Appendix C - CEV-15C Spill Prevention-Response Plan.pdf

SPILL PREVENTION & RESPONSE PLAN

CDRL CEV‐15C

Thule Air Base

FINAL

OPR: GREENLAND CONTRACTORS

Chief of Environmental Engineering DSN 629‐3840 ext. 2698 Supersedes CDRL CEV‐15C 1 July 2009

TABLE OF CONTENTS

1 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

2 INFORMATION AND EMERGENCY CONTACTS

3 GENERAL

3.1 Purpose

3.2 Scope

3.3 Regulatory Overview

3.4 Worst Case Scenarios

4 PREVENTION SECTION

4.1 Facility Incident Commander (FIC)

4.2 General Information

4.3 Potential Spill Locations

4.4 Arrangements for Emergency Services

4.5 Telephone number to emergency services

4.6 Prevention, Control and Countermeasures

4.7 Emergency Equipment

4.8 Evacuation Plans

4.9 Required Procedures

4.10 Site-specific procedures

4.11 Deficiencies in Spill Prevention and Control Measures

5 SPILL CONTROL SECTION

5.1 Responsibilities, duties, procedures and resources

5.2 Immediate response actions

5.3 Facility Response Team

5.3.2 Spill Response Team

5.4 Procedures for FRT alert and response

5.5 Notification of Spills

5.6 Notification of FIC, Installation Commander and local authorities

5.7 Assignment of responsibilities for making notifications

5.8 Surveillance procedures for early detection of spills

5.9 Critical Water and Natural resources

5.10 Additional Emergency Assistance Organizations

5.11 Cleanup procedure

5.12 Reuse and disposal of recovered substances and absorbent materials

5.13 General health, safety and fire prevention precautions

5.14 Public Affairs and releasing information

6 REPORTING SECTION

6.1 Recordkeeping

6.2 Non-Reportable Spills

6.3 Reportable Spills

6.4 Notification of Host Country Authorities

6.5 Spill Response Training and Drills

6.6 Follow-up actions

APPENDIX 1: POTENTIAL SPILL LOCATIONS, HAZMAT STORAGE

APPENDIX 2: POTENTIAL SPILL LOCATIONS, TANKS AND TRANSFORMERS

APPENDIX 3: SPILL ROUTE MAPS

APPENDIX 4: DRAINAGE PATTERNS

APPENDIX 5: EVACUATION PLANS

APPENDIX 6: WATER PROTECTION AREAS

APPENDIX 7: SPILL MIGRATION PATHWAYS

APPENDIX 8: INVENTORY OF SPILL RESPONSE EQUIPMENT

APPENDIX 9: FUEL DISTRIBUTION PIPELINE MAP

APPENDIX 10: INVENTORY OF STORAGE, HANDLING AND TRANSFER SITES

APPENDIX 11: SPILL ROUTE MAP, FLIGHTLINE

APPENDIX 12: CONTINGENCY PLANS

APPENDIX 13: HQ AFSPC/A4/7 GUIDANCE MEMORANDUM, CLEANUP LEVELS

APPENDIX 14 : PROCEDURES

APPENDIX 15: DISTRIBUTION LIST

APPENDIX 16: 2010 REVIEW COMMENTS

1 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

Title: The long title of this plan is “Spill Prevention and Response Plan”. The short title is SPRP, and this title will be used as reference throughout the entire document.

Classification: The document is unclassified.

Responsibilities: Greenland Contractors, Environmental Engineering (GC/CEEE) is the office of primary responsibility for developing and maintaining the plan. The instructions given in this plan are applicable to all organizations and tenant units on Thule AB. Organizations are authorized to extract and reproduce those portions of the plan that are essential in the accomplishment of necessary planning and in the preparation of supporting documents and reports.

References: References referred to in the SPRP do not appear in the plan, but they may be accessed through GC Environmental Engineering or the Air Force Electronic Publication Library (AFEPL).

Reviews/changes: The SPRP is reviewed and updated annually IAW the CDRL and distributed accordingly.

A draft is submitted to the requiring office, 21CES/CEANN, by 1 Nov for review. Review comments, if any, will be provided by 21CES/CEANN within 60 days. Review comments received will be incorporated in the final version of the plan within 30 days; thereafter the document will be submitted to 821ABG/CC for signature. The signed plan will then be submitted as the Final edition.

Further, the plan is subject to change if any of the applicable laws, regulations, or requirements is altered.

Distribution: The plan will be distributed to the organizations shown on the distribution list in Error! Reference source not found.15.

CDRL CEV-15C Spill Prevention and Response Plan July 2010

2 INFORMATION AND EMERGENCY CONTACTS

As Thule AB is a remote site, no immediate support from outside installation agencies may be expected in case of emergencies. If an emergency occurs and Thule AB is not capable of responding, 21st Space Wing must be contacted.

Emergency Phone Numbers

List of persons to be contacted in case of an emergency situation and their phone numbers:

Department Extension

Main Base Fire Department or Ambulance 911

BMEWS Site I Fire Department or Ambulance 911

DET-1 Fire Department or Ambulance 911

821 SFS Security Forces 911

Storm Operations Center 2763/2764

Civil Engineering Service Call 2111

GC Environmental Responder on Call (Service Call) 2111

GC Chief of Environmental Engineering 2698

GC Safety Engineer 3250

M-plant Control Room (Spill Response Team) 3215

821 SPTS/SG Medical Liaison Officer 2696

821 ABG Safety Officer 2709

821 SPTS/CE Civil Engineering 3274

Danish Liaison Officer 2276/2206

Danish Police Inspector 2406/2280

21 CES/CEANN DSN 834-7727

3 GENERAL

3.1 Purpose

The purpose of the plan is to assure that documented guidance regarding spill prevention and response is available to all installation personnel. The plan will describe the procedures, methods, and equipment being used to prevent spills at Thule AB, as well as procedures to be followed in case of releases, accidents, and spills. The goal is to achieve a full state of awareness throughout the installation and in this way enable personnel to:

- Be familiar with spill prevention and response procedures including related regulatory requirements.

- Develop related planning documents (e.g. action plans) that will bring the installation into full compliance with regulatory requirements.

- Quickly and appropriately respond to spills in a manner that will greatly reduce or eliminate contamination, which is the overall purpose.

- Maintain a safe working environment at the installation.

3.2 Scope

The provisions of the SPRP apply throughout the whole installation and to all personnel.

Certain responsibilities are specifically assigned to selected individuals identified in the plan.

The SPRP limits its contents to spill prevention and response issues. Related plans have been developed to cover other functions and may need to be consulted. TABI 10-105 controls the Thule Response Group. This TABI is the overall response instruction for major spills and natural disasters.

3.3 Regulatory Overview

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

US State Laws: Not applicable

USAF: AFI 10-2501, Air Force Emergency Management (EM) Program Planning and Operations

Final Governing Standards for Environmental Protection by United States

Forces in Greenland

Thule AB: EPC Decisions

Host Country: The Greenland Government (GG) Authority has the primary role for environmental protection in Greenland.

3.4 Worst Case Scenarios

The worst case discharge for Thule AB is 2.5 million gallons IAW FGS Appendix AP2. Thule

AB does not have the capability to respond to a spill of that magnitude. The procedures below are a reflection on what could be done with the resources available and should not be interpreted as final or even satisfactory responses.

A disaster scenario at Thule AB would be if the tanker that delivers POL to Thule AB during the summer experienced a significant spill. Pumps are available to recover fuel from the ocean surface. The pumps can only be deployed from the pier and have a capacity of 154 gallons per minute. The collected water and fuel would be disposed in an empty BST (which will be available during the tanker operation).

Thule AB is capable of deploying a spill boom. The boom is long enough to reach the

Dundas Mountain and there is a tethering point there to contain spills from tankers or spills entering the North Star River. However, experiences from the annual exercises indicate that the engine power of the available push boat is insufficient to deploy more than 400 meters of boom due to the heavy current. The boom would be deployed in a loop around the tanker.

In case a weather warning calling for high speed winds is issued the fuel transfer will be aborted temporarily. This minimizes the risk of a spill under conditions where the POL will enter open water fast and thus prevent outside assistance to arrive in time to avoid an environmental disaster.

A critical failure of a Bulk Storage Tank could potentially release more than 2 million gallons fuel. The procedure for containing such an event would be to pump the spill from the secondary containment to an empty bulk storage tank. No BST is designated for this purpose and if all BSTs contain product the spill would remain in the secondary containment basin until a BST could be emptied. There are currently no level alarms installed at the Bulk

Storage Tanks at Thule AB. The probability for such a failure is very low.

Tank 34 contains app. 350,000 gallons waste fuel. If a spill occurs at Tank 34, Thule does not have any other means than pumping the spilled fuel into available tank capacities. Tank

34 does not have adequate secondary containment. This risk is unacceptable and the basis for programmed projects to empty and demolish tank 34.

In order to provide Thule AB with a designated contingency BST and fix the containment at tank 34, the project WWCX 10-0111 “Upgrade Secondary Containment at BST34, Fac.

#30034” was programmed in 2009. However, WWCX 10-0111 has since been cancelled.

The fuel transfer lines between Tank Farm North and buildings and tanks pass over the

North Star River. During high river flows or flooding these lines are potentially at risk. Even if the fuel transfer is aborted immediately following the detection of a leak, the volume of fuel in the pipelines is thousands of gallons. The Spill Boom cannot currently be deployed to contain the mouth of the North Star River due to the lack of engine power on the push boat as described above.

A failure of one or both of the bulk storage tanks at BMEWS would endanger the

Wolstenholme Fjord. The tanks are protected by secondary containment IAW the FGS and the risk of such a failure is very low. However, the fuel transfer pipes between the BSTs and the day tanks inside the BMEWS power point do not have secondary containment or shut-off valves. Although unlikely, a vehicle could crash into these pipes with disastrous consequences. A project has been identified to address this deficiency. If such a spill were to happen, Thule does not have the capability to respond, especially in extreme weather.

Emergency measures would be to extend the broken pipe back into the containment area and establish earth or sandbag dikes to limit the release to the fiord. This applies to failures on the fuel pipelines at the main base as well.

4 PREVENTION SECTION

4.1 Facility Incident Commander (FIC)

The FIC at Thule AB is the Fire Chief. The following table list up the FIC and alternates, iaw FGS C18.3.2.1

Name

Title Responsibility

Duties

Telephone

DP / HP

Aage Johansen Fire Chief Facility Incident

Commander

First Responder

Evaluate spill situation

Provide Guidance in spill containment, clean-up actions and restoration activities

3249 / 3149

Henrik Simonsen Asst. Fire Chief, Operations

Alternate FIC

First Responder

Evaluate spill situation

Provide Guidance in spill containment, clean-up actions and restoration activities

Henrik Aage

Hansen

Asst. Fire Chief, Operations

Alternate FIC

First Responder

Evaluate spill situation

Provide Guidance in spill containment, clean-up actions and restoration activities

Karl Frederik

Mortensen

Asst. Fire Chief, Operations

Alternate FIC

First Responder

Evaluate spill situation

Provide Guidance in spill containment, clean-up actions and restoration activities

4.2 General Information

4.2.1 Facility Description

Thule AB is located 695 miles North of the Arctic Circle (76 32' North latitude, 68 50' West longitude), and 947 miles south of the North Pole on the northwest side of the island of

Greenland. It is approximately 550 miles east of the North Magnetic Pole.

The Thule Defense Area is a large land area that includes various base functions outside the

Main Base area (Appendix 6). Thule AB contains three distinct areas; the Main Base, BMEWS, and Det-1. The areas of the base are divided into building areas designated as 100 through 900 areas. The Group Headquarters and other support functions are located in the

400 area of the base. The area identified as the goal for consolidation efforts is within the

100 and 200 areas (See Figure 1) together with flight line facilities in the 600 area. Also, some large facilities in the 500, 700, 800 and 900 areas, primarily with stand-alone heating systems, will remain.

Figure 1: Thule AB Main Base Area

Thule AB is located in the valley of a glacially fed stream called North River. This area is designated by the Danish government as the Thule Defense Area. The Main Base is located on a relatively flat plain near the mouth of the stream. The active landfill at Thule is located southeast of the main base (Figure 2, taken from Final Landfill Assessment and Operations

Management Plan, 821st ABG, December 2005). DET-1 is located 3 miles east of the Main

Base (Figure 3) and BMEWS located 12 miles northeast and 1,250 feet higher on a hill overlooking Wolstenholme Fjord (Figure 4). Lake Crescent is used for potable water production and is located 5 miles east of the main base (Figure 5).

The base mission consists of BMEWS 12th Space Warning Squadron (12 SWS) and 23nd

Space Operations Squadron (DET-1, 23 SOPS) satellite tracking and control operation.

Figure 2: Thule AB Landfill area

Figure 3: Thule AB DET-1 area

Figure 4: Thule AB BMEWS area

Figure 5: Thule AB Lake Crescent area

4.2.2 Water protection Areas

There are 3 main water protection areas. It is the North Star River, North Star Bay, and Lake

Crescent. Maps of these three locations are shown in Appendix 6 Water Protection Areas

4.2.3 Maps of Locations

Figure 1 to Figure 5 above show maps of the locations covered by this plan. The locations are the Thule AB Main Base Area, Thule AB Landfill area, Thule AB DET-1 area, Thule AB

BMEWS area, and the Thule AB Lake Crescent area.

4.2.4 Critical water resources

Lake Crescent is a critical water resource to Thule Air Base functioning as water supply of potable water to Thule Air Base (See map of Lake Crescent, Figure 5).

4.2.5 Land Uses

The locations indentified in section 4.2.3 are all support functions to Thule Air Base. In CDRL

CEV 13 Conservation Management Plan and in CDRL CEE-2 CE General Plan the Land

Uses / Land management at Thule Airbase are described.

4.2.6 Possible Migration pathways

The possible migration pathways are shown in Appendix 7 Spill Migration Pathways. The red arrows indicate the flow direction.

4.2.7 Drainage Patterns

Drainage patterns are shown in Appendix 4

4.3 Potential Spill Locations

A significant spill is defined as an uncontained release to the land or water in excess of any of the following quantities:

For hazardous waste or hazardous substance identified as a result of inclusion in Table AP1.T4 of the Final Governing Standards, any quantity in excess of the reportable quantity listed in the table;

For POL or liquid or semi-liquid hazardous material, hazardous waste or hazardous substance, in excess of 400 liters (110 gallons);

For other solid hazardous material, in excess of 225 Kg (500 pounds); or

For combinations of POL and liquid, semi-liquid and solid hazardous materials, hazardous waste or hazardous substance, in excess of 340 Kg (750 pounds).

If a spill is contained inside an impervious berm, or on a nonporous surface, or inside a building and is not volatilized and is cleaned up, the spill is considered a contained release and is not considered a significant spill.

All HazMat storage locations where there can be a significant spill are listed in Appendix 1.

Bulk Storage sites for JP-8 are 12 Bulk Storage Tanks (BST) at Tank Farm North, Tank 98 at the pier and two BSTs at J-plant (bldg. 4016). Further, there are a large number of smaller organizational tanks at Thule AB. Appendix 2 lists the tanks that can produce a significant spill.

Bulk Storage, Handling and Transfer sites are listed in Appendix 10, with rate and total quantity of spill.

4.4 Arrangements for Emergency Services

Emergency services are provided by Greenland Contractors. Security is provided by 821

Security Forces Squadron. Sections 5.1.3 - 5.1.6 and 5.1.11 describe the role of each emergency response team.

4.5 Telephone number to emergency services

The telephone number to emergency services on a 24 hour basis is 911.

TEL: 911

4.6 Prevention, Control and Countermeasures

The potential sites where a significant spill can occur are listed in Appendix 1, 2 and 10.

The slope of the terrain will cause all spills in the main base area to ultimately flow west, eventually reaching the North Star Bay (possibly via the North Star River).

Further, the Wolsteinholme Fjord could be threatened by a major spill incident at BMEWS.

Most indoor spills will be contained to the building in which the tanks or hazardous material are located. A spill will be contained using compound absorbent material and spill kits. The primary concern will be the safety of personnel and entry into the sewage system. All indoor potential spill locations must have appropriate spill kits available.

Site specific spill route maps for outdoor locations are provided in Appendix 3 and indicate the potential direction of flow.

Appendix 1 lists the areas where large amounts of hazardous materials and/or waste are stored. The table is listed according to building number, functional area, amount and type of material or waste. The hazardous material inventories from the individual shops are provided to GC/OHS and the Fire Department by GC Supply, who keeps a database over the purchase and stock of hazardous materials.

In all cases spills will be collected in trucks to be temporarily disposed of in POL/water tanks designated for POL spills or stored at Bldg 604 for later shipment as hazardous waste. In case the storage capacity of Thule AB is not sufficient, outside emergency assistance will be required and can be obtained from the list of organizations in section 10.3. Contact to these organizations will occur through 821 ABG/CC.

4.7 Emergency Equipment

Appendix 8 contains an inventory of emergency equipment used by the Facility Response

Team. Appendix 1 and 2 list emergency equipment present at potential spill locations.

At Thule Air Base there are the following communication systems, which can be used under a spill incident:

Telephone system

Land Mobile Radio (LMR) system o Channels :

POL net

CE net

Crash net

In the initial phase of an spill incident, the alarm will go via the telephone system using 911.

4.8 Evacuation Plans

Evacuation plans for potential spill sites, where there is a possibility that evacuation would be necessary are provided in Appendix 5. The signal for evacuations at Thule AB is fire alarms.

4.9 Required Procedures

Written procedures to preclude spills, inspections and recordkeeping requirements can be found in Appendix 14

4.10 Site-specific procedures

In Appendix 12 contingency plans for each potential spill location can be found. At locations, these plans are posted with appropriate spill flow route maps or evacuation plans from

Appendix 3 and 5, respectively.

4.11 Deficiencies in Spill Prevention and Control Measures.

Potential Spill Location Deficiencies Tank Farm North, BST 34 Inadequate Secondary Containment Tank Farm North No storage capacity for worst case spill

Inability to deploy boom at North Star River mouth Fuel Distribution System Inability to deploy boom at North Star River mouth Tanker at DeLong Pier Inability to anchor boom at Dundas Mountain

Inability to recover POL from ocean surface BMEWS BSTs Inability to deploy boom in Wolstenholme Fjord

Interim measures are described in section 3.4

5 SPILL CONTROL SECTION

The spill control section may be considered a contingency plan and is also often referred to as the spill response section. The scope of this section is to identify resources for cleaning up spills at installations and activities located in the Thule Defense Area, and to provide assistance to other agencies when requested.

5.1 Responsibilities, duties, procedures and resources

It is the responsibility of the personnel mentioned below to maintain the procedures necessary for implementing this plan. Such procedures shall ensure adequate training of personnel and implementation of environmental protection and pollution abatement procedures in their areas of responsibility. The personnel will designate additional project officers and monitors as required ensuring an effective program. These designated individuals will continuously inspect the work areas under their individual areas of responsibility. The names and telephone numbers of the project officers and monitors will be posted in prominent locations at potential spill sites.

The Facility Response Team (FRT) consists of personnel from the GC Fire Department

(HAZMAT personnel) and designated individuals from GC Operations (the Spill Response

Team).

The personnel involved in the process of containing and cleaning up spills at Thule AB

(including drills) are identified below. Other offices can be involved in follow-up actions.

5.1.1 Installation Commander (821 ABG/CC)

The Installation Commander exercises the overall responsibility for the management of spill prevention and response planning at Thule AB. The 821 ABG/CC is the chairperson of the

Environmental Protection Committee (EPC).

Public affairs including all notifications to the DLO and/or external offices must be accomplished by or coordinated with the Installation Commander prior to execution. The

Installation Commander designates the Facility Incident Commander (FIC).

5.1.2 Danish Liaison Officer (DLO)

The Danish Liaison Officer serves as the official representative of Denmark, and Greenland

Home Rule at Thule AB.

5.1.3 Consolidated Communication Center (GC/LGCM)

The Consolidated Communication Center (CCC) receives emergency calls (911) and activates responders. The CCC is also known as Hilltop.

5.1.4 Security Forces Squadron (821 SFS)

During a spill situation, Security Forces will:

Evacuate personnel from the scene, if needed, based on the decisions of the Incident

Commander or the Fire Chief.

Secure the area as “Off Limits” to unauthorized personnel.

Coordinate the movement of specific personnel to assist at the incident scene.

Direct traffic.

5.1.5 HAZMAT Personnel and Facility Incident Commander (GC Fire Department)

The Fire Department at Thule AB is the first responder to all incidents. Its responsibilities include responding, containing and assessing all incidents to ensure that the scene is a safe and controlled incident site. It is the Fire Chief’s responsibility to designate an entry control point based on the incident situation. The Fire Chief or Assistant Fire Chief on duty is the designated Facility Incident Commander (FIC) by the installation commander.

The FIC is responsible for directing and coordinating all spill response actions within Thule

AB. The FIC will have the authority to utilize the expertise and resources of the Facility

Response Team (FRT), or any other office of expertise in determining and performing response actions.

5.1.6 Spill Response Team (GC/OMUFM)

The Spill Response Team (SRT) consists of designated members mainly from the Fuels

Operation section, but personnel from the Transportation and Vehicle Maintenance shops can also be appointed. Members must have received training in HAZMAT communication training and have a technical background. The task of the SRT is to respond to spills when requested by the Incident Commander or the Fire Chief in order to perform spill containment, recovery, disposal, and restoration activities.

The SRT will be notified by the FIC and requested to initiate cleanup actions when the incident scene is considered under control and safe to enter. The SRT at TAB is limited in equipment and training, and is therefore not able to respond to all types of incidents. The role of the SRT is to provide manpower for low-risk clean-up tasks and they will always work under the direction of the Facility Incident Commander. Specific incidents they would not be able to include chemical spills were response activities require chemical protection suits and/or advanced respiratory protection equipment. Peterson AFB will be contacted for assistance in case of an emergency that Thule AB is not equipped or otherwise able to respond to.

5.1.7 Civil Engineering Flight Commander (821 SPTS/CE)

The Civil Engineering QAE will oversee GC response efforts.

5.1.8 Environmental Engineering (GC/EE)

GC/EE has the responsibility of managing the Thule AB SPRP. In a spill situation, GC/EE is tasked to assist the FIC in evaluating the situation and provide guidance in spill containment, cleanup actions and restoration activities. GC/EE will manage a record of all spills at TAB and prepare all required reports and documentation.

5.1.9 Pavement and Grounds (GC/LGTT)

The GC Pavement and Grounds division will perform excavations and transport contaminated snow and/or soil as requested by Environmental Engineering.

5.1.10 Safety Organization

The Chief of Safety (821 ABG/SE) is notified of major spills and evaluates compromises of safety related to spill incidents. GC/OHS will provide technical expertise on safety hazards at the request of the FIC or Chief of Safety.

5.1.11 GC Health Services (GC/SG)

GC Health Services (the base hospital) can be activated by the FIC to provide medical expertise and perform triage.

5.1.12 General Personnel

Each individual working at Thule AB including all seasonal contractors are tasked to report any spills to the Alarm Center ext. 911 and to take every reasonable precaution to prevent spills.

Appendix 8 provides data on locations and quantities of spill response equipment at Thule

AB. This is to provide a better and more efficient emergency response to minor spills and to keep a total list of equipment available and updated. Shops can use the lists as a reference, if a spill occurs within their shop and additional spill response equipment is needed.

5.2 Immediate response actions

All permanent residents at Thule AB are obligated to react immediately, when a spill incident occurs and/or is first discovered (e.g. by calling 911). Depending on the quantity of the spill, some personnel groups may be able to initiate an immediate response.

Immediate response actions can include

Restrict all sources of ignition

Check causes and stop source of spill if possible without undue risk of personal injury after stop source of spill or establish containment/diversionary devices to contain release.

Evacuate the area

Report the incident to the Consolidated Communication Center ext. 911. For spills of less than 25 gallons of POL product the spill can be reported to GC/EE(ext 2698) if personnel at the scene are able to respond to the incident. Adequate response will be verified by GC/EE, Make the spill scene “Off Limits” to unauthorized personnel

Further actions will follow the procedure described in section 5.11

5.3 Facility Response Team

The personnel involved in spill response actions can be divided in two groups; HAZMAT personnel and the Spill Response Team (SRT).

5.3.1 HAZMAT personnel

The HAZMAT personnel will complete the initial response to any spill situation and get it under control. The FIC directs the HAZMAT personnel.

HAZMAT personnel are trained professional responders from the GC Fire Department.

Documentation for educational background for FIC and fire fighters is available in GC Human

Resources.

The training requirements for the HAZMAT personnel are provided in the AFI 10-2501, Air

Force Emergency Management (EM) Program Planning and Operations. The initial training must be supplemented by annual refresher training through exercises. These exercises are conducted by the Fire Department.

First Responder Awareness

First Responder Operations

First Responder Technician

According to AFI 10-2501, Air Force Emergency Management (EM) Program Planning and

Operations the HAZMAT personnel may not require technician level training.

5.3.2 Spill Response Team

The SRT will be notified by the FIC and requested to initiate cleanup actions when the incident scene is considered under control and safe to enter, using appropriate personal protection if needed.

The Spill Response Team (SRT) consists of designated members mainly from the Fuels

Operation section, but personnel from other shops can also be appointed. The task of the

SRT is to respond to spills when requested by the Incident Commander or the Fire Chief in order to perform spill containment, recovery, disposal, and restoration activities.

In order to provide the SRT with the skills needed to handle a spill situation, the training will include:

Safety training concerning emergency response information, measures to protect the employee from hazards associated with hazard materials, and methods and procedures for avoiding accidents

Training in the use of respiratory equipment

Training in how to act at spill locations

Training in management of the waste

Performing a drill in cooperation with the HAZMAT team and The Spill Response

Team

Training in the use of Spill Response Equipment (Appendix 8) is accomplished with on-the-job training.

The requirements for the SRT training is not specified in the AFI 10-2501, Air Force

Emergency Management (EM) Program Planning and Operations, but will as a minimum include what is mentioned above.

GC Environmental Engineering coordinates this training as a one-day course in cooperation with the supervisor of the Spill Response Team, The Fire Department and GC Occupational

Health and Safety. Training will be based on MSDS information on the general chemicals present at Thule AB and on site-specific conditions.

If respiratory protection is used during cleanup actions, only personnel trained in accordance with SI.02.15.02.007 will be placed on the cleanup team. This training can be obtained through GC/OHS, Occupational Health and Safety.

Training records are maintained at the GC Site Management Support.

5.4 Procedures for FRT alert and response

The Facility Incident Commander or alternate is on duty at all times. The FRT is activated through the Consolidated Communication Center.

When notified about a spill incident by the Consolidated Communication Center (CCC) the

Fire Department responds immediately to contain the incident and initiate the clean-up.

Access to the CCC is available at all times by radio or phone. Maximum response times for different parts of the base are given below:

On-scene response time from pre-positioned airfield locations for pre-announced emergencies does not exceed one minute.

Initial on-scene response time for unannounced airfield emergencies does not exceed three minutes. Full on-scene response time does not exceed four minutes of initial notification.

Initial on-scene response time for structural and rescue emergencies on Thule main base does not exceed five minutes. Full on-scene response time does not exceed seven minutes.

Initial on-scene response time for structural and rescue emergencies at Det 1 does not exceed eight minutes. Full on-scene response time does not exceed 14 minutes.

Initial on-scene response time by the two fire fighters at BMEWS Site 1 for structural and rescue emergencies does not exceed 7 minutes. Full on-scene response time does not exceed 30 minutes. For all buildings at BMEWS with the exception of #4002 the response time during storm conditions may not exceed 10 minutes (longer response time due to the fact that the fire fighters will have to respond to the situation via tunnel on an el-scooter).

Initial on-scene response time for structural and rescue emergencies at North Mountain does not exceed 11 minutes. Full on-scene response time does not exceed 17 minutes.

Initial on-scene response time for structural and rescue emergencies at South Mountain does not exceed 16 minutes. Full on-scene response time does not exceed 22 minutes.

Ambulance service is available 24 hours a day, seven days a week. An ambulance is capable of transporting patients and emergency medical technicians. EMTs are under the direction and oversight of a physician when treating patients.

The FIC may request the activation of the Spill Response Team. The activation of Spill

Response Team members is coordinated by the operator in the M-plant control room. This position is staffed at all times. The individual Spill Response Team members are activated by telephone or radio. The Spill Response Team will also be assigned to respond to seeping fuel incidents during the summer. GC/EE will request assistance as required through the

GC/OMUFM Supervisor.

5.5 Notification of Spills

The Consolidated Communication Center (CCC) is manned at all times. For every spill incident, the FIC and Chief of Environmental Engineering or alternates are notified by phone or personal pagers. For major spills >25 gallons following roster of persons are notified by phone or personal pagers.

Person/organization Name Office symbol Office Email Phone duty

Phone home

CCC Hilltop N/A GC/LGCM N/A 911 N/A Facility Incident Commander

Mr. Aage Johansen GC/AMF ajo@gc.gl 3249 3149

GC Env. Engineering Mr. Frederik Cappeln GC/EE fvc@gc.gl 2698 2698 Civil Engineering Capt Natalie Chounet 821 SPTS/CE natalie.chounet@thule.af.mil 2271 2271 Chief of Safety TSgt Thomas More 821 ABG/SE thomas.moore@thule.af.mil 2709 3432 GC Operations Mr. Svend Pedersen GC/OPS sgp@gc.gl 3808 3808 GC Site Manager Ms. Inge Bülck GC/CC iwb@gc.gl 3616 3404

Notification of reportable and non-reportable spills will also occur through email as described in chapter 6.2 and 6.3. Spill Memos and CDRLs will use current email addresses from the

CDRL distribution list.

5.6 Notification of FIC, Installation Commander and local authorities

When notifying the Fire Department, the following information should be provided:

Name of individual reporting spill

Location of spill

Number of injured personnel and nature of injuries

Substance spilled

Amount spilled (estimated)

Rate substance currently leaking (estimated)

Time spill occurred (estimated)

Extent to which the spill has traveled

Any pertinent information (e.g. other potential hazards)

The Installation Commander is only notified by 821 SPTS/CE for spills larger than 110 gallons.

The Danish Liaison Officer (DLO) serves as the official representative of Denmark, and

Greenlandic Government at Thule Air Base. All notifications to the DLO and/or external offices must be accomplished by or coordinated with the Installation Commander prior to execution. The role of the DLO is discussed further in section 6.4.

5.7 Assignment of responsibilities for making notifications

All permanent residents at Thule AB are obligated to react immediately, when a spill incident occurs and/or is first discovered. Specific obligations depend on the size of the spill and the capacity of the shop to perform an appropriate response on their own.

Small POL Spill (< 1 gal.):

If the spill is small and can be responded to by the shop personnel, actions to respond, control and clean up the spill will be initiated. GC/EE must immediately be notified and will verify that the spill has been cleaned up appropriately. If a spill kit is used in the spill response action, this must be properly disposed of in accordance with the Hazardous Waste

Management Plan or guidance provided by GC/EE.

Medium POL Spill (1 gal. – 25 gal.):

If the shop personnel can respond the spill, the above guidelines shall be used.

If the spill cannot be handled or occurs in areas of concern, the personnel on site will notify the Alarm Center ext.: 911

Large POL Spill (> 25 gal.) or other HAZMAT or Hazardous Waste Spills of any size:

The personnel on site will notify the Alarm Center ext.: 911

When receiving a 911 call, the Consolidated Communication Center is responsible for notifications as described in section 5.5

Further notification procedures are given in section 6.2, 6.3 and 6.4

5.8 Surveillance procedures for early detection of spills

All bulk quantity tanks, fuel pipeline system, and valves are supplied with alarms that notify operators when a leak occurs.

The 2-person principle is used during fuel transfer processes. One operator is located at the facility where the transfer process begins – and one operator is located at the facility where the transfer process ends. Both operators are in radio contact to ensure quick response and a complete stop if a leak occurs.

The Preventive Maintenance Program (PMP) calls for regular inspections and maintenance of all bulk quantity tanks, the fuel pipeline system, and valves. Monthly inspections include check of corrosion, damages and leaks (Appendix 14).

During July and August GC/EE will conduct field inspections to document seeping fuel and fuel sheens on water bodies and provide protection of the waterways in a timely fashion.

HAZMAT storage areas inspected by GC/OHS and GC/EE at least twice annually.

5.9 Critical Water and Natural resources

GC/EE must notify 21 CES/CEAN if a spill occurs in an area of concern. All reporting must be coordinated with 821 SPTS/CE and the Installation Commander. The Thule Defense Area has several areas of concern that must be protected in the event of a spill. A prioritized list is given below:

1 Lake Crescent (drinking water resource)

2 North Star Bay (coastal water)

3 Wolstenholme Fjord (coastal water)

4 North Star River

5 Streams, rivers and lakes

6 Locations that cannot be properly cleaned and reestablished

Among the lakes in the area, Lake Crescent must especially be protected from any pollution, as this lake is used as Thule AB’s supply of potable water.

The North Star Bay and Wolstenholme Fjord are very vulnerable areas in case of POL

(Petroleum, oil and lubricant) spills during the tanker operations, or release of POL elsewhere at Thule AB. A spill may result in potential damage of the arctic environment around the Thule Defense Area.

The many streams and rivers flowing through the Thule Defense Area lead to coastal waters, therefore any spill in these streams and rivers will eventually end up in the coastal waters.

Soil and Vegetation: In high arctic areas, natural degrading of contaminated soils happens very slowly due to the harsh conditions. Therefore inaccessible locations such as mountainsides are areas of concern.

In general the best way to protect critical water and natural resources is to prevent spill from entering the Storm Water Drainage System. Best management practices for various activities are described in the Storm Water Management Plan. Early detection of seeping fuel from historical spills is a priority for GC/EE.

5.10 Additional Emergency Assistance Organizations

A major peacetime accident may occur involving POL and/or hazardous materials. Actions required may range from simple suppression to highly complex and time-consuming operations with international and/or political implications. It is recognized that response to accidents occurring outside the Thule Defense Area may also be required.

Such responses must be coordinated through the Thule AB Danish Liaison Officer using appropriate Greenlandic and Danish official channels (Grønlands Kommando). Further details of actions to be taken during major peacetime accidents, including base evacuation, are outlined in Thule CEMP 10-2. Additional emergency assistance or information may be required during or after a spill incident. For this purpose, the following list contains contact numbers for various offices that may be of assistance. Contact to these offices will occur through 821 ABG/CC.

Name of Organization Assistance Available Telephone Number

U.S. Forces

Scott AFB or MAJCOM Additional Communication Support DSN 576-1110 (opr)

HQ AFSPC Airlift Support

Scott AFB Air Force Rescue

Coordination Center (AFRCC)

Airlift Support DSN 576-4815/16/17/18/19

Commercial: (618) 256-

4815/16/17/18/19

Elmendorf RCC, Elmendorf AFB, AK Emergency contact DSN 517 522-5375

Air Force Civil Engineering Services

Agency (AFCESA)

Technical guidance and assistance DSN 970-1110

USAF Occupational and Environmental

Health Laboratory (OEHL)

Sampling and analytical support for a complex spill

DSN 240-3305

Chemical Transportation Emergency 24-hour hot line warnings and limited US 1(800) 424-9300

Name of Organization Assistance Available Telephone Number

Center (CHEMTREC) guidance to OSC when spill product can be identified by either chemical or trade name

Environmental Technical Information

Systems (ETIS)

State and federal regulations Directories of federal and state contracts

DSN 970-6167

Oil and Hazardous Materials Technical

Assistance Data System (OHMTADS)

Computerized information on various hazardous substances

US 1(800) 424-8802

Canadian Forces

Halifax RCC, Nova Scotia, Canada Emergency contact DSN 447-8200/2100/2102

RCC Comm. DSN 447-2104

Edmonton RCC, Alberta Canada Emergency contact DSN 620-4402/4403

Commercial:(405) 973-6300

Trenton RCC, Ontario Canada Emergency contact DSN 827-3870/3875 (RCC)

DSN 827-3765 (ATOC)

CFS Alert Emergency contact DSN 627-8011 ext. 201 via

Ottawa operator

Danish Forces

GLK (Grønlands Kommando)

Contact through DLO

Emergency Contact DSN 268 3840 ext.2612

Others

Greenland Fire Protection, Nuuk Ro-Clean Spill Boom, similar to Thule AB

Spill Boom

Commercial: 32 10 56

Note: Edmonton RCC has primary responsibility for Canadian SAR in Northern Canada.

They maintain a SAR response team on 24-hour alert.

5.11 Cleanup procedure

The cleanup procedure includes:

Risk assessment

Spill confinement

Stop the source

Spill clean-up

Follow-up actions

When a spill occurs and/or is first discovered, the first step is to assess the risks that may affect human health, the environment and property. Safety is always put first. The spilled material is identified according to material safety data sheets (MSDS) and the quantity of the spill is determined.

The next step is to limit the spill by blocking, diverting, or confining the spill. Contained absorbents including the PIG socks and booms are used to stop the flow of a liquid before it has a chance to contaminate a water source. Non-absorbing dikes are also available to confine and/or direct liquids, minimize the spill area, and protect drains.

After confining the spill, the source of the spill is stopped. This may simply involve turning a container upright, plugging a leak from a drum and transferring the liquid from the damaged drum to a new one, closing a valve, or bypassing a pipeline.

Once the spill is confined and the leak has been stopped, the incident is reassessed and a plan of action for implementing the spill cleanup is developed. Spills are commonly absorbed with granulate. PIG pillows and mat pads are other alternatives for absorbing the remainder of the spill. Unused absorbents are not hazardous. However once the absorbents are saturated with oils, solvents, etc., they are considered hazardous waste and are disposed of properly in accordance with the Hazardous Waste Management Plan.

If a spill occurs in a water resource Thule AB has PIG absorbent pillows that absorbs only organic liquids (such as POL). The Spill Boom and skimmers (appendix 8) will be deployed for larger spills.

Follow-up actions involve the documentation and verification for the remedial actions and preparation of required reports as described in sections 6.2 and 6.3. If required, further action will be governed by DoDI 4715.8 “Environmental Remediation for DoD Activities Overseas”.

5.12 Reuse and disposal of recovered substances and absorbent materials

Waste oil and fuel from spill incidents is accumulated in POL Water tank no. 2 on Tank Farm

North. After passage through an oil/water separator the water fraction will be discharged into the North Star River. Any required analyses will be coordinated with Environmental

Engineering prior to such discharge. The POL fraction will be incinerated at the K-Plant.

Snow with non-volatile contamination will be transferred to 55 gallon drums and treated as

POL water after melting.

Absorbent materials are disposed of as regulated waste when used for spill incidents, and are therefore disposed off via the DRMO in accordance with the Hazardous Waste

Management Plan.

Snow with volatile fuel contamination will be disposed of at the weathering bed located at

Tank Farm North. The weathering bed is constructed with non-permeable concrete. Mixtures of soil, snow and contamination will be disposed of at the soil disposal site.

Contaminated soil is disposed off at a protected area west of hangar 1 (bldg. #1090) and 2

(bldg. #1091). Here the soil is awaiting land farming projects. The disposal site is divided into

4 sections:

Section A is used for soil contaminated with volatiles such as diesel fuel or gas.

Section B is used for soil contaminated with non-volatile oil such as machine oil and sand from oil water separator sand traps.

Section C is used for soil contaminated with lubricants such as hydraulic oil, gear oil etc.

Section D is reserved for contingency storage of a large amount of soil.

The date and type of spill is noted and the pile identified with GPS coordinates in an inventory that is being maintained in GC Environmental Engineering. No disposal will occur without the approval of GC Environmental Engineering.

Mixtures of soil and absorbent material will be disposed at the soil disposal site if soil makes up 25% or more of the recovered material. If there is less than 25% soil it will be turned out via DRMO.

POL collected in a water resource such as North Star Bay or North Star River will be treated as POL water. For quantities of POL water exceeding the Oil Water Separator capacity for

Thule (estimated 10,000 gallons per year) the POL water will be held in available tank capacity until additional oil water separators can be employed or transport off-site be arranged.

5.13 General health, safety and fire prevention precautions

The FIC will normally assume point of contact and act as Incident Commander until the area is safe and will:

Relay grid coordinates for the incident site to the Consolidated Communications

Center (CCC)

Establish appropriate cordons

Establish Entry Control Points (ECP)

In case of fire, call additional firefighting equipment and position personnel and equipment UPWIND if possible

In case of fire, a report will be submitted IAW AFI 32-2001.

If and when more firefighting equipment is needed, the FIC/AFCO will determine so upon arrival at the spill area.

Oil and water absorbent compound will be used to absorb the fuel and then be removed to a safe place. If foam is used, it must be cleaned up as soon as the hazardous condition is neutralized.

If there is no fire, and the spill is neutralized e.g. by covering with foam, Fire Protection's role is limited to standby actions. Fire fighting vehicles will not be used to remove or wash oil and hydraulic fluid spills. The operation will be given to the agency responsible for recovering and decontamination of the spill. Agency and time will be annotated in the CCC activity log

(ALOG).

5.14 Public Affairs and releasing information

Public affairs including release of any information to the press in invent of a spill must be accomplished by or coordinated with the Installation Commander prior to execution.

6 REPORTING SECTION

6.1 Recordkeeping

When emergency procedures are invoked either directly to GC/EE or via the Alarm Center

IAW section 5.7 it is the responsibility of GC/EE to file reports.

Files of all spills must be documented in the GC/EE office. When notified of a non-reportable spill the GC/EE office will issue a “Spill Memo”. The Chief of Environmental Engineering or alternate will approve the report. All reportable spills will be documented through CDRL and

EIIB reports by GC/EE.

In July and August residual contamination from historical fuel spills can typically be observed at Thule AB. The contamination appears in the form of fuel seepage or fuel sheens. GC/EE is responsible for monitoring this pollution and coordinate protection of the water resources.

Individual observations will not generate a Spill memo. Instead, an annual report on fuel seepage/fuel sheen observations and response action to protect water resources will be prepared by GC/EE by October 1. The report will be available upon request.

Furthermore, recordings of all 911 calls are being filed in the ALOG (Activity Log) in the

Consolidated Communication Center. The ALOG is stored electronically on GC LAN.

6.2 Non-Reportable Spills

For POL spills of less than one gallon no further reporting will occur.

For POL spills of more than one gallon and all non-POL hazmat spills a memo will be submitted to 821 SPTS/CE and 21 CES/CEAN by email. Furthermore, all incidents involving fuel products in excess of one gallon will also be submitted to 821 SPTS/LG (the Fuels

QAE).

The report must be submitted as soon as the remedial actions have been verified by GC/EE and no more than 72 hours after notification has been received by GC/EE. If the remedial actions have not been completed or cannot be verified within 72 hours, the report must include an estimated completion date.

The Spill Memo must contain the following items

Name of installation

Date and time of incident

Actual damage or potential threats to human life, property, and plant or animal life

Location of incident and the nature of the terrain

Cause of incident

Type and estimated amount of pollutant

Remedial action to remove pollution

Assistance required

Estimated or actual completion date of remedial actions

Anticipated or actual reaction by the news media and public to the incident

POC

Corrective actions must be documented as described in section 6.6. Completion of remedial actions must be verified by GC/EE.

6.3 Reportable Spills

A spill is considered a reportable environmental incident if one of the following conditions are fulfilled:

The spill exceeds the reportable quantity (110 gallons for POL products). The reportable quantity for other chemicals is indicated in the Final Governing Standards (FGS), Appendix 1, Table AP1.T4

A spill occurs inside Thule AB and cannot be contained within any required berm or…