpose of the Final Governing Standards for Greenland (FGS-GL) is to provide specific standards for environmental protection at Department of Defense (DoD) installations operating in Greenland. It has been prepared by Headquarters United States Air Force Space Command (HQ AFSPC), as the DoD Environmental Executive Agent (EEA), to meet the requirements of DoD Instruction 4715.5, “Management of Environmental Compliance at Overseas Installations.” The Final Governing Standards (FGS) are based primarily upon the generally accepted environmental standards for DoD installations in the United States (US) with modifications as required based on US legal obligations in Denmark as well as generally applicable and more protective host nation environmental standards. These FGS, in conjunction with applicable DoD and Service policies, provide the complete source of environmental protection practices for US installations operating in Greenland.

The Greenland Home Rule (GHR) Authority has the primary role for environmental protection in Greenland. Base staff should coordinate all correspondence with the GHR Authority with AFSPC/CEV.

Requests for environmental information from the GHR and Denmark should be coordinated with AFSPC/CEV. Base staff should notify AFSPC/CEV when either the GHR or Denmark access the base to do an environmental inspection. Also, the U.S. and Denmark have signed bilateral agreements which impose additional requirements on waste disposal. Base staff should notify AFSPC/CEV on waste disposal issues prior to contacting GHR, to ensure all U.S. treaty obligations are met.

FGS-GL is effective upon issuance by the EEA. Compliance with the FGS is mandatory for all DoD Components, pursuant to DoD Instruction 4715.5. The revised FGS-GL replaces the previous edition dated September 1994 (along with interim policy) as soon as released.

Summary of Changes

The following summary describes the operational differences between the revised FGS-GL and the 1994 FGS. The information below is intended to communicate the more significant changes to the document and does not reflect all changes. Additional changes include modifications to the document format, including the numbering scheme, clarification of many of the old requirements, and other minor changes.

Chapter 2 - Air Emissions

• Revised Medical Waste Incinerators requirements to include good combustion practices for both new and existing overseas MWIs.

• Modified opacity requirements to include continuous emission monitoring for 30-100 million Btu/hr units (excluding gaseous fuels).

• Added criteria for Perchloroethylene Dry Cleaning Machines and Chromium Electroplating and Chromium Anodizing Tanks.

• Revised criteria for Halogenated Solvent Cleaning Machines.

• Revised criteria for Units containing Ozone Depleting Substances to address new refrigerant standards.

Executive Summary 3 24 July 2003

• Specific compliance dates are included in FGS-GL for the following units: Medical Waste Incinerators – 15 March 2005, Perchloroethylene Dry Cleaning Machines – 15 March 2003, Chromium Tanks – 15 March 2003, and Halogenated Solvent Cleaning Machines – 15 March 2003.

Chapter 3 - Drinking Water

• Delineated the frequency of water system surveys to be at least every three years for systems using surface water and every five years for systems using groundwater.

• Modified notification requirements for various exceedances. In many cases, the reporting timeframes have been shortened and the list of parties to be notified has been expanded.

• Added a criterion ensuring installation personnel are appropriately trained to operate DoD water systems.

• Added, deleted, and changed various maximum contaminant levels and monitoring requirements throughout this chapter, including the tables.

Chapter 4 - Wastewater

• Added criteria for recordkeeping that requires monitoring results and other records related to “Effluent Limitations for Direct Dischargers of Conventional Pollutants” be retained for three years.

• Added criteria for “Effluent Limitations For Non-Categorical Industrial Direct Dischargers” to restrict process wastewater with high amount of heat which can inhibit biological activity in the domestic wastewater treatment systems resulting in interference.

• Added criteria for storm water management, to include employee training and the development and implementation of a storm water pollution prevention plan for specified activities.

• Added criteria for septic systems to prevent discharges of industrial pollutants that will inhibit biological activities.

• Modified monitoring requirements table to specify plant capacity and frequency of sampling to clarify and adequately measure BOD5 and total suspended solids sampling requirements.

Chapter 5 - Hazardous Material

• Added criteria that “Drivers will be trained on spill control and emergency notification procedures.”

• Modified material safety data sheet criteria requiring that MSDSs be in English and/or the predominant language in the workplace, to avoid the costly and sometimes unnecessary translation into English.

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Chapter 6 - Hazardous Waste

• Added criteria requiring that arrangements for removal of hazardous waste from the hazardous waste accumulation point be made within five working days once the storage limits have been reached.

• Added a time limit of one year for storage of hazardous waste at a hazardous waste storage area.

• Modified recordkeeping requirements to include maintenance of turn-in documents for three years and added criteria requiring installations to maintain hazardous waste accumulation point records.

• Added supervisory personnel to the list of individuals who require hazardous waste training.

• Added criteria to preclude on-site treatment of hazardous waste, with the exception of elementary neutralization.

• Modified the land disposal requirements to prohibit the land disposal of hazardous wastes and toxic materials in Greenland.

• Modified the incineration standards to prohibit the incineration of hazardous wastes and toxic materials in Greenland.

Chapter 7 - Solid Waste

• Modified criterion for recycling programs to cross reference DoD Instruction 4715.4, to avoid conflict with that instruction and because there is no specific legal requirement to maintain such programs.

• Added requirements for leachate collection and groundwater monitoring in the design of new municipal solid waste landfills.

• Added a requirement that locations of new municipal solid waste landfill units be selected or approved by appropriate host-nation authorities with the mutual agreement of the appropriate base commander.

• Added a requirement that design and maintenance of new municipal solid waste landfill units conform to common standards for Greenland or to specific standards agreed to by mutual consent among the authorities concerned.

• Added a requirement to the landfill closure procedure to ensure that the procedures are agreed upon, in writing, by both the U.S. and Danish/Greenlandic Authorities.

• Deleted the requirement for a written landfill closure plan because, per an international agreement, Greenland has responsibility for perpetual maintenance of landfills after they have been closed.

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Chapter 8 - Medical Waste

• Added veterinary and dental clinics to the scope of this chapter.

• Modified sterilizer requirements that are outlined in Table C8.T1.

Chapter 9 – Petroleum, Oil and Lubricants

• There were no substantial changes to the POL chapter.

Chapter 10 - Noise

• The criteria for this chapter were removed from the March 2000 Overseas Environmental Baseline Guidance Document (OEBGD) and, thus, are no longer included in the FGS.

Chapter 11 - Pesticides

• Removed specific requirements under the medical surveillance program, and stated that the detailed requirements for this program are to be determined by the medical community for each service, command, installation, or individual.

Chapter 12 - Historic and Cultural Resources

• Added a requirement for installations to have access to the World Heritage List of the host nation's equivalent of the National Register of Historic Places, so that Commanders can take into account the effect that DoD actions will have on such property( ies) for the purpose of avoiding or mitigating any adverse effects.

• Deleted the requirement to inventory archaeological resources in areas under DoD control.

Chapter 13 - Natural Resources and Endangered Species

• Modified the criteria requiring development and implementation of management plans for installations having land and water.

• Modified the requirement that the host nation installation Commander be notified upon discovery of any endangered/threatened or host nation protected species not previously known. Previously, notification was “recommended.”

Chapter 14 – Polychlorinated Biphenyls

• Added requirement that unmarked transformers be treated as PCB transformers.

Executive Summary 6 24 July 2003

Chapter 15 - Asbestos

• Removed safety and occupational health concerns from the scope of this chapter and, instead, reference DoD Instruction 6055.1, “DoD Occupational Safety and Health Program,” and DoD Instruction 6055.5, “Industrial Hygiene and Occupational Health,” which cover personnel exposure issues.

• Added requirement that asbestos management plans include procedures to prevent the use of ACM in new construction.

Chapter 16 - Radon

• The criteria for this chapter were removed from the March 2000 OEBGD and, thus, are no longer included in the FGS.

Chapter 17 - Lead-based Paint

• This chapter is completely new, and the criteria focus on reducing LBP hazards. Safety and occupational health concerns are deliberately left out and, instead, references to DoD Instructions 6055.1, “DoD Occupational Safety and Health Program,” and 6055.5, “Industrial Hygiene and Occupational Health,” are included to cover personnel exposure issues.

Chapter 18 - Spill Prevention and Response Planning

• Added a requirement to conduct spill response drills as necessary to ensure the effectiveness of personnel and equipment.

Chapter 19 - Underground Storage Tanks

• There were no substantial changes to the UST chapter.

Environmental Effect Abroad-formerly FGS Chapter 17

• This chapter was removed from the March 2000 OEBGD and, thus, is no longer included in the FGS. Environmental analyses should be conducted under E.O. 12114, and in accordance with applicable DoD Component policies and procedures.