A2 Digital Radiology SOW (16 Dec 20).docx

Statement of Work for: Digital Radiographic (DR) System – Thule AFB

STATEMENT OF WORK

FOR

Digital Radiographic (DR) System – Thule AFB

Prepared By:

Medical Logistics Clinical Engineering Air Force Medical Readiness Agency DATE: 16 Dec 20

REVISION NUMBER: #1.5

Table of Contents

1 SCOPE

This Statement of Work (SOW) defines the effort required for replacing a Digital Radiographic (DR) System at Thule AB.

1.1 Background

The Digital X-ray project has been initiated to replace the GE proteus unit that will fulfill the radiology and orthopedic clinic requirements as specified in this statement of work.

2 APPLICABLE DOCUMENTS

The following documents apply to this SOW to the extent specified herein.

2.1 Department of Defense (DoD) Standards

· Final Governing Standards (FGS-GL) 2003 Edition

· Hazardous Waste Management Plan (A068) 2018 Edition

· Solid Waste Management Plan (A071) 2017 Edition

2.1.2 Availability of DoD Documents

Unless otherwise indicated, copies of documents listed above are available from:

· Executive Services Directorate, DoD Directives Division: http://www.esd.whs.mil/DD/

· Air Force E-Publishing: http://www.e-publishing.af.mil/

· Department of Defense Instruction (DoDI) 8510.01 Risk Framework (RMF)

2.2 Other standards and publications

· Unified Facilities Criteria (UFC) 3-600-01 Fire Protection Engineering For Facilities, Change 1, 14 July 2009

· UFC 3-301-01 Structural Engineering, Appendix F, Table F-1 for Climatic Loading Data and Table F-2 for Earthquake Loading Data

· International Building Code (IBC), 2012 Edition

· National Fire Protection Agency (NFPA) 101 – Life Safety Code, 2012 Edition

· National Information Assurance Partnership (NIAP) Common Criteria Cybersecurity Evaluation and Validation Scheme (CCEVS) evaluation (https://www.niap-ccevs.org)

2.2.1 Availability of Other standards and publications

Unless otherwise indicated, copies of documents listed above are available from:

· www.wbdg.com

3 REQUIREMENTS

3.1 General

The work required by this contract shall be performed in accordance with this Statement of Work (SOW). The Contractor shall provide all materials, plans, labor, equipment, and supervision necessary to accomplish the work requirements. The contractor shall install the DR system in accordance with the detailed requirements below. The contractor shall provide all materials, plans, labor, equipment, and supervision necessary to do the work requirements.

Only equipment and part numbers that are FDA approved, have an existing Defense Health Agency Risk Management Framework Authority to Operate, and commercially available at the time of quote submission, may be offered under this requirement.

3.2 Detail Tasks

3.2.1 Request for Offers (RFO) Overall Minimum Requirements

3.2.1.1 Generator

· At least a 65kw generator. All power at Thule is in the US standard 60 Hz. There is no noise dB limitation. If the noise is excessive, hearing protection or other contingencies will be instituted. Note: An fully functional GE generator is already on-site and compatible with the current system. It is available for use by the contractor at their own risk. Further details can be provided upon request.

3.2.1.2 Detector Plates

· Shall be a two plate Direct Radiography system: two portable wireless detectors with table-top functionality of at least 35 x 43 cm. Each wireless detector shall include a spare battery.

3.2.1.3 Wall Stand

· Shall include a wall stand.

3.2.1.4 Automatic Exposure Controls (AEC) Fields

· Shall have automatic Exposure Control for both the vertical and table buckys with a minimum of 3 AEC Fields.

3.2.1.5 Tube Head

· Shall have ceiling-mounted tube-head adjustable to accommodate weight-bearing lower extremity studies.

3.2.1.6 Table

· Shall have a fixed mounted elevating table with four-way floating tabletop design supporting at least 450lbs at the center with movement.

3.2.1.7 Positioning Devices

· Shall include automated image capture and includes any required positioning devices.

3.2.1.8 Weight Bearing

· Shall include weight-bearing extremity steps/stand with a maximum step height of 24” and capable of bearing patient weight of at least 450 lbs. The detector shall include a weight-bearing protective case for patients to stand on. The system shall include all software to complete weight-bearing exams. Shall include all software to complete these exams.

3.2.1.9 Wall Bucky

· Shall include a motorized auto-tracking, folding & tilting wall bucky that will maintain bucky/tube alignment if one is moved.

3.2.1.10 Integrated Workstation (Qty. 1)

· Shall include all software for orthopedic and radiology clinics to include weight-bearing, dose reporting, and scoli software.

· Shall have integrated independent and secure wireless capability integrating image preview at the workstation

· Shall include integrated Workstation with exam protocols and technique presets that are customizable at the time of applications training

· Shall include integrated 1-2 monitors to manage workflow, image acquisition preview, and post-processing functions. The size of the monitors should be at least 19”.

· Shall include post-processing tools at Workstation for annotation and image manipulation

3.2.1.11 Variable Grid

· Shall have a variable grid for both wall bucky/table bucky Max MA station of at least 800 mA

3.2.1.12 Charging Station

· Shall include at least one charging station and a second set of batteries for each detector.

3.2.1.13 Dose Reporting

· Shall include dose reporting software.

3.2.1.14 Repeat/Reject

· Shall include repeat/reject analysis applications program.

3.2.1.15 Manual Technique

· Manual technique selection shall be possible for all exams.

3.2.1.16 Table

· The system shall be capable of taking images of patients in wheelchairs and gurneys when patient movement to a table is not possible.

3.2.1.17 Radiologist Technician Training

· Shall include on-site/in-person user training for all components and accessories for 2 technologists at time of installation.

3.2.1.18 Acceptance Testing

· Acceptance Testing shall occur immediately after installation (on the same trip). The vendor will need to be onsite as well as the physicist.

· Lodging cost is estimated to be $185 per night per person. Air transportation will be provided by the Government from Copenhagen, Denmark to Thule Air Base.

· Vendors shall provide Maj Clifford Souder (clifford.c.souder.mil@mail.mil) and Mr. Claudy Philemon (claudy.j.philemon.ctr@mail.mil) a finalized schedule.

3.2.1.19 Digital Imaging and Communications in Medicine (DICOM)

· Must be able to burn/export studies into a DICOM format from the workstation and include any peripherals required to do so.

· Shall include DICOM Worklist integration with the Composite Health Care System (CHCS)

· Shall include a CD burner.

3.2.1.20 RMF

· Vendors shall only quote items that already have an Authorization to Operate (ATO)/Authorization to Connect (ATC).

· The unit shall utilize Windows 10 or Linux.

· All major component software applications (SQL, IIS, .Net, etc.) have current commercial support.

· Failure to provide ATO or ATC equipment shall result in rejection of the vendor's quote.

3.2.1.21 Vertical Cassette

· The unit shall have a vertical cassette holder (w/bucky), scoliosis holder, and protector for the 35x43cm detector for weight-bearing exams.

3.2.1.22 Power Requirements

· The system shall operate on the following: 480V. All power at Thule is in US standard 60 Hz. No UPS required for this equipment.

3.2.1.23 Phantoms

· The vendor shall provide a phantom to use during quality control testing by the radiologist technician.

3.2.4 Maintainability/Maintenance Support

3.2.4.1 Maintenance Contract

· Vendors shall only quote items that will be able to be placed on a full-service maintenance contract.

3.2.4.2 Service Personnel

· Location of nearest service personnel shall be provided as well as the option for remote support.

3.2.4.3 Operator Manuals

· The unit shall include 2 sets of operator user manuals and 2 sets of service manuals. All manuals shall be in electronic form.

3.2.4.4 Warranty

· Shall include a 1-year warranty

3.2.5 Removal

3.2.5.1 De-Install

· The current equipment shall be de-installed and removed from the facility. The equipment should be packed and ready for shipment out by sea the next port season and moved to either the DLA Disposition Services (DRMO) lot. De-install is soley the responsibility of the vendor.

3.2.6 Extended Installation, Turnkey or Incidental Services

· The final quote must include all equipment and all site prep/construction/incidental services required to provide a fully operational system that meets all minimum requirements/essential characteristics. If the system requires drilling into the floor, the floor tiles will be replaced with similar or contrasting colors approved by the Thule facility manager. If the system requires ceiling/wall patches, they shall be painted with a closely matching color.

· Vendors must provide with their quote a detailed statement of work and pricing for the installation/site work.

3.3 Program Planning and Management

3.3.1 Site Management

· The contractor shall perform a final cleanup and repair of the work area, including any damage done to adjacent grounds, pavements, or structures. Any damage shall be repaired and returned to conditions matching those before the contractor began work on this project.

3.3.2 Site Information

· Physical name of building/facility: 118 Thule AB Clinic

· Physical address of project: PSC 1501 Unit 82501 APO AE 09704

· Personnel working on the project need Foreign Visitor Request entry approval and dispensation from the Danish Ministry of Foreign Affairs unless if they are from the US, Denmark, or Canada. No US Passport is required if traveling from Denmark. Danish vendors will have to get prior authorization to get on the plane from Copenhagen.

· Note: Danish or Greenlandic authorities do not need to approve anything when entering the country.

· If the contractor has any hazardous materials, the contractor needs to submit MSDS info to our environmental specialists for approval before shipping – please use this email SHR-THU-ENVSHR-THU-ENV@vectrus.com.

3.3.3 Work Items

3.3.3.1 Water Disposal

· Water disposal from this product will be handled by the Base Maintenance Contractor according to hazardous waste procedures.

· Waste products from this project should be disposed of in Base DRMO.

3.3.3.2 Work hours

· The facility hours of operation are 7:30 am-4:30 am ET.

· Contractors can work before/after hours. Access badges would need to be acquired from 821 SPTS.

· Contractors can work weekends. Access badges would need to be acquired from 821 SPTS.

3.3.3.3 Permits and Outages

· The contractor shall obtain all applicable work permits including but not limited to AF Form 103 Work Clearance Request and utility prints for the worksite, welding; burn permit, and any permits or licenses required for the removal of hazardous materials.

· To obtain a hot work permit AF Form 592, when onsite, you will need to contact our Fire Chief Mr. Aage Johansen, ext. 3249. The Fire Chief will then issue a hot work permit for you.

· To obtain above ceiling permits, the contractor will need to submit an AF Form 103 for approval seven (7) days in advance of any work to be performed.

· An approved AF Form 103 and coordination with 821 SPTS and Medical Clinic Staff is required for above ceiling work and dealing with electrical, med gas, sprinkler, alarm, plumbing, etc. outages.

· Check UFC and NFPA requirements for additional information on the process for outages.

3.3.3.4 Facility Required Inspections

· Check UFC and NFPA requirements for information on inspection requirements for electrical, medical gas, sprinkler, plumbing, framing, etc.

3.3.3.6 Environmental

· Wildlife and arctic weather conditions are known environmental concerns or hazards at the site.

· The site is a seismic rated building. Please follow the directions of UFC 3-301-01 Table F-3, Greenland, Thule AB. The site is not an “event” rated building.

3.4 Deliverables

3.4.1 Language and measurements

All literature, measurements, and received measurements shall be in English, and utilize where possible Society of Automotive Engineers (SAE) units of measure. Unit of measure exceptions shall only be accepted for filtering measurements, water chemistry, and equipment literature that was originally written with metric measurements.

3.4.3 Material Submittal

Provide all equipment manuals and installation documentation not supplied by the Government.

3.4.4 Project Schedule

Provide a detailed project schedule showing at a minimum: major milestones towards project completion, task durations and dependencies, cargo transport requirements, and personnel travel needs. If during the period of performance of the contract there are changes to the schedule, an updated schedule would need to be provided so that a modification can be made to the contract.

3.4.5 Final Records

Provide final redline/as-built drawings, system specifications, and operational/maintenance manuals and any other documentation needed for the Base Maintenance Contractor to complete DD Form 1354. Documents shall show actual installation conditions, wiring, and warranty as applicable.

3.6 DHA IA/RMF Requirements

3.7 Pictures of Current Room

3.8 Deleted

3.9 Current DR Room Schematics

image2.emf

A068 (1 Feb 18) Hazardous Waste Management Plan.pdf

Contract No. FA2523-15-C-0001 Supersedes A068, FY-17 1 Feb 2017

1 Feb 2018

A068 HAZARDOUS WASTE MANAGEMENT PLAN

Thule Air Base, Greenland

FINAL

A068 Hazardous Waste Management Plan

2 1 Feb 2018

INSTALLATION IMPLEMENTING INSTRUCTION

Date: This plan is current as of 1 February 2018.

Requiring Office: 21 CES/CEIE

OPR: Vectrus Services, Environmental Engineering (VS/EE)

Subject: Hazardous Waste Management Plan (HWMP), Base Maintenance

Contractor (BMC) deliverable A068

Reference(s): Final Governing Standards for Environmental Protection by United States

Forces in Greenland (FGS), 24 July 2003

Purpose: To purpose of the Hazardous Waste Management Plan is to implement criteria for the hazardous waste characterization, labeling, storage and turn-in at Thule Air Base (Thule AB), Greenland.

Discussion: Implementation of this plan provides documented guidance regarding hazardous waste management to ensure a safe, healthy and clean environment and ensure continuity of operations. It is a comprehensive document applicable to all personnel working at Thule AB. It is designed to ensure installation compliance with FGS regulations governing hazardous waste.

Applicability: The requirements of this plan apply to all base operations.

3 1 Feb 2018

TABLE OF CONTENTS

1 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

2 GENERAL

2.1 Purpose

2.2 Scope

2.3 Regulatory Overview

3 HAZARDOUS WASTE CHARACTERISTICS

3.1 Characterization of Waste

3.1.1 Ignitable Waste (D001)

3.1.2 Corrosive Waste (D002)

3.1.3 Reactive Waste (D003)

3.1.4 Toxicity Characteristic Waste (D004-D43)

3.2 Listed Waste

3.2.1 F-list

3.2.2 K-list

3.2.3 P-list

3.2.4 U-list

3.3 Hazardous Waste Mixtures

3.4 Hazardous Waste Residue

3.5 Container Management

3.6 Lead-Based Paint

4 HAZARDOUS WASTE STORAGE

4.1 Hazardous Waste Accumulation Point

4.2 Hazardous Waste Storage Area

4.2.1 Requirements for HWSA

4.2.2 Documentation for the HWSA

4.3 Closure Plans

5 LABELING

5.1 Hazardous Waste Label

5.2 Non Hazardous Waste Label

5.3 Hazard Class

6 TURN-IN PROCEDURES

6.1 Hazardous Waste Turn-in Procedure

4 1 Feb 2018

6.2 Hazardous Materials Turn-in Procedure

6.3 EPA Provisional ID Number

6.4 Hazardous Waste Tracking

7 CONTINGENCY, PREPAREDNESS AND SPILL RESPONSE

8 PERSONNEL TRAINING

APPENDICES

APPENDIX 1: DEFINITIONS AND TERMS

APPENDIX 2: HAZARDOUS WASTE INVENTORY AT THULE AB

APPENDIX 3: WASTE ANALYSIS PLAN

APPENDIX 4: TURN-IN DOCUMENTS

APPENDIX 5: INSPECTION CHECK LISTS

APPENDIX 6: CLOSURE PLAN

5 1 Feb 2018

1 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

Title: The title of this document is “Hazardous Waste Management Plan”. The acronym HWMP will be used throughout the document.

Classification: This document is unclassified.

Responsibilities: Vectrus Services, Environmental Engineering (VS/EE) is the office of primary responsibility for developing and maintaining the HWMP. The instructions given in this plan are applicable to all organizations and tenant units at Thule AB. Organizations are authorized to extract and reproduce those sections of the HWMP that are essential in the accomplishment of necessary planning and in the preparation of supporting documents and reports.

References: References referred to in the HWMP do not appear in the plan, but they may be accessed through VS/EE or the Air Force Electronic Publication Library (AFEPL).

Reviews/changes: The HWMP will be reviewed and updated annually. The initial draft is submitted to BMC Deliverable distribution list. Any review comments received will be incorporated in the final version of the plan within 30 days.

Distribution: The Final plan is submitted to the BMC Deliverable distribution list, tenant units, US/Danish Contractors and other organizations performing work at Thule AB.

6 1 Feb 2018

2 GENERAL

2.1 Purpose

The purpose of the HWMP is to ensure that documented guidance for hazardous waste (HW) management is available to all installation personnel.

The documentation will include:

Identification of all HW generators.

Identification of all HW streams.

Identification and description of all HW being produced.

Implementation of proper procedures for handling, labeling, marking, storing, and disposing of HW.

Monitoring the required performances with regard to HW management as described in this plan.

Continued evaluation and update of the HW inventory and analysis plan.

Establishment of procedures to ensure outside contractors' compliance with the Thule AB

HWMP.

Revision and update of host-tenant support agreements and exercise support agreements (BOX-TOP, National Science Foundation, etc.) by the Environmental, Safety, Occupational Health Council (ESOHC) to ensure that these comply with the HWMP.

The goal is to achieve a full state of awareness throughout the installation in order to protect employee health, provide a safe work environment, minimize adverse effects on the environment from the generation and disposal of HW, and minimize the disposal costs of the generated HW.

2.2 Scope

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

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

A071 Solid Waste Management Plan

A070 Spill Prevention and Response Plan

A067 Asbestos Management Plan

7 1 Feb 2018

2.3 Regulatory Overview

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

Federal Regulations: 40 CFR, Title 40, Parts 1-790 and Environmental Requirements

Parts 1-900 (Guidance)

49 CFR, Title 49, Parts 171-80 and Hazardous Material Parts 100- 199 (Guidance)

USAF: Final Governing Standards for Environmental Protection by United

States Forces in Greenland, prepared by HQ AFSPC, referenced herein as FGS.

Thule AB: ESOHC decisions

Host Country: Country to Country Agreement concerning Disposal of United

States Salvage:

Memorandum of Understanding (MOU), “An Agreement Concerning the Disposal of United States Salvage, Surplus or Excess Equipment and Supplies at USAF Aerospace Defense Command Bases and Sites in Greenland”, dated 29 June 1976 and 1987 Amendment.

8 1 Feb 2018

3 HAZARDOUS WASTE CHARACTERISTICS

Waste is hazardous if it can be harmful to human health and the environment when handled improperly.

Hazardous waste is a solid waste that:

1. Is a listed waste1 or

2. Exhibits a characteristic of a hazardous waste2 or typical hazardous materials characteristics3

The Waste identification process is shown in the flowchart below:

Solid waste

Is the waste listed?

Does the waste exhibit any of the 4 characteristics specified?

No

The waste is hazardous waste

The waste is solid waste

See SWMP

Yes

No

Yes

Solid Waste

The HW identification process is the first step in determining if the waste is solid or not.

Solid waste is: Garbage, refuse, sludge, and other discarded materials including solid, semisolid, liquid, and gaseous containing materials, resulting from industrial and commercial operations and from community activities.

It does not include solids or dissolved material in domestic sewage or other significant pollutants in water resources, such as silt, dissolved, or suspended solids in industrial wastewater effluent, dissolved materials in irrigation return flows or other common water pollutants.

1 See FGS appendix 1 2 See FGS appendix 1 3 See FGS Table C5.T1

9 1 Feb 2018

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

3.1 Characterization of Waste

There are four HW characteristics. If a waste exhibits one or more of the four characteristics it is a HW. This can be determined by the user’s basic knowledge, Material Safety Data Sheets (MSDS) – in future Safety Data Sheets (SDS), or by analyzing the waste.

The four characteristics are:

Ignitable

Corrosive

Reactive

Toxic

3.1.1 Ignitable Waste (D001)

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

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

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

It is an ignitable compressed gas as determined by appropriate test methods or US Environmental Protection Agency (EPA).

It is an oxidizer.

A flash point is the lowest temperature at which a liquid can emit a vapor that will ignite when exposed to an ignition source.

Oil based paint, cleaners, and contaminated fuel

10 1 Feb 2018

3.1.2 Corrosive Waste (D002)

Waste is corrosive if:

It has a pH-value of less than 2

It has a pH-value of greater than 12.5

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

Strong acids such as battery acid and hydrochloric acid

Bases such as sodium hydroxide

3.1.3 Reactive Waste (D003)

Waste is reactive if it is an unstable material that can pose a problem at any stage of the waste management cycle. A solid waste exhibits the characteristic of reactivity if a representative sample of the waste has any of the following properties:

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

It reacts violently with water.

It forms potentially explosive mixtures with water.

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

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

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

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

It is a forbidden explosive.

Unexploded Ordnance (UXO) and flares

3.1.4 Toxicity Characteristic Waste (D004-D43) IAW 40 CFR 261.24

Waste has a toxicity characteristic if it contains one or more compounds in a concentration equal or higher than the regulatory level listed in the table below. These concentrations are determined using the EPA’s Toxicity Characteristic Leaching Procedure (TCLP) test method 1311 as stated in EPA publication SW-846. Where the waste contains less than 0.5 % filterable solids, the waste itself is considered to be the extract for the purpose of this section.

11 1 Feb 2018

EPA HW REGULATORY NO. CONTAMINANT LEVEL (mg/L)

D004 Arsenic 5.0

D005 Barium 100.0

D018 Benzene 0.5

D006 Cadmium 1.0

D019 Carbon Tetrachloride 0.5

D020 Chlordane 0.03

D021 Chlorobenzene 100.0

D022 Chloroform 6.0

D007 Chromium 5.0

D023 o-Cresol 200.0

D024 m-Cresol 200.0

D025 p-Cresol 200.0

D026 Cresol 200.0

D016 2,4-D 10.0

D027 1,4-Dichlorobenzene 7.5

D028 1,2-Dichloroethane 0.5

D029 1,1-Dichloroethylene 0.7

D030 2,4-Dinitrotoluene 0.13

D012 Endrin 0.02

D031 Heptachlor (and its epoxide) 0.008

D032 Hexachlorobenzene 0.13

D033 Hexachlorobutadiene 0.5

D034 Hexachloroethane 3.0

D008 Lead 5.0

D013 Lindane 0.4

D009 Mercury 0.2

D014 Methoxychlor 10.0

D035 Methyl Ethyl Ketone 200.0

D036 Nitrobenzene 2.0

D037 Pentachlorophenol 100.0

D038 Pyridine 5.0*

D010 Selenium 1.0

D011 Silver 5.0

D039 Tetrachloroethylene 0.7

D015 Toxaphene 0.5

D040 Trichloroethylene 0.5

D041 2,4,5-Trichlorophenol 400.0

D042 2,4,6-Trichlorophenol 2.0

D017 2,4,5-TP (Silvex) 1.0

D043 Vinyl Chloride 0.2

12 1 Feb 2018

3.2 Listed Waste

A listed HW is a waste identified on one of four lists published in the EPA regulations. The lists are divided into

F-list non-specific source wastes

K-list specific source wastes

P-list commercial chemical products

U-list commercial chemical products

3.2.1 F-list

F-listed waste at Thule AB only applies to waste that is generated from the use of certain common organic solvents. Solvents used for their solvent properties, for example - used for degreasing and cleaning. The listing only covers solvents that are above a certain concentration before use.

It is only F002 and F003 that are found in recurring waste streams at Thule Air Base.

Rags used for cleaning or degreasing and waste residue

3.2.2 K-list

K-listed waste is from a specific source on the K-list. This list includes waste from certain wood-preserving chemical manufacturing, petroleum refining, and other manufacturing processes. This list is not relevant for Thule AB.

3.2.3 P-list

P-listed waste is certain unused acutely hazardous commercial chemical products. P-listed waste is not found in recurring waste streams at Thule AB.

3.2.4 U-list

U-listed waste is an unused commercial chemical product that is not acute. There are no recurring waste streams of this type at Thule AB.

Chemicals such as acetone, ethyl ether, and methanol

13 1 Feb 2018

3.3 Hazardous Waste Mixtures

A HW mixture is a mixture of a listed HW and any other material, or a mixture of a characteristic HW and any other material - provided that the mixture still exhibits the hazard characteristic. Most mixtures of HW and other wastes or materials are classified as HW. Therefore, mixing a HW with a non-HW does not produce a non-hazardous mixture.

3.4 Hazardous Waste Residue

Any residue remaining in a container, or an inner liner removed from a container that held any commercial chemical product or manufactured chemical intermediate, having the generic name listed in Table AP1.T4 in the FGS, annotated “F”, "P" or "U" as the first character in the USEPA waste number.

Any residue or contaminated soil, water, or other debris resulting from the cleanup of a spill into or on any land or water of any commercial chemical product or manufactured chemical intermediate having the generic name listed in Table AP1.T4 in the FGS, annotated “F”, "P" or "U" as the first character in the USEPA waste number.

3.5 Container Management

Empty containers, which cannot be reused, present a problem. They add considerably to the quantities of solid waste to be disposed of, and if they have previously held HM, disposal may be environmentally unsafe and constitute high costs.

When disposing of used containers the following requirements will be followed:

Containers that have previously held non-HM can be disposed of as solid waste.

Containers having previously held HM or acute HM may be disposed of as solid waste if the container is completely empty. The definition of empty is:

A container that holds less than 2.5 centimeters (one inch) of residue on the bottom, or no more than 3% (by weight) of the total capacity of the container remain in the container (if the container is less than or equal to 110 gallons in size).

A container that has previously held an acute HM, as defined in the FGS, is considered "empty", only if it has been triple-rinsed with an appropriate solvent, or the liner has been removed. The manufacturer's Material Safety Data Sheet (MSDS) – future Safety Data Sheet (SDS) will be examined to determine if the material contains acute hazardous components.

A triple rinsing of a drum is performed using a solvent containing isopropyl alcohol, DF-8, or water depending upon the chemical that has been in the container (if in doubt, call BMC Environmental section, ext. 2698 for advice). The procedure is to pour approximately 10% of the rinsing solvent into the drum (5 gallons solvent in a 55 gallon drum). Close the bungs and slush well. Open the bungs and pour the material into a container suitable for this kind of solvent. Repeat the rinse twice. The rinse solvent is treated as HW.

14 1 Feb 2018

3.6 Lead-Based Paint

According to base maintenance contract hazardous waste includes lead-based paint.

On June 8, 2003, EPA issued a final rule to help accelerate the pace of lead-based paint removal from residences, and thereby reduce exposure to children and adults from the heath risks associated with lead. This final rule expressly allows residential lead-based paint waste to be disposed of in construction and demolition (C&D) landfills. Thus, residential lead-based paint waste may be disposed of in a C&D landfill or a municipal solid waste landfill.

VS/EE has certified analytical reports on file for building materials with lead-based paint IAW the FGS requirement to characterize and determine if waste streams are hazardous.

Construction debris containing lead-based paint does not meet the criteria of hazardous waste characterization IAW FGS and EPA Toxicity Characteristic Leaching Procedure (TCLP) test method 1311.

15 1 Feb 2018

4 HAZARDOUS WASTE STORAGE

At Thule AB, there are two types of HW accumulation and storage points:

HWAP Hazardous Waste Accumulation Point

HWSA Hazardous Waste Storage Area

All HW will be accumulated in approved accumulation and storage points.

4.1 Hazardous Waste Accumulation Point

An HWAP is an area designated for the accumulation of HW at or near the point of generation.

Any shop which generates recurring HW will have an HWAP in order to accumulate waste in accordance with the FGS. The requirements for the HWAP will ensure the waste is accumulated in a proper and environmentally sound manner.

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

In the event that new HW streams are identified, HWAPs will be established or the waste stream will be added to an existing HWAP in coordination with BMC Environmental section.

At Thule AB, HWAPs may be used to accumulate non-hazardous wastes that are unacceptable for landfill disposal IAW A071 Solid Waste Management Plan. This includes non-regulated wastes such as used glycol and e-waste as well as regulated waste that does not meet the definition of hazardous waste (e.g. PCB items such as ballasts). Requirements ‘g’ through ‘k’ in section 5.1.1 below only applies to containers used to store HW.

Documentation for HWAPs is located at BMC Disposition Services (turn-in documents, manifests), BMC Environmental section (waste analysis records, inspection records) and BMC Administration section (Training records for BMC employees).

The requirements for an HWAP are as follows:

a) A HWAP will be established at or near the point of generation.

b) Will accumulate no more than 208 liters (55 gallons) of hazardous waste, or 1 liter (1 quart) of acute hazardous waste4, from each waste stream.

c) HW that contains free liquids will be placed in secondary containment. The secondary containment will have sufficient capacity to contain 10% of the volume of all containers, or the volume of the largest container, whichever is greater.

d) Each HWAP will be designed and operated to provide appropriate segregation for different waste streams, including those, which are chemically incompatible.

e) The HWAP will be segregated from all potential ignition sources, including electrical sources, open flames, heat sources, cutting and welding operations, any smoking areas and ashtrays at a distance of 50 ft.

4 The waste listed in Appendix 1 in FGS with a U.S EPA waste number with the designator “P” or the waste with (H) following the waste number.

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f) Signs:

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

The designated HWAP area will be clearly marked, e.g. with black and yellow striped safety hazard tape or paint.

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

g) When amounts in paragraph 5.1.1.2 are met or the container is 90% filled, the container will be transferred to a HWSA within five working days. HW containers will be labeled as directed in Chapter 6.

h) Containers will be UN-approved except for containers for batteries.

i) Containers will be in a good condition (no rusting, bulging or structural defects).

j) A container holding hazardous waste will always be closed during storage, except when it is necessary to add or remove waste.

k) Containers with flammable liquids will be grounded.

l) A contingency plan will be maintained and be easily accessible in each HWAP (chapter 8)

m) Emergency telephone or radio will be available at or near the HWAP (i.e. a phone in a nearby office is sufficient).

n) Appropriate spill absorbent for the waste stored will be available.

o) Personal protective equipment will be available in sufficient amounts and appropriate for the waste stored (e.g. an eye wash station).

p) The HWAP will be orderly and not contain items or materials that are not intended for disposal or recycling via BMC Disposition Services within the designated area.

q) The Hazardous Waste Management Plan will be accessible at the HWAP.

r) Personal training requirements will be met. It is the responsibility of the shop supervisor to only assign personnel to HWAP duties after they have received hazardous waste training.

Documentation for completed training for BMC personnel is available at BMC Administration section.

s) BMC Environmental section will inspect the HWAP at least once every quarter. VS/EE will follow up on discrepancies from requirements.

t) The schedule for inspection of well managed HWAPs can be reduced by BMC Environmental section to two times per year.

4.2 Hazardous Waste Storage Area

A HWSA is an area designated for accumulation and storage of HW. In the HWSA, there is stored HW in quantities greater than 55 gallons received from one or more HWAPs. Testing and maintenance of emergency equipment is conducted at least annually.

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There are no volume limitations on the quantity of HW accumulated, and no requirements to the HWSA being located at or near the point of generation.

At Thule AB, there are the following HWSAs:

Bldg. #604 – Funded HW storage. Operated by BMC Disposition Services.

Bldg. #935 – Consolidation of HW, Waste under management. Operated by BMC Disposition Services.

Bldg. #937 – Potential HW pending analysis. Operated by BMC Disposition Services.

Drivers will have a valid ADR certificate (The European Agreement concerning the International Carriage of Dangerous Goods by Road) when transporting HW to and from the HWSA.

4.2.1 Requirements for HWSA

a. HW that contains liquids will be placed in secondary containment.

b. The HWSA will be designed and maintained to prevent fire, explosions, and release of HW/HM into the environment.

c. Access will be controlled to prevent incidental contact.

For outdoor facilities, the requirement is a fence with a lockable gate.

For buildings, the requirement is a lockable entrance to the building.

When outdoor facilities and buildings are not in use, fences and doors are kept locked. Keys are only entrusted to BMC Disposition Services HAZMAT specialists, the BMC Base Civil Engineer/Deputy Site Manager and the BMC Fire Chief.

d. A sign will be posted and will be visible from at least 25 feet from all approaches. The sign will have the following text:

English:

"DANGER UNAUTHORIZED PERSONNEL KEEP OUT"

“HAZARDOUS WASTE MANAGEMENT AREA"

Danish:

”Uvedkommende ingen adgang”

”Område med farligt affald”

Greenlandic:

”Navianartoq susassaqanngitsut iseqqusaanngillat”

”Tamanna nakkutigineqarpoq Navianartumik ilitsivik

e. Ignitable or reactive waste will be segregated from all potential ignition sources to prevent fire or explosions. These types of waste will be separated from all electrical sources, heat sources, open flames, cutting or welding operations, and smoking areas at a distance of 50 ft.

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f. Aisle space will be wide enough to allow inspection of the drums. A minimum of 4 ft. is recommended along the center aisle, and a 2 ft vertical and horizontal aisle should be provided between the other rows.

g. Incompatible wastes will be properly segregated.

h. A contingency plan will be maintained and be easily accessible in each HWSA (chapter 8).

i. Personal protective equipment will be available in sufficient amounts and appropriate for the waste stored.

j. Emergency telephone or radio, portable fire extinguisher and an eye wash station/bottles will be available.

k. Spill absorbents appropriate for the waste stored will be available.

l. A Closure Plan will be available (Appendix 6)

m. The BMC Disposition Services will prepare the EPA Uniform Manifest for all off-site shipments and maintain a copy of the manifests for at least three years after shipment. The HWSA manager will ensure that a DD Form 1348-1A, a DRMS Form 1930, and relevant support documents (MSDS/SDS, analysis report, log) accompany all HW turned in, and that the HW is funded by BMC Environmental section.

n. When stored in Bldg. #604, the containers will be placed on pallets and sufficient aisle space will be ensured between rows to allow forklift operation and ready access for inspection and possible leak response.

o. Incompatible HW will be segregated with (temporary) walls to avoid incidental mixing if a spill occurs.

p. The HWSA will be inspected weekly by the HWSA manager (self-inspection, Appendix 5).

q. The HWSA is inspected once every quarter by BMC Environmental section and annually by Fire Protection. BMC Environmental section will follow up on discrepancies from requirements.

r. Portable fire extinguishers, spill control equipment and decontamination equipment will be be available.

s. Bldg #604 and #937 are not heated during arctic winter season. Hence, no water is available to supply water hose streams, automatic sprinklers or water spray systems. Instead, water is supplied from fire trucks and the fire hydrant system.

4.2.2 Documentation for the HWSA

a. A training record for the individual that handles hazardous waste and their supervisor will be available at the HWSA.

b. Turn-in documents (Appendix 4) for the last three years will be available at the BMC Disposition Services office and in the HWSA.

1348-1A

c. A Hazardous Waste Log will be maintained at the HWSA by the HWSA manager. The inventory will be updated immediately when changes occur. The log will record number and type of containers with HW, name/address of the generator, appropriate hazard class, quantity, date, storage location and disposition data.

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d. The Hazardous Waste Log will be made available to the Fire Department.

e. Inspection records for at least three years will be maintained at the HWSA (Appendix 5).

f. Manifests for outgoing HW for the last three years. If not provided, BMC Environmental section will request signed and dated manifests from DLA Disposition Services showing final destination.

The BMC Disposition Services is responsible for maintaining this documentation.

4.3 Closure Plans

Every HWSA will have a closure plan (see APPENDIX 6) before it is opened. The plan will specify the procedures to be followed in order to achieve complete and safe closure. This includes:

a. Removal of all waste to another HWSA or by ship to continental United States (CONUS).

b. Removal of all temporary dike walls. If spills have occurred on flexible liners, these should be containerized and disposed of as HW. If no spills have occurred, the liners may be disposed of in the sanitary landfill.

c. Removal of used pallets. If any spills have occurred on the pallets or they show any visible signs of contamination, the pallets should be dismantled and disposed of as HW, otherwise they may be disposed of at the sanitary landfill.

d. Handling of any polluted soil by treatment and disposal of this as HW.

It is the responsibility of the HWSA manager to ensure a complete and safe closure of the storage area. The closure will be coordinated with BMC Environmental section.

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5 LABELING

Containers will be properly marked to indicate their use for waste accumulation and stores.

The container will be marked with one of the three labels and hazard class.

All other markings on the container from previous use will be removed before it is used for waste accumulation.

5.1 Hazardous Waste Label

Yellow label: “HAZARDOUS WASTE” is used when the waste is determined to be hazardous. The information on the label will include:

Name: Organization (e.g. 821ABG/VS/SVCS, Bldg. #237)

Address: Thule Air Base, Greenland

City: APO AE 09704-5000

US-EPA id no.: e.g. MIR 0000 36616

EPA waste no.: The EPA waste no. (stated by MSDS/SDS, or FGS, e.g. D001)

Accumulation start date: The date the drum is filled to 90% of its capacity

The proper shipping name and UN number will be written e.g., “Environmentally Hazardous Substances Solid N.O.S” UN: 3077.

White label: “THIS CONTAINER ON HOLD PENDING ANALYSIS” is used if the contents of the container are unknown and a sample will be collected for HW characterization and while awaiting analysis results: The information on the label will include:

Contents: e.g. Drum found on base

Origin of materials: Process or activity, e.g. Drum Project

Address: Organization (e.g.

821ABG/VS/OMEP, Bldg. #801)

Accumulation start date: Date of sampling

Black label: “USED BATTERIES” is used for batteries.

Shipper: Organization (e.g. 821ABG/VS/CEMR, Bldg.

#551)

Contents: Used batteries/ hazardous waste

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5.2 Non Hazardous Waste Label

Green label: “NON-HAZARDOUS WASTE” is used when the waste is determined to be non-hazardous. The information on the label will include:

Shipper: Organization

(e.g. 821ABG/VS/SV, Bldg. #237)

Contents: e.g. used developer

“Used oil” label is used for oil suitable for energy recovery - see Solid Waste Management Plan (SWMP). The information on the label will include:

Company: Organization

(e.g. 821ABG/VS/LGTM, bldg. #580)

Source: e.g. Oil changes in VM

Contact: Hazmat specialist, Shop Supervisor or waste oil truck

“Drained used oil filter” label is used for oil filters. The information on the label will include:

Accumulation start date: The date the drum is filled to 90% of its capacity. Below the “Accumulation start date” write shop name

(e.g. VS/LGTM bldg. #580)

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5.3 Hazard Class

The warning labels most commonly used at Thule AB are:

Flammable:

Hazard class 3 Flashpoint is below 140º F (60º C).

Poisonous: Hazard class 6

Corrosive:

Hazard class 8 pH-value is less than 2 or greater than 12.5.

Miscellaneous: Hazard class 9

All labels can be ordered from the BMC Disposition Services, ext. 2785. The BMC Disposition Services will identify the proper Department of Transportation (DOT) marking for each shipping container.

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6 TURN-IN PROCEDURES

6.1 Hazardous Waste Turn-in Procedure

The following procedure will be followed when HW is turned in:

a. Get a MSDS – in future SDS or analysis test results and if required the logbook for HW.

b. The waste generator characterizes the HW.

c. HW containing free liquids will always be over packed before turn-in. Containers below 55 gallons will be placed in the salvage drum that is packed with absorbent material.

d. Label the container, see Chapter 5.

e. The waste generator will in cooperation with BMC Disposition Services fill out the turn-in papers for HW:

1. Hazardous Waste Profile Sheet, (DRMS Form 1930), see APPENDIX 4

2. DD Form 1348-1A, see APPENDIX 4

f. Contact the BMC Disposition Services, ext. 2785, for weighing and transportation.

g. All HW turn-in documents will be kept on file at the BMC Disposition Services and the waste generator for a period of three years from the date of turn-in.

h. Contact BMC Environmental section for funding.

6.2 Hazardous Materials Turn-in Procedure

The procedure for turn in of HM, only batteries, is the same as for HW, except for the following:

a. A DD Form 2521 or DD Form 2522 (half the size of a DD Form 2521) will be filled out instead of the DRMS Form 1930. The form will be filled out using the information given on the material’s MSDS/SDS.

b. The original price or an estimate price will be printed on the DD Form 1348-1A.

c. The strict regulations, which apply for packaging HW, do not apply for HM, but packaging will be appropriate for transportation.

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6.3 EPA Provisional ID Number

Shortly (7 to 8 days) before the Pacer Goose departs from Thule AB to Norfolk, VA, EPA Form 8700-12 “RCRA Subtitle C Site Identification” is prepared for 821 ABG/CC signature and consequently submitted to the Virginia Department of Environmental Quality (A069 Hazardous Waste Permit). The EPA Provisional ID Number will be renewed after 30 days of the initial number, if the HW has not reached its final location.

6.4 Hazardous Waste Tracking

Training for hazardous waste specialists in tracking HW was accomplished in December 2015.

HW storage and turn-in is intended to be tracked through EESOH-MIS (Environmental Enterprise Safety Occupational Health Management Information System) database.

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7 CONTINGENCY, PREPAREDNESS AND SPILL RESPONSE

Contingency Plan: A document setting out an organized, planned, and coordinated course of action to be followed in case of a fire, explosion, or release of HW or hazardous waste constituents that could threaten human health or the environment.

The HW generators are responsible for the development and updating of the site-specific contingency plans for each HWAP/HWSA. BMC Environmental section will, if required, assist in the development and updating of the plans, which should be available in English, Danish and Greenlandic.

The plan has to be submitted to any function identified in the plan, and which the plan relies upon to provide emergency services, e.g. police department, fire department, hospital and emergency response teams.

The contingency plan will be designed to minimize hazards to human health or the environment from fires, explosions, or any unplanned sudden or non-sudden release of HW into the air, soil, and water. Specific requirements to be incorporated into the plan are described below.

Each contingency plan will contain the following information:

The most important and most detailed portion of the contingency plan is the description of the emergency procedures that will be followed for HW-related emergencies. The plan should detail response actions that will be implemented in the event of a release, fire, and/or explosion at each accumulation site.

Where HW is generated, accumulated, or stored will be evaluated to determine what kinds of emergency equipment may be necessary to abate emergencies that may be reasonably anticipated to occur at that location. A list of emergency equipment that may be used in the event of a HW incident.

The emergency response equipment can include:

- Spill booms or absorbent pillows.

- Granular absorbents (one drum for every 300 gallons stored).

- Fire control equipment, as decided by BMC Fire Protection.

- Chemical respirators suitable for the waste in storage.

- Emergency eyewash stations (bottle-type is sufficient).

- Gloves and boots.

- Face shields and safety glasses.

- Salvage drums.

Personal protective equipment will be available in sufficient amounts. BMC Environmental section will ensure, together with BMC Fire Protection, that there is enough equipment and that it is properly maintained.

If there is a possibility that evacuation from a building or the installation may be necessary, the contingency plan will include an evacuation plan.