J-1502000-33.a STW-07 Outdoor Painting Depainting and Corrosion Control.pdf

STW-07

Naval Support Activity Souda Bay

Outdoor Painting, Depainting, and Corrosion Control

DATE:

August 2021

DOCUMENT OWNER:

EV SWPM

AUTHORIZED BY:

IEPD

See the NSA Souda Bay EMS Manual EMP-10 Attachment 1 NSA Souda Bay Document Control Index, to locate the most current controlled version in use at NSA Souda Bay

1. Purpose

The purpose of this Standard Operating Procedure (SOP) is to establish a best management practice and procedure for outdoor painting, de-painting, and aircraft corrosion control operations.

The Final Governing Standards (FGS) for Greece require development and implementation of a Stormwater Pollution Prevention Plan (SWPPP) to control and regulate discharges of pollutants into surface waters. The FGS for Greece is the primary governing document. If there are any contradictions between the FGS and this SOP, the FGS takes priority. This SOP implements the NSA Souda Bay SWPPP for outdoor painting, de-painting, and aircraft corrosion control operations.

Small scale/spot aircraft corrosion control may occur at locations shown on Figure A-7h. Larger scale aircraft corrosion control is not typically conducted at Naval Support Activity (NSA) Souda Bay, with the exception of emergent situations and with prior approval from NSA Souda Bay CO or designated representative.

Small boat de-painting and painting is done outdoors at Marathi Pier boat lift by Base Operations Support Contract (BOSC) sub-contractors. Standard practice is to take all boats out of the water with no over water depainting or painting. The BOSC provides hazardous material (HM) storage space for sub-contractors while a job is underway. The subcontractor is responsible for handling, storage, removal, and disposal of hazardous waste (HW) generated during a job. See Appendix A: Figures 1, A-7c, and A-7e.

Small boat spot de-painting and painting is done outdoors beside the Port Operations Building. Port Operations personnel conduct spot corrosion control on Port Operations and Security boats. See Appendix A: Figures 1 and A-3a.

US Navy Ships temporarily berthed at Marathi Pier may need to conduct corrosion control on ship decks or hull.

Facility, building, and other permanently fixed equipment de-painting and painting is done throughout NAS Souda Bay.

All statements of work for task orders through the BOSC include the requirement that contractors must comply with the all BOSC contract requirements which includes compliance with the FGS. The requirement to comply with the FGS is included in all BOSC sub-contracts. All statements of work for task orders through the Job Order Contract (JOC) include the requirement that contractors must comply with the FGS.

2. Best Management Practices at NSA Souda Bay

The following BMPs have been developed for use at NSA Souda Bay. These BMPs are intended to reduce stormwater pollution in accordance with industry practice and Environmental Protection Agency (EPA) recommendations, and to provide at least equivalent protection as the BMPs listed in the FGS Table 4.5.

NSA Souda Bay Port Operations will provide this SOP as guidance to visiting Navy ships to use when conducting corrosion control on ships at Marathi Pier.

Corrosion Control

DATE:

August 2021

DOCUMENT OWNER:

EV SWPM

NSA Souda Bay Air Operations will direct visiting Navy air squadrons/detachments to use this SOP when conducting corrosion control on aircraft at NSA Souda Bay.

Outdoor painting, depainting, and aircraft corrosion control activities must use the following BMPs:

• All residues from processes to remove corrosion or damaged paint from aircraft must be collected and disposed of as HW. Contact your shops HW Coordinator or the Environmental Department HW Program Manager (EV HWPM) for detailed instructions.

• Standard practice is to take all boats out of the water. No over water depainting or painting is allowed.

• Provide a temporary berm around the work area if the potential for a spill is present.

• If pier side depainting or painting must be done, place boom around boats or ships. Any

HM release to the waters of Greece qualifies as a reportable spill.

• No de-painting or painting debris/drips are allowed to enter the waters of Greece.

• Antifouling paint materials within rinse water from marine debris removal pressure washing of boat bottoms or decks must be collected and disposed of as HW.

• Maintain good housekeeping of the work area.

• Secure all HM and HW in appropriate storage areas and in accordance with the HWMP and

HAZMAT policies and guidance.

• Do not leave any painting equipment or materials exposed to the weather when not being used.

• For small boat bottom paint depainting and painting: Use tarps or other appropriate enclosures to capture all de-painting debris from toxic bottom paints such as chips, sanding dust, sand blast residue, anti-fouling paints, soaps, and solvents. Similarly, capture all painting debris such as drips and spills of paints and thinners. Dispose of all debris including brushes and rollers etc. per HW disposal requirements.

• Typically, no outdoor de-painting, painting, or corrosion control is done on vehicles or ground support equipment. Contact Environmental Department Stormwater Program Manager (EV SWPM) if there is a need to conduct these types of operations.

• Contractors are typically responsible for their own HW disposal.

• Do not conduct de-painting or painting during rain events.

If there are any areas of this SOP that are not clear, please contact the EV SWPM for more information.

3. Definitions

BMP- Best Management Practice BOSC- Base Operations Service Contract EPA- U.S. Environmental Protection Agency EV HWPM – PWD Environmental Hazardous Waste Program Manger EV SWPM – PWD Environmental Stormwater Program Manger FGS – Final Governing Standards HM – Hazardous Material HW – Hazardous Waste IEPD – Installation Environmental Program Director

Corrosion Control

DATE:

August 2021

DOCUMENT OWNER:

EV SWPM

JOC – Job Order Contract SOP – Standard Operating Procedure STW- Stormwater SWPPP - Stormwater Pollution Prevention Plan

4. Points of Contact

Title Phone Number EV SWPM 266-1565 Cell 694-043-1277 EV HWPM 266-1973 Cell 694-043-1249