PHNS Env Req Cont Ship Projects 9Sep11.pdf

ENVIRONMENTAL AGREEMENT FOR CONTRACTORS ON SHIP PROJECTS

Rev. September 9, 2011

1. The proper handling, transporting, and disposing of Hazardous Waste (HW) is a matter of environmental responsibility and legal obligation. This agreement shall be strictly enforced to minimize the potential for environmental fines and adverse Navy publicity. All environmental matters and assistance shall be directed to the Pearl Harbor Naval Shipyard & Intermediate

Maintenance Facility (PHNSY&IMF) Environment Division (Code 106.3) at 474-9080.

PHNSY&IMF Points of Contact (POCs):

Director, OSHE Office: 106 473-8000 ext. 4459

Environment Division 106.3 474-9080

Solid & Hazardous Waste Branch 106.31 473-8000 ext. 4580

Environmental Compliance Branch 106.32 473-8000 ext. 3019

2. Contractors shall comply with all Federal, State and local environmental rules and regulations.

3. Environmental Management System (EMS). Contractors will be aware of PHNSY&IMF’s environmental policy and will comply with EMS requirements.

4. The contractors shall appoint, in writing, an Environmental Manager for the project site. The

Environmental Manager shall be directly responsible for coordinating contractor compliance with environmental requirements and shall be onsite during work operations at all times. An alternate

(Shift) Environmental Manager shall have the same qualifications and responsibilities as the appointed Environmental Manager. The person in this position must be trained to adequately accomplish the following duties: ensure compliance with all applicable Federal, State, and local environmental requirements including the Clean Water Act (Dry-dock and Storm Water

Management); Hazardous Materials (HM) and HW Management; and the Clean Air Act

(National Emission Standards for Hazardous Air Pollutants [NESHAP]). The Environmental

Manager shall ensure compliance with waste segregation and storage compatibility requirements;

hazardous waste identification, handling, storage, documentation, and Code 106.3 disposal requirements. Duties include inspecting and managing waste accumulation areas, if required;

ensuring only authorized personnel add wastes to containers; ensuring all Contractor personnel are trained in Hawaii Administrative Rules (HAR) requirements in accordance with their position requirements; and coordinating removal of waste containers. The Environmental Manager shall maintain an Environmental Records binder which will include the Environmental Protection

Plan, if applicable, and documented environmental surveillances.

5. Contractor Environmental Brief. The contractors shall attend an environmental brief presented by the PHNSY&IMF Environment Division (Code 106.3) prior to the start of work.

PHNSY&IMF Project Manager/Representative shall coordinate the scheduling of the brief with

Code 106.3. The Government On-Site Installation Leader/POC (e.g., Alteration Installation

Team [AIT] Government Representative) shall be present at the briefing. Sub-contractors shall also be present at the briefing. The Contractor shall provide the following information to Code

106.3 prior to the briefing for review and to prepare for discussion at the briefing:

a. Name and phone number of contractor(s)’ on-site representative(s) who is knowledgeable of environmental rules and regulations and who will be the point(s) of contact in all environmental matters.

b. Types and quantities of hazardous materials to be used and wastes/wastewater to be generated.

6. Regulatory Interface. PHNSY&IMF (Code 106) will be the point of contact for interface with regulatory agencies and will coordinate inspections with the required parties. PHNSY&IMF will be notified of any regulatory inspections, meetings, inquiries, issues or requests for information specific to the operations being conducted by its contractors.

The contractors shall immediately investigate all practices cited in Notices of Violations

(NOVs)/Notices of Noncompliance (NONs)/enforcement actions and take immediate actions to remedy infractions to come into compliance. The contractor shall provide to PHNSY&IMF a written response identifying the alleged violation, investigation results, the cause generating the need for a response, remedial actions taken and preventative actions the contractor intends to take to prevent a recurrence. The contractor shall not enter into any agreement with a regulatory agency without notifying and obtaining concurrence from the Navy. Contractors shall reimburse the Navy for any monetary fines and penalties assessed against the Navy as a result of non-compliant actions.

7. Plan Submittals. The contractors shall submit the following plans to Code 106.3 for review and acceptance prior to the start of work: Environmental Protection Plan (exceptions apply when no dust, debris, pollutant, or waste is generated and no potential exists for a release to the environment), Abatement Plans (i.e., asbestos, lead), and Construction Waste Management Plan.

8. Inspections and Surveillances. Having a comprehensive and aggressive inspection and surveillance program is one of the major cornerstones to having an effective environmental management system. Contractors shall have a documented surveillance and oversight program in place. Contractors shall inform PHNSY&IMF of their inspection and surveillance program including frequency and documentation to ensure compliance with rules, regulations, and terms of this contract. PHNSY&IMF will conduct periodic environmental inspections/surveillances of operations to ensure compliance. Contractors shall provide PHNSY&IMF Code 106.3 personnel access to all spaces, operations, and records related to environmental compliance and a knowledgeable person to accompany PHNSY&IMF personnel. Contractors shall remedy any conditions found to be in noncompliance with Federal, State, or local rules, regulations and statutes. Contractors may elect to inspect the work area prior to occupancy. Any pre-existing environmental discrepancies shall be reported to PHNSY&IMF for corrective action. Prior to termination of the agreement, Contractors shall contact PHNSY &IMF Code 106 to accompany

Contractors on an inspection to resolve any environmental discrepancies (i.e., abandoned and unknown waste). All materials, tanks, items, etc. used shall be removed upon completion of the availability.

9. Work Area and Cleanliness. Contractors should inspect the work area prior to arrival. Any pre-existing environmental discrepancies shall be reported to Code 106.3 for corrective action.

Prior to the completion of the project, contact Code 106.3 to accompany the contractor on an inspection to resolve any environmental discrepancies (i.e., abandoned and unknown waste).

Contractors shall maintain the work areas in the highest reasonable state of cleanliness consistent with the work performed. Every effort shall be made to prevent pollutants from entering the harbor. At a minimum, all trash, industrial waste, mechanical or grinding debris, etc. shall be removed and properly disposed of at least once every shift or more frequently as required. No vehicle or equipment maintenance shall be performed on PHNSY&IMF property.

a. PHNSY&IMF has a Storm Water Permit which is applicable to all work being performed dock side and in adjacent laydown/work areas.

1) Good housekeeping work practices shall be implemented to prevent pollutants such as but not limited to solid waste, trash, industrial debris, rust, anodes, blasting media, etc. from entering the storm drain system and the harbor. Examples such as covering storm drain openings, placing of filter material in or around drains that may be affected or placing filtering materials in or around the work site may be used. Pollutants shall be removed to prevent contamination of rainwater runoff or entrance into the storm drain system. Debris containing pollutants (e.g., lead, chromate, paint, etc.) shall be properly disposed of in accordance with environmental disposal requirements.

2) Non-storm water discharges are prohibited from entering the storm water system.

Measures shall be taken to ensure nothing is discharged directly onto the pier, into the storm drains or into the harbor. Any generated wastewater shall be collected and properly disposed.

Washing and rinsing of equipment and personnel shall be performed in a facility connected to the sanitary sewer system, such as an approved sink.

3) Storage of Materials. Materials shall be stored in a manner that will not contribute pollutants to storm water runoff. If necessary, materials shall be covered. Keep moveable metal items more than five (5) feet from storm drains. Unpainted metal equipment and metal ship spare parts shall be covered with non-permeable coverings. Hazardous materials/hazardous waste shall be stored properly to prevent spills/releases into the environment.

10. Hazardous Materials. The contractor shall use HM from PHNSY&IMF to the maximum extent practicable. Project management will provide oversight of the proper management of the

HM handled/stored by the contractor.

11. Emergency Planning and Community Right-to-Know Act (EPCRA) Sections 312 and

313 and 20 CFR 1910.1200. Provide an inventory and Material Safety Data Sheet (MSDS) for all hazardous materials brought into the command and forward to PHNSY&IMF Division (Code

106.3). At the completion of the job, the “EPCRA Section 312 & 313 Hazardous Material

Storage/Usage Worksheet” shall be completed and turned in to Code 106.3. Information on controlled biological substances such as “Gamazyme” needs to be reviewed by Code 106.3 prior to bringing material into PHNSY&IMF.

12. Hazardous Waste (HW). Hazardous waste and empty containers generated by the contractor shall be turned in to PHNSY&IMF Hazardous Waste Facility (HWF), (Building 1663) using a Custody Transfer Form (CTF) and MSDS via the government’s Contracting

Officer/Representative.

a. HW shall be properly packaged using Department of Transportation (DOT) approved containers and labeled to identify its contents prior to turn in to Code 106.3. Contractor shall be responsible for providing DOT containers compatible with the waste generated.

b. The activity responsible for collection, sampling, and disposal of waste will be dependent upon the contract agreement.

c. Keep waste segregated. Waste shall not be combined or consolidated with waste generated from different processes.

d. Hazardous waste shall be turned in daily to the HWF at Building 1663. If hazardous waste is not turned in daily, a Hazardous Waste Satellite Accumulation Area (HWSAA) permit to store hazardous waste at or near the point of generation may be issued by PHNSY&IMF Code 106.3 at

Building 1663. Requirements on establishing and maintaining a HWSAA will be provided when a request for a HWSAA is submitted.

e. Contractors are not allowed to remove hazardous waste from PHNSY&IMF without the authorization of the PHNSY&IMF Environmental Office, Code 106.3.

13. Oil and Hazardous Substances Spills (Including Gases). Contractor or Project

Manager/Navy Point of Contact or Government On-Site Installation Leader/POC (e.g., AIT

Government Representative) shall notify the Regional Dispatch Center (RDC) at 911 for all oil and hazardous substance spills. Hydraulic oil spills resulting from manlift or forklift equipment that can be handled by the operator shall be immediately contained, cleaned up and notification made to the RDC.

14. Wastewater/Rinsewater. Contractor shall comply with the Best Management Practices and requirements of the PHNSY&IMF Water Pollution Prevention Plan, NAVSHIPYD&IMFPEARLINST 5090.8.

a. Dry-Docks: Discharges to the harbor via dry-dock, e.g., docking and undocking, industrial operations such as blasting and painting, etc. are regulated in accordance with the effluent limitations, monitoring requirements and other conditions set forth by the Dry-Dock

Permit. Wash down water is prohibited from being discharged into dry-dock drains without

Code 106.3 approval. All hull wash water subsequent to the initial hull wash down immediately after docking is prohibited from being discharged.

b. Storm Water: Non-storm water discharges into the harbor via the storm water system are prohibited by the Storm Water Permit and require controls to reduce the discharge of pollutants. No discharges of wastewater or rinsewater into storm drains, dry-dock drains or the harbor. Contractor shall prevent concrete silt and debris from flowing into existing drainage during concrete pouring and/or concrete cleaning operations. Any generated wastewater shall be collected and tested for proper disposal.

c. Sanitary Sewer System: Washing and rinsing of equipment and personnel shall be performed in a facility connected to the sanitary sewer system; such as an approved sink.

Contact Code 106.3 for assistance in disposing of wastewater.

15. Wastewater Transfer. Ensure that all wastewater transfer operations do not result in a spill. Verify positive connection of hoses at collection tank and provide a tank watch during pumping operations. Positive connection shall be verified prior to each use. Means of communication is required between source and destination of transfer/pumping operations.

Collection tanks shall be continuously monitored to ensure overfill/spill is prevented. When disconnecting or removing hoses, precautions shall be taken to prevent spillage of residual liquid in the hoses. Contingency spill kit and secondary means of spill containment (110% of tank capacity or double-walled) for oil or bilgewater tank(s) shall be employed at all times when tank is in service. The causes of spills by contractors in ranking order are: personnel error followed by equipment failure and inadequate containment.

a. Bulk collection wastewater tanks. Contractor’s tanks (collection system or tank truck) shall be clean and free of oily or chemical residue (visual cleanliness) and shall be inspected by Code

106.3 personnel PRIOR to the performance of work as required by work control documents, e.g., process control procedures. Contact Code 106.3 at 474-9080 for this to be accomplished.

16. Gas Cylinders. All gas cylinders that are used by the contractor shall be taken back by the contractor. Do not abandon compressed gas cylinders. Ensure that all gas cylinders used by the contractor have proper plugs and caps and that a 20-foot separation is maintained between fuel and oxygen cylinders when not in use for 24 hours.

17. Hydroblasting or Sandblasting Operations. Hydroblast (>100 psi) water or sandblast grit generated shall be collected, sampled and disposed of accordingly. Hydroblast water containment method shall be implemented to contain all hydroblast water generated from the process to prevent runoff entering the dry-dock drains, storm drains or harbor. Sandblast containment methods shall be employed to prevent any fugitive dust to become airborne and/or entering the dry-dock drains, storm drains or harbor. Code 106.3 shall be notified to conduct an inspection of the containment prior to the initial start of the hydroblasting/sandblasting work and prior to the disestablishment of the containment. If multiple containments will be established, each containment shall be inspected by Code 106.3 prior to use and prior to disestablishment.

The activity responsible for collection, sampling, and disposal of hydroblast wastewater or spent grit will be dependent upon the contract agreement.

18. Painting Operations. For spray-painting operations, reasonable containment methods (e.g., screen containment) shall be employed to prevent uncontrolled release of overspray. Contact

Code 106.3 for guidance when conducting spray-painting operations in dry-dock areas which are higher than 10 feet below the topside of the dry-dock. Employing over-spray containments are not required if the method of applying paint coatings is by brush and/or roller. In either method of applying coatings, spray or brush and roller, a drop cloth is required below the area that is being painted. Code 106.3 shall be notified to conduct an inspection of the containment prior to the initial start of the painting operation and prior to the disestablishment of the containment. If multiple containments will be established, each containment shall be inspected by Code 106.3 prior to use and prior to disestablishment. Keep containers closed when not in use. No air-drying of brushes, rollers, rags and containers. Ensure container integrity is satisfactory.

19. Shipbuilding and Ship Repair Surface Coating Operations -- National Emission

Standards for Hazardous Air Pollutants (NESHAP), 40 Code of Federal Regulations (CFR)

Part 63, Subpart II. PHNSY&IMF is required to control volatile organic hazardous air pollutants (HAP) for shipbuilding and ship repair surface coating operations. The NESHAP standard requires use of coatings with volatile organic compound (VOC) content below regulated limits. Keep containers closed when not in use. No air-drying of brushes, rollers, rags and containers. Ensure container integrity is satisfactory. No thinning is allowed unless a waiver is obtained from Code 106.3. In all cases, provide to Code 106.3 a usage log with the coating name, manufacturer, batch number, volume used and coating category for each marine coating applied by the end of each month or when operations end, whichever comes first.

a. NESHAP Batch VOC Certifications. Contractor shall provide Code 106.3 records of certification of the as-supplied VOC content of each batch of marine coating prior to application to a ship. Acceptable batch VOC certificates include those supplied by the manufacturer or vendor and those prepared by a laboratory qualified to perform VOC content analysis in accordance with Environmental Protection Agency (EPA Method 24. Contractor shall not apply marine coatings without having a batch VOC certificate on hand.

20. Lead and Chromate Paints. Paints containing lead or chromates greater than or equal to

0.06% by weight shall not be used.

21. Cadmium. Cadmium plated or coated material shall not be used unless no technically acceptable substitute is available.

22. Class I Ozone Depleting Substance (ODS). Return any recovered Class I ODS to the Navy

(Department of Defense ODS reserve). No Navy activity shall transfer any Class I ODS to contractors. Contract specifications and contractual actions shall not include the use of Class I

ODS nor be provided as part of any equipment for non mission-critical applications.

a. All usable Heating, Ventilation, Air Conditioning and Refrigeration (HVAC&R) equipment, e.g., air conditioners, air compressors, dehumidifiers, removed by a contractor that contains or potentially contains ODS shall have a warning label or marker affixed to the equipment with the following statement:

“WARNING: CONTAINS (ODS CHEMICAL NAME) A SUBSTANCE WHICH HARMS

PUBLIC HEALTH AND THE ENVIRONMENT BY DESTROYING OZONE IN THE UPPER

ATMOSPHERE.”

Examples of ODS chemical name are Chlorodiflouromethane, Dichlorotetraflouroethane, etc.

b. For all scrap HVAC&R equipment removed that contains or potentially contains ODS, the contractor shall ensure the following:

(1) An EPA-certified technician must evacuate the refrigerant (and compressor oil) in the entire unit using certified recovery equipment to the applicable level of evacuation (40 CFR

82.156, Table 1 for appliances or 82.156(4)(f) for small appliances). Install a permanent tag

(preferably metal tag) on the unit stating the words “REFRIGERANT AND OIL REMOVED

PER (applicable document)” along with “Name, Company or Ship and Date Refrigerant

Recovered” or similar. The unit shall include a signed statement from the person turning in the equipment verifying all refrigerants have been recovered from the equipment.

(2) The collected compressor oil shall be turned in to Code 106.3 at Building 1663 using a

CTF filled out in accordance with NAVSHIPYD&IMFPEARLINST 5090.1 (series). The collected refrigerant may be turned in to Building 1665, Storage Area 17.

23. Recycling Program. Recyclable materials are to be delivered to the Navy Recycle Center at

Building 159, 474-9207.

a. The following items are to be collected for recycling and diverted from entering our landfills.

(1) Corrugated Cardboard

(2) Empty Beverage Containers (glass, plastic, aluminum)

(3) Paper (white paper, shredded white paper, newspaper, magazines, telephone books)

(4) Printer Toner Cartridges

(5) Scrap Metal (segregate ferrous metal and non-ferrous metal)

(6) Wood (unpainted and untreated)

b. The following government furnished material is not recyclable. For proper disposal of the material refer to the contract or contact the government representative for the project.

(1) Automated Data Processing Equipment

(2) Circuit Cards and Circuit Boards

(3) Items Identified with National Stock Numbers, Manufacture Plates, Part Numbers and

Serial Numbers

(4) Material and Equipment Requiring Demilitarization

(5) Precious Metals

(6) Refrigerators, Freezers, Air Conditioners, Water Coolers

(7) Ship material and parts

24. Manlift and Forklift Equipment. An Operators Daily Checklist shall be filled out prior to operation of equipment on a daily basis. Any identified leaks or deterioration of hoses shall be noted and corrected prior to operation of equipment. At the end of shift, the manlift and/or forklift shall be positioned or located away from nearby drains and parked over a drop cloth.

Spill kits shall be staged within close proximity of manlift and forklift operations.

25. Zinc/Aluminum Anodes or Lead Ballast. To minimize release of zinc/aluminum/lead to the environment:

a. During handling of used anodes/ballast, use a drop cloth to contain debris/flakes that might break off and fall to the dock floor. This drop cloth is in addition to any dry-dock containment drop cloth that may exist. Remove all debris/flakes from the area upon completion of work and turn in to Building 1663, HWF, with a CTF in accordance with

NAVSHIPYD&IMFPEARLINST 5090.1 (series).

b. Stage and/or store “new" anodes or ballasts in a manner that prevents ground contamination and also to prevent exposure to rainwater and the environment. When not in use, new anodes and ballast should be covered at all times. Minimize staging time on the dock floor and at topside.

c. Used anodes shall be totally contained and protected from the environment. Methods include but not limited to putting anodes in closed containers or wooden boxes with covers. The intent is to contain all oxidized particles during collection, staging and transport of used anodes.

Place different anode/ballast types in separate containers and clearly identify each container.

d. Disposal Method. Used anodes and lead ballasts are recyclable and should be turned in to Navy Recycle Center, 474-9207. Material can be controlled via Material Identification

Shipping Record (MISR) tag. Excess “new” zinc/aluminum anodes or lead ballasts should be returned to Supply Department Code 521 at Building 159 or the Code 400 supervisor as appropriate.

26. Cross-Connection and Backflow Prevention. Request Shop 99’s services when connection to any dockside/pierside potable water system is required. Only Shop 99 is authorized to make connections under the cross-connection control and backflow prevention program.

27. General Refuse Sent to H-POWER. All general refuse, household trash, non-hazardous, non-recyclable trash is sent to H-POWER. The following items are prohibited from being placed into trash/refuse containers:

a. HM, HW and empty HM/HW containers – Turn in to the HWF, Bldg 1663, 473-8000 ext.

4580.

b. Oxygen Generating Devices (e.g., Oxygen Breathing Apparatus [OBA] canisters, etc) –

Turn in to the HWF, Bldg 1663, 473-8000 ext. 4580.

c. Compressed Gas Cylinders and Propane Tanks (e.g., BBQ, etc.) Turn in government issued cylinders to Defense Logistics Agency (DLA) at Storage Area 17 on Lake Erie Street.

Contact DLA at 474-2259.

d. Recyclable Items - Contact Navy Recycle Center, 474-9207 for assistance.

e. Ordnance and Munitions - Call the Base Police via the RDC at 911.

f. All waste discarded is regulated by Federal, State and Local requirements. Do NOT place the command at risk for environmental fines, safety violations or injury to personnel. BE

RESPONSIBLE FOR THE WASTE YOU GENERATE!

g. Proper disposal of prohibited items can be accomplished through the Code 106.3

Environment Division, which operates a Solid and Hazardous Waste Program. You can contact them at 473-8000 ext. 4580 for guidance.

h. Contractors shall not use government trash/refuse containers.