Atch_J-8_Updated_ESH_requirements _20_Sep_2010.pdf

DEPARTMENT OF THE NAVY

PUGET SOUND NAVAL SHIPYARD

AND INTERMEDIATE MAINTENANCE FACILITY

1400 FARRAGUT AVENUE

B REMERTON, WASHINGTON 98314-5001

IN REPLY REFER TO

Ser 430/341 20 Sep 10

Encl: ( 1) Environment, Safety, and Health (ESH) Requirements for the Bremerton Naval Complex as amended 15 September 2010

1. This letter transmits an amendment to the Environment, Safety, and Health (ESH) Requirements for the Bremerton Naval Complex dated 7 July 2006, reference (a). This amendment consolidates all previously issued ESH guidance or additions into reference (a) and replaces the previous amendment issued by reference (b). The amended ESH requirements document is provided in enclosure (1) to this memo.

2. The existing direction consolidated into enclosure (1) includes: the replacement of attachment 1 to incorporate the newest CHMI form; the addition of attachment 14 providing direction on disposal of non skid wastes; the addition of attachment 15 to define shipboard confined spaces; and the addition of attachment 16 providing additional requirements for scaffolding and ladders. Submission of air pollution O&M Plans is clarified and guidance on the use of PSNS & IMF LP air is added.

3. Enclosure (1) requirements are to be invoked for all work at PSNS & IMF or NBK Bremerton beginning 1 October 2010.

T. J. BRORSON

Copy to:

MEMORANDUM

From:

To:

Subj:

Head, Head, QA/ESH Division (Code 430) Contracts Division (Code 440)

UPDATED ENVIRONMENT, SAFETY, AND HEALTH ( ESH)

Ref:

REQUIREMENTS FOR THE BREMERTON NAVAL COMPLEX

( a) Enclosure ( 1) to PSNS & IMF ltr Ser 106.31/0155 dtd 7 Jul 06

( b) Enclosure 25 Jun 10

( 1) to PSNS & IMF ltr Ser 430/223 dtd

ENVIRONMENT, SAFETY, AND HEALTH (ESH) REQUIREMENTS

FOR THE BREMERTON NAVAL COMPLEX

DATED 7 July 2006

Amended 15 September 2010

Attachment 1 has been replaced and Attachments 14, 15, and 16 have been added to incorporate previously issued addendums regarding HM inventory, non-skid waste disposal, confined space determinations, and ladder and scaffolding requirements. Clarification of requirements for submission of Air Pollution O&M Plans was added (pg 13) and guidance on use of PSNS&IMF LP air was added (pg 18). All references to Code 1202 within this document shall mean PSNS&IMF Industry Management Department, Code 400. All reference to PSNS&IMF Shop 90HM shall mean Shop 99HM. Both organizations have been internally redesignated.

All amended text within the document is highlighted - except Attachments 1 and 14 - 16.

Enclosure (1) timothy.brorson Typewritten Text AMENDED 24 June 2010 (Attachment 11 replaced) timothy.brorson Typewritten Text timothy.brorson Typewritten Text timothy.brorson Typewritten Text timothy.brorson Typewritten Text timothy.brorson Typewritten Text timothy.brorson Typewritten Text timothy.brorson Typewritten Text timothy.brorson Typewritten Text timothy.brorson Typewritten Text timothy.brorson Typewritten Text timothy.brorson Typewritten Text timothy.brorson Highlight timothy.brorson Highlight

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ESH REQUIREMENTS FOR CODE 1202 CONTRACTORS AT THE BNC

SCOPE

ENVIRONMENT, SAFETY, AND HEALTH (ESH) REQUIREMENTS FOR CODE

1202 CONTRACTORS AT THE BREMERTON NAVAL COMPLEX

This specification provides environmental and safety requirements and procedures required for any work performed by Code 1202 contractors at the Bremerton naval complex (BNC), Bremerton, WA (which includes Puget Sound Naval Shipyard and Intermediate Maintenance Facility (PSNS & IMF), Bremerton site, Naval Base Kitsap (NBK) at Bremerton, and any tenant activities or ships moored within the BNC boundaries).

ATTACHMENTS

(1) Contractor’s Hazardous Material Inventory, PSNS&IMF 5090/132

(2) Contractor 's Hazardous Material Storage Location Registration, PSNS&IMF 4110/8

(3) Waste Information Sheet, PSNS&IMF 4855/612

(4) Solid Waste Tracking Sheet

(5) Monthly Project Waste Summary Report

(6) 45-/90- Day Accumulation Area Weekly Inspection Log, PSNS&IMF 5090/127

(7) Contractor Request for 45-/90- Day Hazardous Waste Accumulation Area

Certification/Recertification, PSNS&IMF 5090/137

(8) Contractor Request for Hazardous Waste Satellite Accumulation Area (SAA) Registration

PSNS&IMF 5090/136

(9) Emergency Response Procedures, PSNS&IMF 5090/9

(10) Code 106.3 Storm Drain/Sanitary Sewer Discharge Approval PSNS&IMF 5090/110

(11) Best Management Practices

(12) Elements from the Fire Safety Plan

(13) Designated Smoking Area Sign Attachments 14, 15, and 16 were added in amendment dated 15 September 2010

REQUIREMENTS

I. GENERAL REQUIREMENTS

a. All documentation/correspondence and/or communication specified in this document shall be submitted to the Contracting Officer, Code 1202 or their designated representative.

b. Environmental Mutual Understanding Meeting. Prior to beginning work, the contractor shall schedule to meet with Code 1202 and Base Environmental to discuss environmental protection requirements and to develop a mutual understanding relative to the details of environmental protection and awareness, including protecting natural resources, required reports, and other measures to be taken.

This meeting will normally occur as part of the arrival conference.

c. Environmental and Safety Compliance, General Awareness Training, and Regulatory Interface

1. The contractor is responsible for complying with the environmental regulatory notices or orders, including payment of any fines attributable to the contractor’s conduct, regardless of whether or not the contractor is the named recipient of the notice, order, or fine.

2. The contractor shall designate an Environmental Coordinator to be responsible for ensuring environmental compliance for the duration of the project. The Coordinator’s duties are to know environmental protection requirements, conduct frequent inspections of work and storage areas for cleanliness, waste management, air and water pollution controls and provide general oversight on the environmental issues associated with this contract.

3. Failure to comply with or repeated violations of local, state, or Federal regulations can result in the violator(s) losing their access to the BNC or the operation being suspended until the contractor can

15 Sep 2010 timothy.brorson Highlight provide properly trained personnel. The contractor shall provide a certificate of training upon request by Code 1202.

4. Contractors shall ensure all their personnel working at the BNC, their supervisors, and their sub-contractors, are aware of the facility-specific environmental, safety, and health requirements specified in this document.

5. All contacts with environmental regulatory agencies shall be coordinated in advance with the PSNS & IMF Environment, Safety, and Health Office via Code 1202. Documents requested by a regulatory agency must be turned over to Code 1202. PSNS & IMF Environment, Safety, and Health Office and Code 1202 will review and forward document(s) to the requesting agency. The contractor shall provide Code 1202 with a copy of any related correspondence/record of communication between the contractor and the regulatory agency in a timely manner.

d. Pollution Prevention. Pollution or waste generation shall be prevented or minimized at the source, whenever possible. What cannot be prevented at the source shall be recycled in an environmentally safe manner, whenever feasible. Pollution or waste that cannot be prevented or recycled shall be properly disposed of following the requirements of this document.

e. Weekdays/Holidays. Three days notice shall be provided to PSNS & IMF, via Code 1202, when weekend or holiday support is needed (for example; waste turn-in).

f. Definitions – Technical:

Code 1202 1. . The term used to identify the Contracting Officer and/or their designated representatives.

Contractor2. . The term contractor refers to both the prime contractor and subcontractors. The prime contractor shall ensure that his/her subcontractors comply with the provisions of this contract.

Dangerous Waste3. . Defined under WAC 173-303. This includes, but is not limited to, federal hazardous waste, extremely hazardous waste and state-only dangerous waste.

Fugitive Dust4. . Particulate matter or any visible air contaminants (smoke, dust, or fume) other than uncombined water that is not collected by a capture system and emitted from a stack, but is released to the atmosphere at the point of generation.

Hazardous Material5. . Any material, which, by virtue of its potentially dangerous nature (e.g., toxic, flammable, corrosive, oxidizing, irritating, sensitizing, reactive), requires control in its use, packaging, handling, storage, or stowage, to assure safety to life and property. This definition is intended to apply to proprietary industrial, commercial, or locally prepared blends, mixtures, formulations, or compounds of gases, liquids, and solids intended for use at the job site. This definition also includes materials such as blast grit, welding rods, and fuel. Fuel already in vehicles is exempt.

Hazardous Waste6. . See definition for dangerous waste. The two terms may be used interchangeably with one another.

Solid Waste7. . Any solid, semi-solid, or liquid waste that does not designate as dangerous waste, asbestos (ACM) waste, or PCB waste.

Volatile Organic Compound (VOC)8. . An organic compound that participates in atmospheric photochemical reactions. This excludes all compounds determined to have negligible photochemical reactivity by the U.S. Environmental Protection Agency and listed in 40 CFR 51.100(s) in effect July 1, 1998.

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9. Waste Awaiting Designation (WAD). Waste for which the designation by the Government has not been completed.

10. PCB Waste. As defined in 40 CFR 761, but does not include those PCB containing wastes regulated as dangerous wastes in Washington State.

II. MANAGEMENT OF HAZARDOUS MATERIALS

a. Hazardous Materials

1. Initial Inventory. The contractor shall submit to PSNS & IMF Code 106.34, via Code 1202, an inventory of hazardous materials during contract performance, on a Contractor Hazardous Material Inventory, PSNS&IMF 5090/132 (attachment (1)). Include all Hazardous Material (HM), except for Government Furnished Material (GFM), obtained from the Hazardous Material Control Center (HMCC) at Building 997. Include a current Material Safety Data Sheet for each item listed. See definition of HM in Section I (f). Inventory must be approved by Code 1202, prior to bringing HMs onto the BNC: Code 1202 will forward the inventory to the PSNS & IMF Code 106.34 for review. Allow 5 working days for processing the request. Submit monthly report of HM usage, no later than 5 calendar days after the end of each month, to Code 1202 for forwarding to Code 106.34.

2. Government Furnished Material (GFM). HM will be provided by the Government as specified.

Complete the Contractor Hazardous Material Inventory form, attachment (1), for HM not obtained through the HMCC at Building 997. Material drawn out of the HMCC does not require completion of the inventory form. GFM obtained through the HMCC will have a peach colored, Hazardous Substance Management System (HSMS) barcode label affixed to the container. The label signifies the material is approved and being tracked for reporting purposes.

3. Inventory Update and Usage Report. Inventory of all HM shall be updated and monthly usage reported by the 5th calendar day of the following calendar month, including GFM not obtained through the HMCC.

b. Marine Coatings

1. All coatings used on naval vessels, and their components being repaired shore side, at the BNC must comply with the marine coatings NESHAP (see Standard Item 009-97). Label all coating’s containers, or their components, with the “compliant marine coating - add no thinning solvent” labels in accordance with Standard Item 009-97.

2. Submit documentation of marine coatings Volatile Organic Compound (VOC) data as measured by EPA Method 24, if Method 24 data is not on the MSDS. This documentation is to occur with the inventory approval submission.

3. Submit monthly report of marine coating usage data, per Standard Item 009-97, no later than 5 calendar days after the end of each month to Code1202 for forwarding to PSNS & IMF Code 106.34.

NOTE: 5 days supercedes the 009-97 time requirement. Report usage by following the procedures in paragraph II (a) (3).

c. Prohibited Hazardous Material

Radioactive materials or instruments capable of producing ionizing radiation as well as materials that contain asbestos, mercury, methylene chloride, lead, chromic acid and chromates, or polychlorinated biphenyls are prohibited. Other material may not be approved for use if less hazardous material is available. Contractor requests to use any of these prohibited materials must be submitted to PSNS & IMF, via Code 1202, for approval prior to bringing any material onto the BNC.

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d. Unforeseen Hazardous Material

If material that may be dangerous to human health, or the environment upon disturbance, is encountered during contract performance, the contractor shall stop that portion of work and notify Code 1202 immediately. If the situation is an immediate threat to human health or the environment, call Regional Dispatch Center at 911 on a BNC phone, or 476-3333 on an outside line or cellular phone.

e. Hazardous Material Storage

1. Submit the form "Contractor Hazardous Material Storage Location Registration" to PSNS & IMF Shop 90HM via Code 1202, for the registration and disestablishment of hazardous material storage locations (HMSL). See attachment (2) for a copy of the form. Post a copy of the completed registration at the HMSL. When disestablishing the HMSL, mark the date closed on the completed posted form, and submit it to Shop 90HM, via Code 1202.

2. Post a sign reading "DANGER - FLAMMABLE MATERIAL - NO HOT WORK WITHIN 50 FEET" in areas where flammable and combustible liquids are stored. Sign is available from Shop 90HM via Code 1202.

3. Label flammable liquid storage cabinets not equipped with self-closing doors with the words "KEEP DOORS CLOSED." Labels are available from Shop 90HM via Code 1202.

4. Code 1202 is responsible to coordinate the possible availability of lockers with PSNS & IMF Shop 90HM for GFM issued by PSNS & IMF.

III. WASTE MANAGEMENT

PSNS & IMF is the owner of all waste (solid, dangerous or otherwise) generated within the BNC. This includes all waste generated by contractor personnel while working at BNC.

a. Waste Identification and Designation

1. Any item or material not incorporated into the project and that is not reusable without reclamation is a waste. Government material destined for disposal, recycling, salvage, or reuse by the contractor is also a waste.

2. The contractor is responsible for identifying all wastes to be generated or produced during performance of this contract. They shall complete Section I of a Waste Information Sheet (WIS) (attachment (3)) for each waste generated. Instructions for completing the WIS are provided on the back of the form. Provide the Material Safety Data Sheet and other supporting data as requested. To the maximum extent practicable, the contractor shall submit the WIS in time to complete designation of the waste before it is generated. WISs shall be submitted to PSNS & IMF Code 106.34, via Code 1202, for designation. Allow a minimum of 5 working days for processing the WIS; more time will be required when sampling is necessary.

NOTE: It is extremely important that generation of bulk waste (e.g., flushes) be discussed with Shop 90HM and Code 106.34 via Code 1202 prior to generation. See this section, paragraph (e) (4), page 6, for oily waste. Discussion may reduce the generation of dangerous waste or waste that won't be amendable to on-site treatment. If discussions fails to occur and it is discovered that it would have prevented dangerous waste or use of on-site treatment of waste, the contractor will be responsible for the cost of disposal. See Attachment 14 for non skid waste management requirements.

3. Upon receipt of the WIS, PSNS & IMF Code 106.34 shall designate the waste identified on the WIS and shall perform any analysis required for designation of waste. Upon completion, the WIS will be returned to the contractor via Code1202. The contractor shall manage the waste in accordance with direction in Section IV of the WIS and this contract. Notify Code 1202, 14 calendar days in advance for request of bulk containers.

15 Sept 2010 4 timothy.brorson Highlight

b. Waste Awaiting Designation

1. Waste awaiting designation (WAD) (i.e. waste for which Government designation as dangerous, or non-dangerous (solid) waste has not been completed) in non-bulk containers, shall be turned over to the Government at a location specified by Code 1202 prior to the end of each work shift.

2. The contractor is responsible to manage off-hull bulk containers of WAD in a dangerous waste accumulation area, following the procedures in Section III (f) through III (j). Management and disposition will be based on final designation via the WIS.

3. The contractor will complete Sections I and II of a WIS, and attach an ID label (PSNS 5090/82) on each container of waste. Include the letters “WAD” in the space below the “ID” located on the left side of the ID label. The WIS shall be processed in accordance with Section III (a) (Waste Identification and Designation).

c. General Waste Management Requirements

1. The Government will arrange for the recycling or disposal of all waste except asbestos, or blast media that is not acceptable to recyclers. The contractor is responsible for the storage, transport, and disposal of asbestos only waste. See Section III (k). See Section VI (b) for blast media criteria.

2. All non-bulk waste awaiting designation (WAD) and dangerous waste shall be turned over to the Government at a location specified by Code 1202 for accumulation and disposal prior to the end of each work shift. Each container (or group of containers) of waste turned over shall be accompanied by a Waste Information Sheet (WIS). Reference the WIS providing the designation for the waste when not

WAD.

3. All bulk WAD and dangerous waste will be managed by the contractor in a dangerous waste accumulation area

4. In no event shall any waste, including wastewater, be disposed of in the storm sewer system or dry dock drainage systems.

5. Discharge to the sanitary sewer is also prohibited without written authorization from Code 1202 via the Waste Identification and Designation Process (Section III (a)).

d. Salvageable, Reusable and Recyclable Wastes. Source segregate recyclable items and place in containers designated for each commodity.

e. Solid Waste

1. Waste, designated as solid waste, shall be segregated at the source and containerized to prevent spills or discharges to the environment.

2. Cover and contain all solid waste as to prevent it from blowing away and to prevent water run-on or run-off. The area around the solid waste collection areas shall be kept clean and free of debris.

3. Prior to the end of each work shift dispose of solid waste in containers specified by Code 1202.

4. Oily Waste:

(a) Submit a WIS for pre-designation. Non-synthetic oil (uncontaminated with a dangerous waste), which pre-designates non-hazardous, will have instructions on the WIS to contact Shop 90 to conduct a jar test. If the jar test fails, the pre-designation is void; manage as WAD and submit a new WIS for a new designation.

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(b) Label containers used to store used oil with the ID label, PSNS 5090/82, marked with the words "Used Oil". Label oily wastewater containers with the ID label, marked with the words “Oily Wastewater.”

(c) Secondary containment requirements specified in Section IV (3) apply.

(d) Prominently mark the area as an "Oil Collection Area." Prominently display "No Smoking or Open Flame" and the Emergency Spill Procedures Poster (attachment (9)). Smoking in an oil collection area is prohibited.

(e) Used oil, which passes a jar test, will be transferred to the on base Oily Wastewater Treatment System, managed by Shop 90.

(f) Manage other used oil based on its designation and direction on the WIS.

5. Contractor disposal of Non-Recyclable Blast Grit:

(a) Containerize to prevent spills or discharges to the environment. The area around the collection areas shall be kept clean and free of debris.

(b) Track disposal by use of the Solid Waste Tracking Sheet (SWTS), attachment (4), for each shipment. If scales are not available, calculate the weight based on the formula provided in the Monthly Project Waste Summary Report (e.g., 3 cubic yards multiplied by 250 = 750 pounds). The SWTS shall be summarized monthly on the Monthly Project Waste Summary Report, attachment (5). This package shall be submitted no later than the 5th calendar day of the following month to Code 1202.

(c) Solid Waste Pickup Options. Ensure transporter has the SWTS before leaving the BNC.

Hand-off exchange is preferred, but when a face-to-face hand-off is not possible, the following procedure is required:

(1) Firmly affix a clear (no colors), waterproof envelope to the front left corner of the accumulation container (a zipper sealed baggie, duct-taped to the box is acceptable.) At the end of the shift prior to pick-up time, inspect the box, complete the applicable portion of the SWTS, and place it in a waterproof envelope.

(2) The transporter removes the SWTS from the envelope, signs on the appropriate line, and provides it to the receiver for signature at the disposal site. The receiver completes their portion of the SWTS and returns it to the contractor.

(3) When no SWTS is in the envelope, the waste will not be transported for disposal.

(d) Containers of solid waste shall be emptied no less than once per week, or as otherwise permitted by Code 1202. The waste must be contained and covered during transport to prevent littering. At project completion, leave the areas clean.

(e) Solid waste shall not be taken to any site that has not been approved by Code 1202 prior to removal from the worksite. Contractor is responsible to ensure no disposal action is taken that can be construed as illegal dumping. Waste shall be hauled to a facility permitted to handle that type of waste, and vehicles and haulers used for the transportation of solid waste shall be permitted, licensed or otherwise approved by the applicable County Health District(s). If the contractor is to dispose of waste at the local transfer facility, the completed SWTS will need to be presented to transfer facility personnel before the waste will be accepted.

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(f) When required by the receiving facility, submit a completed Waste Disposal Application to

Code 106.34 for approval and joint signature, via Code 1202. Any additional testing required by the local health officer, is the contractor’s responsibility.

f. Dangerous Wastes, PCB Wastes

1. Under no circumstances shall the contractor remove dangerous waste, or PCB wastes from the BNC premises. PSNS & IMF will retain ownership of all waste.

2. Prior to the start of any work that will result in the generation of dangerous waste, or PCB wastes, contact Code 1202 to obtain arrangements for turn-in of non-bulk waste.

3. Containers and labels shall be provided by PSNS & IMF Shop 90HM, upon request through Code 1202. Containers and labels are available for pick-up in the Controlled Industrial Area, Bldg. 367 of PSNS & IMF, Monday through Friday between the hours of 0745-1600. Back shift hours (1600 – 2350) are available upon request. Bulk containers require 14-calendar day notice.

4. Label containers with an ID label, PSNS 5090/82 to identify the type of waste. Apply waste label(s) and DOT label(s) as specified on the WIS.

5. Turn non-bulk waste over at a pre-arranged location prior to the end of each work shift. A WIS, with the shaded portions of Sections I and II completed, shall accompany the waste. The WIS shall be processed in accordance with Section III (a) (Waste Identification and Designation).

g. Accumulation Area for Bulk Waste Awaiting Designation and Dangerous Waste

1. Accumulate in an approved satellite or 90-day accumulation area meeting the requirements set forth in WAC 173-303 and this document. 90-day areas are referred to as 45/90-day areas at the BNC. The 45-day is to flag the waste for turn in or initiation of off-site shipment to ensure 90-days is not exceeded.

For simplicity, the term 90-day is used in this document, but forms will use the 45/90-day term.

2. Bulk dangerous waste must be managed in a 90-day accumulation area. Bulk waste awaiting designation (WAD) may be managed in either a satellite or 90-day accumulation area.

3. Provide an accumulation area operator (AAO) to manage accumulation areas (including waste awaiting designation (WAD)). The AAO must be on site when dangerous waste or WAD is being generated.

4. Submit to Code 1202, once every 7 calendar days, an accumulation area inspection record meeting the requirements set forth in WAC 173-303 for 90-day accumulation areas. Attachment (6) meets those requirements for an inspection record and is available for use from Code 1202.

5. Containers of ignitable or reactive waste must be located at least 50 feet from the BNC fence line, unless located inside a building or when in transit.

6. Containers of dangerous waste and WAD must be segregated from each other and all other items.

7. Comply with the following Special Restrictions for Wastes and Accumulations.

(a) Satellite accumulation over-water, such as on piers, is not authorized unless waste is accumulated with secondary containment and is attended by an Accumulation Area Operator (AAO) at all times. Satellite areas are authorized inside dry docks.

(b) Equip and locate all flammable, reactive, and Extremely Hazardous Wastes (EHW) as defined in WAC 173-303 with impermeable secondary containment capable of containing 100 percent of the largest container in the containment or 10 percent of the total volume of all

7 7 July 2006 containers, whichever is greater. If secondary containment is not protected from the rain, provide additional capacity for 4 inches of rain.

(c) Provide secondary containment for all transfers of liquid EHW's from one container to another and for all liquid dangerous waste accumulated within 50 feet of a storm drain.

(d) Ninety-day areas will not be authorized in dry docks, on piers, or over-water sites. All waste in 90-day areas requires secondary containment. Maintain a 36-inch aisle space in accumulation areas.

h. Registration and Closure of Dangerous Waste Accumulation Areas

1. Registration of satellite areas and 90-day areas are required prior to waste accumulation.

2. Submit to Code 1202, a Contractor Request for 45/90-Day Hazardous Waste Accumulation certification and Re-certification form, see attachment (7), and or a Contractor Request for Hazardous Waste Satellite Accumulation Area (SAA) Registration form, see attachment (8).

3. Notify Code 1202 of any changes in accumulation areas including closure. Closure of 90-day areas requires inspection and approval by Code 1202.

i. Procedure for Turn-In of Dangerous Waste to the Government

1. Contact Code 1202, no more than 45 calendar days from the start date, for 90-day accumulation areas to arrange for the turn-in or off-site transport.

2. Contact Code 1202 to arrange for the possible turn-in, to the Government, of bulk dangerous waste from satellite accumulation areas, prior to exceeding the time and quantity limits. If the Government is unable to accept the waste within the time limits, the contractor is required to convert the SAA to a 90-day accumulation area.

j. Dangerous Waste Training

1. Train all personnel to perform their duties in a way that ensures compliance with WAC 173-303 for Large Quantity Generators and this document for dangerous waste management. Keep all training records at the job-site and ensure they are available upon request.

2. Train the AAO in the 2-hour, facility specific hazardous waste course provided by PSNS & IMF Code 106.33. This course will be provided once and is paid (instructor's fee only) for by the Government.

The course will be conducted at the job site unless otherwise specified. All AAO'S must complete the training prior to the generation of waste awaiting designation and dangerous waste. Schedule training with Code 1202 a minimum of 14 calendar days prior to generating waste. Train the AAO in the PSNS & IMF provided station specific 1 hour refresher course within 1 year from the initial course. The contractor is responsible for additional AAO training, after the PSNS & IMF provided one has been given, using the course outline from the facility specific course.

k. Asbestos Containing Material (ACM) wastes. Remove, manage, and dispose of asbestos in accordance with Puget Sound Clean Air Agency, Regulation III, Article 4. Dispose off-site within 10 days of generation. Submit a copy of the Asbestos Waste Shipment Record (AWSR) to Code 1202 after the initial transporter signs off and before the waste is taken off-site. Code 1202 is to provide a copy of the AWSR to PSNS & IMF Code 106.31. Submit a copy of the completed AWSR for forwarding to PSNS & IMF Code 106.31, within 20 days of waste shipment for disposal. For projects located at NBK, submit copies of the AWSR to NBK at Bremerton, Code N45A4.

IV. SPILLS

All contractor personnel, including subcontractors, performing work at the BNC, must be aware of and understand spill prevention, spill events, and the proper response for each type of event. The PSNS &

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IMF Emergency Spill Procedures Poster, PSNS 5090/9 (attachment (9)), shall be posted at the work site or otherwise immediately available for employees.

a. Spills Prevention

Contractors shall take all reasonable and necessary precautions to prevent Oil and Hazardous Substances (OHS) from reaching the air, ground, or waterway. Reasonable steps, at a minimum, shall include the following.

1. Place a spill response kit at or near hazardous material and dangerous waste handling and transferring work sites. Post the list of the materials for the spill kit.

2. Place oil and hazardous substances (OHS) in approved containers. Inspect containers to ensure integrity prior to the transfer of material and storage of oil and hazardous substances. Secure all containers (i.e., drum covers on) when not in use. Store all containers in approved lockers or facilities, which are maintained in a clean and orderly manner. Secure or empty all containers prior to transportation.

3. Protect storm drains, catch basins, manholes, and floor drains within 50 feet of OHS operations with a mat, plug or other suitable device to prevent flow into subsurface distribution systems.

4. For the contractors OHS equipment: All OHS containers with a capacity of 55 gallons or more must be located in an impermeable secondary containment. The containment must be capable of containing 100 percent of the largest container in the containment or 10 percent of the total volume of all containers, which ever is greater. Where possible, cover the containment to prevent the accumulation of rainwater. If secondary containment is not protected from rain, provide additional capacity for 4 inches of rain. For known, uncontaminated rainwater that does accumulate, follow the requirements in Section V for discharge. For contaminated rainwater, follow the requirements in Section III.

5. Vehicle and Equipment Operations. Restrict vehicle and equipment fueling operations to designated areas as specified. Provide these designated areas with measures that prevent contamination of stormwater runoff. Vehicle and equipment cleaning, maintenance, and awaiting maintenance areas are prohibited, unless otherwise approved by Code 1202, in conjunction with Code 106.3

6. Work Site Cleanup. Keep work site clean to minimize loss of accumulated debris when it rains.

Clean up as necessary to maintain control of potential pollutants.

7. Implement additional preventative measures required to minimize the potential of any spill event, such as using tarps, drip pans, and proper storage.

8. Transfers of OHS over water shall not be considered routine. Oil and fuel transfer evolutions are subject to the requirements of 33 CFR Parts 154 and 156. Tank cleaning effluent and bilge water are considered “oil” and the subsequent transfer of this material is considered an oil transfer evolution.

(a) Oily wastewater, fueling, defueling, and internal fuel transfer evolutions should only be accomplished when operationally necessary.

(b) Provide a qualified Person in Charge (PIC) at both the transfer and receiving points, to supervise transfer operations.

(c) Tank and bilge cleaning transfer operations require a Coast Guard approved Operations/Mobile Transfer Manual, per 33 CFR Part 154.100. In addition, current hose testing records that meet the requirements of 33 CFR Part 154.500 and documentation that transfer personnel are qualified as PICs per 33 CFR Part 154.710, are required.

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(d) Notify PSNS & IMF Shop 90 and Code 106.33 via Code 1202, at least three days in advance of any OHS transfer.

(e) The contractor must schedule and conduct an Operational Risk Management (ORM) meeting prior to all petroleum transfer operations (diesel, JP-5, lube oil, hydraulic oil, etc.). The ORM meeting is to ensure that proper spill mitigation and response measures are in place. Attendance shall include Code 1202, PSNS & IMF Shop 90 and Code 106.33, the Fire Department and, for ships under overhaul availability, the appropriate project personnel, Temporary Services Zone Manager or Ship Safety Officer/Ship Safety Supervisor (SSO/SS). For homeport ships, the Homeport Office shall attend. The Shipyard Watch Officer and NBK CDO (for home ported ships) must be notified of all ORM meetings and transfer schedules but are not required attendees at meetings.

(f) The contractor may conduct a pre-transfer brief among all parties to the transfer, in lieu of an ORM meeting, for oily wastewater transfers. Items to be discussed, during the pre-transfer brief, include but are not limited to: type and quantity of product to be transferred; communications; emergency procedures; and roles and responsibilities for all personnel involved in the transfer. Attendance shall include Shop 90, Code 106.33, and contractor personnel. For ships under overhaul availability, the project ESH manager is an optional attendee.

9. OHS transfer operations are generally prohibited between sunset and sunrise. Should a nighttime transfer be required, the contractor must request written permission from Code 1202. Code 1202 must obtain permission, with 24-hour notification, from Commander Navy Region Northwest via PSNS & IMF Code 106.33, the PSNS & IMF Watch Office or the Homeport Office (whichever is applicable).

b. Spill Event

A spill is any unpermitted or uncontrolled release of oil or a hazardous substance to the water or ground or ship systems such as bilge water, or CHT, etc. This includes any spilling, leaking, pumping, emitting, discharging, injecting, escaping, leaching, disposing, or dumping of liquid or solid material not authorized by the contract. There are two types of spill events, emergency and non-emergency.

c. Emergency Spill Event

Any spill event meeting one or more of the following criteria is an emergency spill event.

1. Is an immediate threat to human health or the environment, or

2. Is a material not known to the person discovering the spill, or

3. Has the immediate potential to enter or has entered a drain or waterway, or sanitary sewer, or migrate off BNC property, or

4. Requires assistance from the BNC for cleanup, or

5. Is more than 10 gallons.

d. Non-emergency Spill Event

1. Is not an immediate threat to human health or the environment, and

2. Is a material known to the person discovering the spill, and

3. Has not entered, and does not have immediate potential of entering a waterway or waterway inlet (e.g., storm drain, sanitary sewer manhole, etc.), and remains on Government property, and

4. Can be cleaned up safely by contractor personnel without assistance from the Government, and

7 July 2006 10

5. Is 10 gallons or less.

e. Spill Response Procedures

1. The following applies to emergency spills caused by the contractor during contract performance:

(a) Immediately notify the Regional Dispatch Center by calling 911 on BNC phone, or (360) 476-3333 on a non-BNC or cellular phone.

(b) Isolate the spill area and stay upwind until arrival of the BNC clean up crew.

(c) If the properties of the spilled material are known, providing it can be done without endangering the safety or health of the contractor or other personnel, try to stop the spill and/or contain the spill to prevent it from going into drains or waterways

(d) The contractor shall then notify Code 1202.

(e) The Government will respond to all emergency spills.

(f) The contractor may be requested to assist the Government clean-up crew, by providing available technical data (e.g., MSDSs and waste profiles) the contractor possesses on the material spilled shall be provided upon request to emergency response personnel.

(g) The contractor shall assist shipyard personnel in the preparation of spill reports if requested.

(h) The BNC will provide to Code 1202 all relevant data necessary to determine financial impact and liability of the spill and reimbursement for assistance of spill clean up and disposal services. The contractor shall reimburse the Government for spill response, clean up and disposal services.

2. The following applies in the event of a non-emergency spill, caused by the contractor during contract performance:

(a) Stop the source of the spill, contain the spilled material and keep it away from drains or waterways. Block any drains near the spill if there is a chance the spill will reach them.

(b) Wear the proper personal protective equipment while cleaning up a spill.

(c) Turned waste debris over to the Government accumulation area operator as waste awaiting designation.

V. WATER POLLUTION

a. Water Pollution Control. Provide a WIS per section III (a) (Waste Identification and Designation) for each unique type of wastewater generated. In no event shall waste or any other material be disposed of, or be allowed to enter, into dry dock drainage system, Sinclair Inlet or the storm sewer system.

Discharge to a sanitary sewer drain (e.g., sinks & toilets) is prohibited unless prior authorization has been obtained (via the Waste Information Sheet). Allowing non-approved discharges may result in a direct violation of regulations and/or permits issued by the Environmental Protection Agency (EPA), or the Washington Department of Ecology (WDOE).

b. Storm Drain Discharge. Nothing is to be poured or allowed to drain into any storm drain system without the express permission of Code 1202. Discharge of known uncontaminated water may be discharged to the storm sewer by obtaining approval through submission of the form "Code 106.3 Storm Drain/Sanitary Sewer Discharge Approval," PSNS 5090/110. Attachment (10) is an example of the form and includes the types of operation allowed and the criteria to be met. Submit the form to PSNS & IMF, Code 106.32 or fax it to (360) 476-8550 via Code 1202.

c. Shipboard Liquid Waste Discharges. Shipboard liquid waste (e.g., liquids resulting from draining, cleaning, flushing, testing systems on naval vessels) disposal generally do not need a WIS, unless it has to

11 7 July 2006 be collected for treatment at PSNS & IMF's Industrial Wastewater Pretreatment Facility (IWPF) or disposed of as hazardous waste. Guidance for shipboard liquid waste disposal is provided in IPI 0505- 903 and shall be used by Code 1202 to determine the disposition of shipboard liquid wastes. Code 1202 shall complete the Wastewater Disposal Report form as specified in IPI 0505-903, and submit it to the project ESH manager (primary) or Code 106.32 (alternate) for approval and/or recordkeeping. Manage liquid wastes not covered by the IPI in accordance with Section III.

d. Hull Preservation Work Requirements

1. Dry Dock Process Water Collection System (PWCS). In the normal mode of operation (AUTO) the PWCS is designed to route "contaminated" storm water runoff to the sanitary sewer, or to a treatment system. Only clean water is routed to Sinclair Inlet.

2. Initial Hull Wash. An initial hull wash (at pressures less than 150 psi, without detergent, brushes, brooms, scrappers, etc.) to remove salt and marine growth immediately following dry docking is allowed, prior to placing the PWCS in AUTO mode. The wash must be performed as soon as possible after docking. Contact the project Environment, Safety, and Health (ESH) Manager via Code 1202 for inspection of the hull for flaking paint. Flaking paints shall be captured separately from the sea growth waste and disposed of as hazardous waste via the WIS process. Sea growth shall be doubled bagged, marked with the word "Sea Growth" and disposed of in a regular trash dumpster.

3. Hull Pressure Washing/Hydroblasting

(a) All pressure washing/hydroblasting wastewater must be collected for treatment.

(b) During the planning stage the contractor must meet with the project ESH Program manager, Shop 90, and Code 106.32 to work out a plan to collect pressure washing/hydroblasting wastewater. This plan must be submitted for approval by Code 106.32 and Shop 90 via Code 1202. (Note: The contractor must cease all pressure washing /hydroblasting operations and clean the cofferdam when the treatment system is overwhelmed due to heavy rainfall or when the treatment system stops operating.)

(c) Ensure the dry dock drainage channels and sand traps remain clear of staged production equipment and material such that flow is not restricted.

e. Best Management Practices

Identify potential sources of pollution, which may reasonably be expected to affect the quality of stormwater discharge from the site and select from the list of mandatory Best Management Practices (BMPs) provided in attachment (11). If the applicable BMPs are not effective in preventing the discharge of pollutants, then select and implement additional BMPs from EPA 832-R-92-005 and Washington State Department of Ecology, Stormwater Management Manual for Western Washington.

VI. AIR POLLUTION CONTROL AND REPORTING

a. General Requirements

1. Marine coatings shall be used as supplied; no thinning is allowed.

2. Respond to Code 1202 in writing within 2 working days, whenever a NESHAP violation has been detected. Provide details of corrective actions taken as specified in the written request.

3. Report the usage of Volatile Organic Compounds (VOCs), Toxic Air Contaminants, blast grit usage (either blast nozzle through put in tons: or blast nozzle diameter, vessel pressure, media type, number of nozzles and total hours of operation), weld rods and filler metals (include AWS type and process) used to Code 1202, see Standard Item 009-02. Report fuel used for the operation of portable internal combustion

7 July 2006 12 engines (e.g., compressors and generators) but not mobile sources such as vehicles and material handling equipment. Completion and submission of the Contractor Hazardous Material Inventory (attachment (1)), as specified in the Hazardous Material section, will satisfy this reporting requirement. For portable/stationary internal combustion engines, also provide a description of the engine (including make, model, size, horsepower, hours of operation, and volume of fuel consumption. The reports will be made monthly. Marine coating use reporting requirements are specified in Section II.

4. Use of air contaminant generating equipment and air pollution control equipment may be authorized under existing PSCAA registered operations. The contractor shall identify, prior to start of work, the equipment to be used to PSNS & IMF Environment, Safety, and Health Office, via Code 1202.

PSNS & IMF will determine need for a Notice of Construction/Order of Approval. For portable (skid or trailer mounted) internal combustion engines, identify the make, model, size and brake horsepower.

5. For equipment not authorized under existing PSCAA equipment registration or otherwise exempt under PSCAA Regulation I, the contractor is responsible for coordinating submission of the Notice of Construction (NOC) with PSNS & IMF Code 106.31 via Code 1202. Provide a copy of the NOC application and Order of Approval to PSNS & IMF via Code 1202.

6. Submit an air emission equipment Operation and Maintenance (O&M) Plan to Code 400, and receive Government approval of the plan prior to using the equipment and comply with approved plan.

Maintain the O&M plan and any associated records on site for the duration of the project. Be prepared to provide those records for review promptly (goal is 20 minutes), when requested by regulatory agencies such as PSCAA, following the procedures specified in Section I (c)(5). Submit copies of records, required by the O&M to Code 1202 within 5 calendar days after the end of each month. The O&M plan must contain at a minimum the following elements:

(a) Maintain all equipment in good working order, through following manufacturer's operation and maintenance recommendations at a minimum.

(b) Maintain records of any repairs made, including records of preventive maintenance.

(c) Periodic inspections, including but not limited to, evidence of fugitive emissions.

(d) Ensure deficiencies are promptly repaired. Secure operation of such equipment if immediate repairs are not feasible.

(e) When fugitive emissions are found, determine whether reasonable precautions are being taken to minimize such emissions.

(f) Requirements to repair the equipment or shut down operations when reasonable precautions are not being taken to minimize fugitive emissions.

(g) Any requirements listed as conditions on the Order of Approval for the equipment, if applicable.

(h) Records generated to demonstrate that these actions (e.g. inspections/maintenance/corrective actions) have been completed, including the location, date, time, and name of persons completing the actions. Records may be in the form of a logbook.

7. Minimize dust emissions by using Best Available Control Technology (BACT). Dry power brooming is not permitted. Instead, use vacuuming, wet mopping, wet sweeping, or wet power brooming (collecting any wastewater for disposal). Confine over spray from outdoor spray painting to the work area where painting is occurring, use tarps, shrink-wrap, mobile attachments, or similar methods of over spray control. Employ water sprays or total attachment (or both) at material transfer points in the area in which visible dust is generated. Ensure water spray does not cause run-on/run-off concerns. Provide covers, wetting of materials or adequate freeboard as necessary to prevent loss of particulate matter in transit. Provide and position floats or tarps adjacent to and under the work area to contain fugitive

13 15 Sept 2010 timothy.brorson Highlight emissions for over-water work. Secure grinding, blasting, material transfer and painting during windy periods when other BACTs are not effective.

b. Abrasive Blasting

1. Blast media, which is either recovered, recycled and reused on site or can be recycled off-site after use, is required. Economic feasibility will be considered for exceptions to this requirement. Use of an additive product, Blastox or similar, which minimizes the generation of hazardous waste is required when lead, or other heavy metals are a constituent of the coating to be removed. This requirement does not apply when using steel shot, steel grit, or steel shot/grit mixtures as the abrasive media in recovery/recycle blasting systems.

2. Use of silica sand is prohibited in sandblasting. Blast media must contain less than 3% magnesium and be acceptable for recycling into concrete. Products used with the resulting waste not being recyclable to recyclers will be the contractor’s responsibility for disposal, if designation is a solid waste. In the event the contractor is responsible for disposal of solid waste, follow the procedures in section III (e) (5).

3. Control fugitive emissions from loading and unloading abrasive blast media.

4. Perform blasting operations inside an enclosure equipped with emission collection devices. For outdoor blasting of structures or items too large to be reasonably handled indoors, employ control measures such as an enclosure of the area being blasted. Open blasting within an enclosure is acceptable with 100% containment and negative ventilation/filtration. Post a watch stander to monitor blasting operations to ensure operations are ceased immediately upon the loss of grit or fugitive emissions outside the control area.

5. Collect dust, sand, paint, and other debris resulting from abrasive blasting operations. Handle debris from the abrasive blasting operations as waste awaiting designation.

VIII. HEALTH AND SAFETY

a. Voluntary Protection Program

1. PSNS & IMF is a Star site in OSHA's Voluntary Protection Program (VPP). The following OSHA website provides additional information on VPP: http://www.osha.gov/dcsp/vpp/index.html

2. Contractors are required to develop and implement effective safety and health management systems. This includes, but is not limited to, submission of their safety plan in their bid package, specifically including methods to ensure compliance with OSHA regulations during work accomplishment. Example: If the work to be accomplished involves lockout/tagout, confined space entry, fall protection, respirator use, then the contractor will submit their safety plan on those items.

3. PSNS & IMF, is required for injury reporting purposes, to include contractors and their subcontractors, who have worked in the Controlled Industrial Area, a total of 1,000 or more hours in at least 1 calendar quarter. For contracts with task orders, it is based on each task order.

4. Use of OSHA 300 Log is required and is to be submitted to Code 1202 by the end of the project or by 10 January for the previous calendar year, whichever comes first. Negative reporting is required.