Attachment J-12 Enviro Guidlines.docx

Attachment J-12

Environmental Protection Guidelines for Contractors on Ship’s Projects at Pearl Harbor Naval Shipyard & Intermediate Maintenance Facility Revised July 2019

Environmental Compliance Branch Waterfront Environmental Branch 106.32 106.33

(808) 474-9080

(808) 473-8000 ext 4301

4. Regulatory Interface. PHNSY&IMF (Code 106.3) will be the POC for interaction with regulatory agencies and will coordinate interface and inspections with the required parties. The Government Contracting Officer or Representative and PHNSY&IMF (Code 106.3) will be notified of any regulatory inspections, meetings, inquiries, issues or requests for information specific to the operations being conducted by its Contractors.

Contractors must immediately investigate all practices cited in Notices of Violations (NOVs), Notices of Noncompliance (NONs) or enforcement actions, and take immediate actions to remedy infractions to return to compliance. Contractors must provide to PHNSY&IMF (Code 106.3) a written response within three (3) calendar days of completing the investigation, identifying the alleged violation, investigation results, reasons for a response, remedial actions taken and preventative actions to prevent a recurrence. Contractors must not enter into any agreement with a regulatory agency without notifying and obtaining concurrence from the Navy. Contractors must reimburse the Navy for any monetary fines and penalties assessed against the Navy as a result of non-compliant actions within 3 calendar days.

5. Contractor Environmental Manager (EM) Responsibilities and Qualifications. The EM is responsible for ensuring all parties, including subcontractors, under Contract are in compliance with Federal, State, local and PHNSY&IMF requirements.

. Qualifications. The Contractor must submit a letter, signed by an officer of the company, appointing the EM and alternate(s). The letter must state the named person(s) is responsible for managing and implementing the Contractor’s Environmental Program and has met the minimum environmental qualifications and training at time of the proposal.

b. The EM and alternate(s) must have a minimum qualification of 5 years of environmental experience and current training. EM training records must be submitted to the Government COR after award of contract but before start of work. Alternate Shift EM must have the same qualifications and responsibilities as the appointed EM on these environmental topics:

(1) Resource Conservation Recovery Act (RCRA) management of hazardous waste (40 CFR)

(2) Hazardous Waste Operations and Emergency Response (HAZWOPER) (40 CFR and HAR)

(3) Department of Transportation Hazardous Material (49 CFR)

(4) HAR, Clean Water Act, and Clean Air Act.

c. The EM and alternate(s) must have 5 years of experience to adequately accomplish their duties which include, but are not limited to (as applicable to the contracted scope of work):

(1) Compliance with all applicable Federal, State of Hawaii and local environmental requirements including:

(a) Clean Water Act (NPDES Permits).

(b) Hazardous Materials.

(c) Solid & Hazardous Waste Management.

(d) Spill Prevention Control and Countermeasures (SPCC), oil and hazardous substance (OHS) pollution prevention.

(e) Clean Air Act, National Emission Standards for Hazardous Air Pollutants (NESHAP) and Ozone Depleting Substances (ODS).

(f) Toxic Substances Control Act (TSCA) for Polychlorinated Biphenyls (PCBs) and asbestos.

(2) Waste Management:

(a) Performing upfront characterization of waste prior to generation to ensure proper management, accumulation, handling and labeling while under the control of the Contractor.

(b) Waste segregation and storage compatibility requirements.

(c) Inspecting and managing waste accumulation areas.

(d) Ensuring only authorized personnel add wastes to containers.

(e) Ensuring personnel and subcontractor(s) are trained to obtain representative sample(s), including utilization of proper sampling device(s) for specific sampling points and applying proper sampling techniques when collecting samples.

(b) Submitting training records to the Government COR within 45 days of contract award.

d. The EM or alternate(s) must be on-site during work operations at all times.

e. The EM or alternate is responsible for reviewing and approving, in writing, all environmental documents submitted to the Government (e.g., turn in documents, plans, profile sheets, etc.).

f. Environmental Records Binder. Contractor must maintain an Environmental Record Binder which includes training or qualification records, Environmental Protection Plan (EPP), and documented environmental surveillances. An EPP is not required if work is administrative in nature such as visual inspections, software installation, gauge reading, etc.

6. Environmental Compliance Assessment, Training and Tracking System (ECATTS). The Prime Contractor’s Project Manager and EM (including alternate) must complete ECATTS before start of work.

a. Log into http://www.ecatts.com.

b. Select “U.S. Navy Worldwide” located under “Go To Your Training.”

c. Create an account by typing “navfac” as the registration password in the “NEW USERS – Register Here.”

d. Fill out the Account Registration Form.

e. Select type of Contractor in the “Training Type” blank.

f. Select “Hawaii” as the Primary State where you will be working.

g. Once you receive account confirmation, log in and select “All Available Environmental Training.”

h. Select appropriate training, e.g., NAVFAC Construction Contractor (Prime), NAVFAC Construction Subcontractor (Plumbing), etc.

i. Complete all applicable training modules listed under appropriate job title.

j. Print the Certificate of Accomplishment and submit to the Government COR and Code 106.3 prior to the start of work.

7. Contractor Environmental Brief. Contractors must attend a Contractor Environmental Brief presented by Code 106.3 prior to the start of work. The Government Representative, (e.g., COR) prime Contractor and subcontractors must be present. At the briefing, the Contractor must submit a completed Environmental Checklist.

8. Plan Submittals. Contractors must submit their environmental plans to Code 106.3 via the Government COR for review at least within 45 days of contract award. Revise the plans throughout the project to incorporate changes in site condition or scope of work that could have an environmental impact. Maintain the current versions onsite. No requirement in this section will relieve the Contractor of any applicable federal, state, and local environmental protection laws and regulations.

a. Environmental Protection Plan General Information.

(1) Contractor designation letter for the EM and alternate(s).

(2) Present an overview of known or potential environmental issues that must be considered or addressed during the work.

(3) POC list to include names, position titles and emergency contact information;

duties and levels of authority assigned to personnel on the job site who oversee environmental compliance, project specific procedures, training and certifications, contact information, documentation, inspection or oversight program, storm water control and management, procedures for spill prevention and releases, clean air compliance; planned air pollution generating process (e.g., spray painting, abrasive blasting, demolition, etc.).

(4) Plan showing the proposed activity and identify the areas of limited use or nonuse. Include measures for marking the limits of use areas, including methods for protection of features to be preserved within authorized work areas and methods to control runoff and to contain materials on site, and a traffic control plan.

(5) Actions to be taken in the event of inclement weather (heavy rains, high winds, hurricanes, storms, tsunamis, etc.).

b. Management of natural resources (land resources, tree protection, fish and wildlife, historical, archeological)

c. Storm water management and control.

d. Prevention of releases into the environment.

e. Waste Management identification of types and estimated volumes of waste to be generated, procedures for documenting waste determination, management procedures for accumulation, labeling and disposition (when allowed by Code 106.3), management of used oil, etc;

f. Sampling Plan.

(1) Duties and levels of authority assigned to personnel on the job site who will perform sampling, training and certifications.

g. Clean Air Act Compliance. Identification of portable and stationary internal combustion engines that will be supplied, used or serviced on site, comply with 40 CFR 60 Subpart IIII, 40 CFR 60 Subpart JJJJ, 40 CFR63 Subpart ZZZZ and local regulations. At a minimum, include make, model, serial number, manufacturer date, size (horsepower), and EPA emission certification status of each engine. Maintain records and log hours of operation and fuel use. Logs must include reasons for operation and delineate between emergency and non-emergency operation;

h. Abatement Plan (e.g., asbestos, lead)

i. Demolition Plan

j. Surveillance Plan

9. Work Area and Cleanliness. Contractors must maintain the work areas in the highest reasonable state of cleanliness consistent with the work performed. Every effort must be made to prevent pollutants from entering storm drains and the harbor. At a minimum, all trash, industrial waste, mechanical or grinding debris, etc. must be removed and properly disposed of at least once every shift or more frequently as required. No maintenance of Contractor-owned vehicle or equipment will be performed on PHNSY&IMF property. All materials, tanks, items, etc. used must be removed upon completion of work. If Contractor material is placed in the wrong receptacle, the Contractor will be required to segregate material from the receptacle and dispose of properly.

a. The Contractor shall notify PHNSY & IMF Code 106, Regional Dispatch Center (RDC) and the Navy’s administrator of this Contract immediately (i.e., within 15 minutes of spill occurrence or discovery) regarding all spills of oil, hazardous substance, hazardous waste, fuel, sewage, gases or other chemicals. Spills include reportable quantity spills, per federal and Hawaii regulations, and non-reportable spills, including all spills into water or storm drains of less than a reportable quantity and spills that could have reached water or drains f not contained within secondary containment. To the maximum extent practicable, notification should include date and time spill occurred or was discovered, specific substance spilled, spill volume (total spilled and amount in water), operation underway when spill occurred, description of spill (e.g., size, color and movement of spill on land and water), specific response actions taken or planned (e.g. personnel safety, source id, source control, containment, cleanup, volume recovered, disposal). If not all information is readily available, spill notification should still be immediate, and additional information provided with a subsequent update. The Navy alone shall determine whether to provide assistance.

b. For any reportable quantity spill, or non-reportable quantity spill into water or a storm drain, the Contractor shall conduct an investigation into the cause or causes of the spill, including root causes (e.g., equipment failure or personnel error such as failure to follow procedures or inadequate written procedures, training, equipment maintenance or supervision). The investigation shall identify corrective actions taken, or to be taken, that will prevent future similar spills at the same or other locations where similar work is planned or ongoing, and report the findings and corrective actions taken to PHNSY & IMF Code 106 within 3 working days of the spill.

4) Fire hose or main testing water and sanitary wastes, including drinking fountains, must not be discharged into the dry dock drainage system or onto the dry dock floor. Sanitary wastes must be discharged to the sanitary sewer system with PHNSY&IMF (Code 106.3) approval.

5) Solid wastes, including spent sandblast grit, scale, rust, zinc anodes, and other debris on the dry dock floor must be expeditiously collected and removed from the dry dock floor at the end of each shift to avoid contact with and contamination of rainwater run-off. When practicable, filter material such as Scotch Foam must be used to cover dry dock drain gratings to prevent solids from entering the dry dock drain system. The Scotch Foam (or similar material) must be routinely inspected and replaced when fouled.

6) Water-tight containments, floor coverings, drop cloths, or other similar methods must be used to prevent discharges of pollutants to the dry dock drainage system.

7) Portable latrines used in the dry docks must be placed in secondary containments to prevent leakage of sewage and cleaning or disinfecting solutions from entering the harbor via the dry dock drain system. Latrines must be secured and placed on flat surfaces for stability to prevent them from falling over. Every effort must be made to prevent spills during movement of latrines.

8) Herbicides and pesticides (includes wood treated with pesticides) must not be used in the dry dock.

9) Contractors are required to perform daily inspections of the dry dock at the “end-of-daylight” hours and within 15 minutes of a rain event (when industrial work is being performed). This is a requirement of NPDES Permit No. HI 0110230 and NAVSHIPYD&IMFPEARLINST 5090.5B Dry Dock Pollution Control Plan. Contact the Government Representative or knowledgeable PHNSY&IMF (Code 106.3) personnel for inspection requirements. All inspections must be documented and submitted to PHNSY&IMF (Code 106.3) by the 7th day of the following month. For example, records for inspections performed in August are due to PHNSY&IMF (Code 106.3) by September 7. It is not necessary to perform a daily inspection if no industrial work occurs, but written records must explicitly indicate “No Industrial Work” for that specific date and also must include the information of a point of contact.

Only PHNS&IMF Shop 99 is authorized to make connections for Contractors under the cross-connection control and backflow prevention program.

14. Hydroblasting or Sandblasting Operations. Hydroblast water and sandblast grit generated must be collected, sampled and disposed of accordingly. Hydroblast water containments must be implemented to contain all hydroblast water generated from the process to prevent runoff from entering the dry dock drains, storm drains or harbor. Sandblast containment methods must be employed to prevent any fugitive dust to become airborne or entering the dry dock drains, storm drains or harbor.

Contracting Officer or Representative and PHNSY&IMF (Code 106.3) must be notified of Contractor’s plan to establish a containment; to conduct an inspection of the containment prior to the start of the hydroblasting or sandblasting work; and prior to the disestablishment of the containment. If multiple containments will be established, each containment must be inspected by PHNSY&IMF (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.

1) Class I and Class II ODS

· No Navy activity is authorized to transfer any Class I or Class II ODS to Contractors.

· Return any recovered Class I and Class II ODS to the Navy (Department of Defense ODS reserve).

· Contract specifications and contractual actions must not include the use of Class I or Class II ODS nor be provided as part of any equipment for non-mission critical applications.

2) All usable Heating, Ventilation, Air Conditioning and Refrigeration (HVAC&R) equipment, e.g., air conditioners, air compressors, and dehumidifiers, removed by a Contractor that contains or potentially contains ODS must 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 names are Chlorodifluouromethane (R-22), Dichlorotetrafluoroethane (R-114), etc.

3) For all scrap HVAC&R equipment removed that contains or potentially contains ODS, the Contractor must ensure the following:

· 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(a)(3), Table 1 for appliances or 82.156(a)(4) 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 must include a signed statement from the person turning in the equipment verifying all refrigerants have been recovered from the equipment.

· The collected compressor oil must be turned in as HW to the Hazardous Waste Facility (B1663) using a CTF filled out per NAVSHIPYD&IMFPEARLINST 5090.1 (latest) and a Safety Data Sheet (SDS) for the refrigerant.. If the collected refrigerant is Class I or Class II ODS it must be turned in to DLA Defense Distribution Center.

4) Accidental release of a refrigerant is a release and must be reported immediately to the Contracting Officer or Representative and to the Regional Dispatch Center, 911. See Spill or Release Prevention and Reporting.

1) Contractor is responsible for the proper waste determination and waste management from the point of generation until accepted at the HWF (Building 1663).

· Sandblast grit

· Oily water (except for Used Oil as defined by 40 CFR 279 or HAR Title 11)

· Fuel products

· Sanitation waste, wastewater and related personal protective equipment

· Aqueous Film-Forming Foam (AFFF)

· Empty HM containers

· Construction Debris

· Excavated Soil

· Asbestos

· Excess materials

· Expired materials

1) During handling of used anodes and ballast, use a drop cloth to contain debris and flakes that might break off and fall to the floor. This drop cloth is in addition to any containment that may exist. Remove all debris and flakes from the area upon completion of work and turn in to the Hazardous Waste Facility (B1663) with a CTF per NAVSHIPYD&IMFPEARLINST 5090.1G.

2) Stage and 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 pier side.

3) Used anodes must 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 or ballast types in separate containers and clearly identify each container.

4) Disposal Method. Used anodes and lead ballasts are recyclable and should be turned in to the Navy Recycle Center, 474-3717 or 471-0967.

c. Recycling Program. Recyclable materials must be turned into the Navy Recycle Center at Building 159,

· Corrugated Cardboard

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

Additional Environmental Requirements for Contractors; accomplish

(V)(G) CHECKPOINT – “CLEANLINESS INSPECTION (PRE-EXISTING

CONDITION)”

1. Accomplish a physical inspection of lay-down areas assigned to contractors and in the dry dock prior to start of the availability to document any pre-existing environmental discrepancies (e.g. abandoned and unknown material or waste, spills, etc.).

Submit one legible copy of a report listing the results of the inspection of 3.1 to the Code 400 SUPERVISOR, within 24 hours of completion of 3.1. Negative reporting is required.

1.1 Prior to start of work, Prime contractor’s Project Manager, first line supervisors and first line supervisors of all known sub-contractors must attend a “Contractor Environmental and Safety Brief” as scheduled by the Code 400 SUPERVISOR. PHNSY & IMF’s Environmental and Safety Divisions, Codes 106.1 and 106.3, will provide the briefing. The topics presented will include environmental and safety requirements, dry dock requirements and containment boundaries if dry dock work is involved.

1.2 Mark and identify ownership with indelible ink all Prime contractors and subcontractor’s equipment, material, and properties (e.g. gas cylinders, forklifts, man lift, pallets of paints, sandblast or paint equipment, storage containers or connex boxes, temporary lighting and ventilation ducts, etc.).

1.3 Contact the Prime contractor for coordination and connection of all potable water connections at piers, dry docks, buildings and facilities. Contractor must not make any connections to any potable water stations or connectors.

1.4 Do not discharge any wastewater (e.g. hydro water, bilge water, rinse water, etc.) directly into storm drains, dry-dock drains, or into the harbor.

1.5 Properly manage (i.e. collect, sample, mark, label, transport and dispose) all wastewater (e.g. hydro water, bilge water, rinse water, etc.) per Federal, state and local laws and regulations, unless otherwise directed by terms of the contract or Code 106.3.

1.6 Accomplish washing or rinsing of equipment and personnel in area(s) designated for such purposes (i.e. a facility connected to the sanitary sewer system such as an approved sink) or over a self-contained area.

1.7 Accomplish liquid transfers and painting operations in a manner that prevents spills, ground (pier or dry dock topside), harbor, or dry dock floor contamination.

1.8 Inspect and verify positive connection at each connection joint prior to liquid transfers and pneumatic painting operations.

1.8.1 Provide a receiving vehicle watch person who has a means of constant communication (e.g. phone, walkie-talkie, etc.) with source pump operator during liquid transfers to monitor and prevent overfill of the receiving vehicle.

1.9 Provide secondary containments, self-contained drip pans, drop cloths, or other affirmative means to prevent ground (pier or dry dock topside) or dry dock floor contamination, for receiving containers, all equipment (e.g. manlifts, forklifts, cranes, tanker trucks, etc.) and during disconnecting or removing of hoses (i.e. after pumping operations or pneumatic painting operations. Secondary containments will be able to contain 110% of the container or tank’s capacity that contains the petroleum or hazardous substance.

1.10 Provide and stage ample spill kits within close proximity of storage or accumulation areas, manlifts, forklifts, tanker trucks, receiving containers, and painting operations.

1.11 Position manlifts and forklift equipment over self-contained drop cloths and away from drains when not in use, including at the end of, and in between, each shift.

1.12 Accomplish daily “shift” inspections for each manlift and forklift equipment used on-site. Any unsatisfactory condition(s) must be noted and corrected prior to operation.

1.13 Maintain a minimum of twenty (20) feet separation between fuel and oxygen cylinders when they are not in use within a twenty-four (24) hour period. Ensure that all gas cylinders have proper plugs and caps.

1.14 Do not abandon any waste (i.e. hazardous, industrial, liquid or solid) on the Federal Property.

1.15 During all sandblasting or painting operations, contain the spent debris and overspray from entering the dry dock drains, storm drains, or into the harbor.

1.16 Collect, label, sample (representative sampling), manifest, transport and dispose of all hydro blast water or spent sandblast grit per Federal, state and local laws, and regulations, unless otherwise directed by terms of the contract or Code 106.3.

1.17 Erect containment(s) to prevent uncontrolled releases during pneumatic paint over-spray operations with purpose to prevent damage to Federal, public, or private property, including to the dry dock floor or basin area.

1.18 Install drop-cloth(s) beneath all paint mixing areas and paint application areas located on the pier or in the dry dock basin. All pier and dry dock basin areas must be covered regardless of the method used to apply the paint coatings (e.g. spray, brush, roller, etc.).

1.19 Immediately notify the Regional Dispatch Center (RDC) at 911 and the Code 400 SUPERVISOR and Code 106.3 at 474-9080 of all spills of any hazardous substance.

1.19.1 Hydraulic oil spills resulting from manlift, forklift, receiving containers, or tanker truck equipment that can be handled by the operator must be immediately contained and cleaned up.

1.19.1.1 Immediately notify RDC at 911 and the Code 400 SUPERVISOR and Code 106.3 upon completion of the clean-up.

1.20 Collect, label, fill out CTF, transport and dispose of all spill clean-up debris per Federal, state and local laws, and regulations. Contractor must be responsible for the disposal costs and associated handling and transporting costs for contractor-generated spills.

1.21 Contractor must properly fill out CTF and turn in all waste and spill debris generated on the Pearl Harbor Naval Complex to PHNSY & IMF Building 1663. Call between the hours of 7:00 a.m. to 2:00 p.m.

1.22 Paints containing lead or chromates greater than or equal to 0.01% by weight must not be used.

1.23 Cadmium plated or coated material must not be used unless no technically acceptable substitute is available. Immediately notify the Code 400 SUPERVISOR, in writing, of intended use.

1.24 To minimize release of zinc, aluminum, and lead…