Appendix E - CEV-15J Slug Mgmt Plan.pdf

Supersedes 01 July 2009 edition 01 July 2010

CDRL CEV–15J

SLUG MANAGEMENT PLAN

Thule Air Base, Greenland

FINAL

OPR: GREENLAND CONTRACTORS

Chief of Environmental Engineering DSN 629-3840 ext. 2698 Contract No. FA2523-05-C-9001

CDRL CEV-15J Slug Management Plan

Thule Air Base, Greenland 3/21 01 July 2010

TABLE OF CONTENTS

1 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

2 REGULATORY BACKGROUND

2.1 Purpose

2.2 Scope

2.3 Regulatory Overview

3 ORGANIZATIONS AND RESPONSIBILITIES

3.1 Installation Commander, 821 ABG/CC

3.2 Danish Liaison Officer, DLO

3.3 Occupational Health & Safety, GC/OHS

3.4 Civil Engineering, GC/CE

3.5 Environmental Engineering, GC/EE

3.6 Utilities and Facilities Maintenance, GC/OMUFM

3.7 Fire Protection, GC/AMF

4 POTENTIAL SPILLS AND BATCH DISCHARGES

4.1 Introduction

4.2 Facility Layout of the Sanitary Wastewater System (SWWS)

4.3 Discharge Practices

4.3.1 Discharges of sanitary wastewater collected by truck

4.3.2 Water from boilers and heating system

4.3.3 Water from washing of aircrafts/vehicles

4.3.4 Water from the laundry shop

4.3.5 Water from parts washers

4.3.6 Discharge of water from swimming pool

4.3.7 Intrusion of Storm Water

4.4 Storage of Chemicals, Toxic Organic Pollutants and Solvents

4.5 Floor Drains

4.5.1 Bldg. 118 – Hospital

4.5.2 Bldg. 107 – Dundas Buffet Restaurant

4.5.3 Bldg. 4016 – Power Plant, J-site

4.5.4 Bldg. 236 – TOW Club

4.6 Conclusion

5 SLUG MANAGEMENT AND OPERATIONS

5.1 Discharge Practice and Non-routine Batch Discharges

5.1.1 Discharge practice for trucked and hauled waste

5.1.2 Discharge practice for trucked sanitary wastewater

5.1.3 Intentional non-routine batch discharge

5.2 Handling of Chemicals and Control of Toxic Organic Pollutants and Solvents 12

Thule Air Base, Greenland 4/21 01 July 2010

5.2.1 Rooms with floor drain directly to the SWWS

5.2.2 Rooms with floor drain indirectly to the SWWS

5.3 Buildings, Containment Structures and Equipment

5.3.1 Planning of new building, containment structures and equipment

5.3.2 Inspection and Maintenance of the SWWS

5.3.3 Oil/water Separators

5.3.4 Sand/Grease Traps

5.3.5 Cross Connections

5.4 Prevention of Accidental Spill

5.5 Emergency Response

5.6 Notification

5.7 Employee Training

5.8 Sludge Disposal

6 EFFLUENT MONITORING

7 WATER POLLUTION COMPLAINTS

APPENDIX 1: DEFINITIONS

APPENDIX 2: SEWAGE SYSTEM

APPENDIX 3: DISTRIBUTION LIST

APPENDIX 4: 2010 REVIEW COMMENTS

Thule Air Base, Greenland 5/21 01 July 2010

1 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

Title

: The title of this document is “Slug Management Plan” CDRL CEV-15J. The acronym SMP is used throughout the document.

Classification

: The document is unclassified.

Responsibilities

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

Reviews/changes

: The SMP will be reviewed and updated annually IAW the CDRL and distributed accordingly. A draft is submitted to 21 CES/CEAN by 1 Nov for review. Review comments, if any, will be provided 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 821 ABG/CC for signature. The signed plan will then be submitted as the final edition.

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

Distribution

: The plan is distributed to the organizations listed in the distribution list, APPENDIX 3.

Thule Air Base, Greenland 6/21 01 July 2010

2 REGULATORY BACKGROUND

2.1 Purpose

The purpose of this plan is to provide detailed instructions for spills and batch discharges (slugs) prevention and control for all installation personnel at Thule AB.

As the wastewater system is not constantly used for drainage of storm water, the limitations of this plan are circumstances that potentially can have influence on the wastewater system.

Circumstances related to surface water can be found in the Storm Water Management Plan, CDRL CEV-15G.

Likewise, as no wastewater treatment plant has been installed there are no possibilities to control the quality of the discharged wastewater. A control system is being implemented but not as a part of this plan.

2.2 Scope

The provisions of the SMP apply throughout Thule AB and to all personnel. Certain responsibilities are assigned to selected individuals identified in the plan.

Related plans that are developed to cover other functions and may need to be consulted:

• Spill Prevention and Response Plan, CDRL CEV–15C

• Storm Water Management Plan, CDRL CEV–15G

• Hazardous Waste Management Plan, CDRL CEV-15B

• Hazardous Material Management Plan

2.3 Regulatory Overview

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

In accordance with the Final Governing Standards for the Environmental Protection by United States Forces in Greenland (FGS-GL) 24 July 2003 C4.3.2.1.6: “Activities or installations that have a significant potential for spills or batch discharges will develop a slug prevention plan”.

The Clean Water Act (CWA) requires industrial facilities to reduce, minimize, or eliminate sources of pollution exposed to storm water runoff. The goals of the CWA are to make the rivers, lakes and streams fishable, swimmable and drinkable.

Thule Air Base, Greenland 7/21 01 July 2010

3 ORGANIZATIONS AND RESPONSIBILITIES

In order to ensure that spills and batch discharges (slugs) are handled in an environmentally correct manner, it is important that personnel are fully aware of their responsibilities in the SMP.

The following outlines responsibilities:

3.1 Installation Commander, 821 ABG/CC

The Installation Commander has the overall responsibility for the management of the SMP at Thule AB. The responsibility is implemented through the base Environmental Protection Committee (EPC), of which the Installation Commander is the chairperson. The EPC is responsible for reviewing the SMP prior to finalization of the yearly review and/or any other updates of the plan and prior to approval by the Installation Commander.

The Installation Commander, or designated representative, serves as the On-Scene Commander in all incidents that may require emergency response action.

3.2 Danish Liaison Officer, DLO

The Danish Liaison Officer serves as the official representative of Denmark and the Greenland Home Rule concerning environmental issues at Thule AB.

3.3 Occupational Health & Safety, GC/OHS

The Occupational Health & Safety office performs health and safety inspections.

3.4 Civil Engineering, GC/CE

The Civil Engineering office is responsible for the establishment of procedures to ensure that GC Environmental Engineering reviews all projects. This includes the responsibility to secure that all relevant environmental information is available for the review.

3.5 Environmental Engineering, GC/EE

Environmental Engineering is responsible for developing, updating, and implementing the SMP.

3.6 Utilities and Facilities Maintenance, GC/OMUFM

The responsibility of GC/OMUFM stated as the domestic wastewater treatment system (DWTS) in the FGS:

• Batch discharges of trucked wastewater.

• Inspection and maintenance of the wastewater pipe system.

3.7 Fire Protection, GC/AMF

The Fire Chief serves as the initial On-Scene Commander for emergency response actions.

Thule Air Base, Greenland 8/21 01 July 2010

4 POTENTIAL SPILLS AND BATCH DISCHARGES

4.1 Introduction

A plan for spills and batch discharges is required by C4.3.2.1.6 of the FGS. Activities or installations that have a significant potential for spills or batch discharges (into the wastewater system) will develop a slug prevention plan. Each plan must contain the following minimum requirements:

• Description of discharge practices, including non-routine batch discharges.

• Description of stored chemicals.

• Plan for immediately notifying the domestic wastewater treatment system (DWTS) of slug discharges and discharges that violate prohibitions under this section, including procedures for subsequent written notification within five days.

• Necessary practices to prevent accidental spills. This would include proper inspection and maintenance of storage areas, handling and transfer of materials, loading and unloading operations, control of plant site runoff, and worker training.

• Proper procedures for building containment structures or equipment.

• Necessary measures to control toxic organic pollutants and solvents.

• Proper procedures and equipment for emergency response, and any subsequent plans necessary to limit damage suffered by the treatment plant or the environment.

4.2 Facility Layout of the Sanitary Wastewater System (SWWS)

Thule AB is situated in an area with an extremely low population density approx. 25 miles from the nearest village. The climate is high arctic desert. Due to very low temperatures, the sanitary wastewater system (SWWS) has unconventionally been made of insulated black steel pipes situated above ground with heat tracing.

On base, the sewage runs gravitationally through the system to Bldg. 984, where it is discharged through an underwater pipeline into the North Star Bay.

At BMEWS, wastewater is led to a septic tank, from where it is dispersed over a mountainside.

Beside the fixed SWWS, wastewater from Det-1 and Bldg. 107, 561, 563, 580, 605, 651, 754, 760, 1201, 1408, and 1411 is collected in a tank. A special truck collects the contents. The contents are discharged into the SWWS at Bldg. 984.

The majority of water led to the SWWS originates from household sources like showers, washrooms, washing clothes and kitchens. The only direct drainages from floors outside the dormitories are in Bldg. 107, 118, 236 and 4016. In all other situations, the water is by pump or manually poured into the SWWS.

No storm water leads to the SWWS.

Consult Appendix 2 for a diagram of the SWWS on the main base.

Thule Air Base, Greenland 9/21 01 July 2010

4.3 Discharge Practices

The main discharges made to the SWWS are what can be expected for at place where 700 people are living and with some craftsman-like activities but without any industrial activities.

4.3.1 Discharges of sanitary wastewater collected by truck

Some of the wastewater is transported by truck, as mentioned in section 4.2.

4.3.2 Water from boilers and heating system

On main base, the primary source of heating originates from a system of high-pressure steam that is produced in three different places: Bldg. 1391, 241, and 341. Due to high levels of impurities in the boiler water, it is necessary to replace the water and discharge to the SWWS.

To prevent corrosion, a number of additives are used and subsequently discharged into the

SWWS.

Further heating is produced on low-pressure systems at Bldg. 1401, 1824 and 4016. From those places, only small amounts of boiler water are expected to be discharged to the SWWS – primarily in case of maintenance of the systems.

4.3.3 Water from washing of aircrafts/vehicles

Aircrafts are not washed at Thule AB, except for the small helicopter operated by Air Greenland.

The helicopter is washed in HG-4 (Bldg. 606), where the water is led through an oil/water separator to the sewage system.

Vehicles are washed at the following facilities: Bldg. 580, Bldg. 836, Bldg. 622, and Bldg. 1408 plus an outdoor wash ramp near the harbor (no facility number assigned). In all facilities, the waste is led through to an oil/water separator. From there the water is discharged through the sewage system for all facilities except for the outdoor wash ramp near the harbor, where the water is discharged directly to the North Star Bay and at Bldg. 836, where the water is led through an oil/water separator to the storm water drainage system.

One oil/water separator is located at the Crash Fire Rescue Training Facility at Perimeter Road.

The oil/water separator is only operated when the Fire Department performs aircraft crash exercises. Used fire water is led through the oil/water separator to the storm water drainage system.

Another oil/water separator is included in the mobile Brita filter system.

An outdoor oil/water separator is located in the culvert on the corner of Crescent Road, Bldg.

610 and Bldg. 614, directly into the storm water drainage system. This culvert was renovated during the early summer of 2008 as the culvert must be capable of handling large amounts of thaw water during spring. The oil/water separator was included here as part of the storm water system as the upstream area is used during the winter to pile snow from the runway.

Thule Air Base, Greenland 10/21 01 July 2010

4.3.4 Water from the laundry shop

In the laundry shop, Bldg. 237, clothes are rinsed or washed. The rinsing process is designated as a dry-cleaning process, where methylene chloride is used. Residuals from the rinsing process are required to be treated as hazardous waste and collected for disposal to ensure nothing is introduced to the SWWS.

Conventional detergents are used for the washing process. Water from the washing process is led to the SWWS directly from the machines. In case of spillage, the water will be recovered in a drain, from which the water will be pumped to the SWWS.

4.3.5 Water from parts washers

At Thule AB, there are 2 parts washers. They are located in Bldg. 580 and 4016.

The water from Bldg. 580 is led to an oil/water separator and to the SWWS. The water from Bldg. 4016 is led directly to the sewage system and any remaining slug is transferred to storage drums.

4.3.6 Discharge of water from swimming pool

During the summer 2006, an endless pool was installed at the Sport and Fitness Center in Bldg.

608. The endless pool is emptied out and cleaned every second month. The volume of water introduced to the SWWS is estimated to be 12 m3. The concentration of calciumhypochlorite is

1.5 ppm. There are no emergency response related to slug management.

Beside the normal use of chlorine, the water is sanitized using a treatment filter that releases small quantities of copper and silver.

4.3.7 Intrusion of Storm Water

Although the SWWS is segregated from the storm water drainage system, the division might be compromised. The pipes of the SWWS are situated in the ditches and culverts that form the storm water drainage system. As the segregation between the SWWS and the storm water drainage system is the guarantee against unintended pollutants that have been washed off by the surface water, it is important to keep the SWWS without leaks.

4.4 Storage of Chemicals, Toxic Organic Pollutants and Solvents Handling and storage of hazardous materials are at Thule AB managed by the Hazardous Material Management Plan. Major storages are kept in Bldg. 555, 580, 605, 629, 801, 1391, and 4002.

Handling and storage of hazardous waste at Thule AB is managed by the Hazardous Waste Management Plan (CDRL CEV-15B). Major storages are kept in Bldg. 552, 563, 604, and 935.

The potential of accidental spillage of chemicals that might contaminate the SWWS is where sumps and floor drains are leading directly to the SWWS. In all other cases, the chemicals have to be manually poured or pumped into the drains.

4.5 Floor Drains

As mentioned in section 4.2, the only direct drainages into the SWWS from floors outside the dormitories are in Bldg. 107, 118, 236, and 4016. Special interest has to be made to these locations, as they are the only places where accidental releases of chemicals can occur.

Thule Air Base, Greenland 11/21 01 July 2010

4.5.1 Bldg. 118 – Hospital

There are only floor drains from showers – for both staff and patients.

All decontamination incidents are handled by the Fire Department in an outdoor mobile emergency system. The system collects all decontamination water for hazardous waste characterization.

As a part of the Environmental Awareness Program at Thule AB (newcomer briefings), all personnel are informed to return expired medical supplies to the hospital or DRMO.

All X-rays are performed with digital computer technology leaving no hazardous waste like mercury, silver, formaldehyde etc.

4.5.2 Bldg. 107 – Dundas Buffet Restaurant

In the kitchen in Bldg 107 several floor drains are installed. From the floor drains, water is led to a grease trap, where grease and other low-density liquids with low solubility in water can be withheld. The water is subsequently discharged to the SWWS.

4.5.3 Bldg. 4016 – Power Plant, J-site

At the auxiliary power plant at J-site, a sump is located in a room containing a parts washer. The sump is drained directly to the SWWS – without an oil/water separator. Furthermore, there is a storage of petroleum, oil and lubricants (POL), and hazardous materials. The waste is stored in four 55-gallon steel and plastic drums situated horizontally and with secondary containment to collect spillage of chemicals.

4.5.4 Bldg. 236 – TOW Club

Water discharged to the SWWS through the floor drains in the kitchen is also led through a grease interceptor.

4.6 Conclusion

The SWWS at Thule AB is very unusual as it is situated above the ground. At the same time, it is totally segregated from the storm water drainage system. Hereby it is eliminated that outdoor spills of chemicals, POL and other contaminants might run off into the SWWS – except for the possibility that it might enter through a leakage during the short period, where the storm drains are flooded and thereby partly submerging the SWWS.

Thule Air Base, Greenland 12/21 01 July 2010

5 SLUG MANAGEMENT AND OPERATIONS

Based on the analyses in section 4, the following management and operation plan is established.

5.1 Discharge Practice and Non-routine Batch Discharges

The main risk of damaging the SWWS or the recipient comes from the different routine discharges and non-routine batch discharges.

5.1.1 Discharge practice for trucked and hauled waste

According to the FGS, C4.3.2.1.7: “The discharge of trucked and hauled waste into the DWTS, except at locations specified by the DWTS operator is prohibited”.

As there is no wastewater treatment plant on Thule AB, the only function responsible for the SWWS is GC Utilities and Facilities Maintenance. As such, GC Utilities and Facilities Maintenance has the right to specify discharge of trucked and hauled waste. To prevent damage on the environment beside wastewater all discharges of trucked and hauled waste have to be done after consultation with GC Environmental Engineering.

The FGS, Chapter 4.3.3 includes the general requirements for the discharged batch. GC Utilities and Facilities Maintenance must retain records of the discharge for three years.

5.1.2 Discharge practice for trucked sanitary wastewater

As mentioned in paragraph 4.2, an amount of the collected wastewater is not transported by the SWWS but by truck to Bldg. 984, where it is discharged into the SWWS by the grit system. The same procedure is used for materials collected from septic tanks.

There is no limitation on the amount of trucked wastewater and no record has to be made, as long as the discharge is measured as a part of the ongoing registration of wastewater.

5.1.3 Intentional non-routine batch discharge

Intentional non-routine batch discharges, e.g. when water from a boiler is discharged due to maintenance, are recorded IAW GC Utilities and Facilities Maintenance instructions.

5.2 Handling of Chemicals and Control of Toxic Organic Pollutants and Solvents Hazardous Material Management Plan and Hazardous Waste Management Plan (CDRL CEV- 15B) govern handling of hazardous substances.

5.2.1 Rooms with floor drain directly to the SWWS

In areas with a floor drain and storage of hazardous substances or POL, the rules outlined in the Spill Prevention and Response Plan have to be observed. Temporary drain covers are used when chemicals may spill. The covers can be removed for floor cleaning and other activities requiring use of the drain.

5.2.2 Rooms with floor drain indirectly to the SWWS

In some areas, water from floor drains is pumped to the SWWS. In case a spill occur during pump operation, the pump must be stopped immediately and spill response initiated.

Thule Air Base, Greenland 13/21 01 July 2010

5.3 Buildings, Containment Structures and Equipment

5.3.1 Planning of new building, containment structures and equipment When designing a new building, containment structures and equipment, it is essential to ensure no spill is led through the SWWS.

The measures are:

• To build structures that contains large storages of pollutants in a way with no direct access to the SWWS.

• To keep showers, toilets and other drains in parts of the building, where no pollutants are stored.

• To secure drains from areas where pollutants are stored by installing a pump that discharges the wastewater to the SWWS, that can be stopped in case of an accident or preferable only is operated when conditions has been checked.

• To keep pollutants in areas with floor drains in secondary containments.

To secure that a proper measure has been chosen, all projects have to be reviewed by GC Environmental Engineering.

5.3.2 Inspection and Maintenance of the SWWS

Inspection and maintenance of the SWWS is the responsibility of GC Utilities and Facilities Maintenance and part of the maintenance program at Thule AB.

The maintenance of the SWWS is important as the segregation between the SWWS and the storm water drainage system is a major part of the safety measures against pollution of the SWWS with spilled materials.

5.3.3 Oil/water Separators

The discharge of petroleum oil, non-biodegradable cutting oil, and products of mineral oil origin is prohibited. In places where oil is removed from objects with water and soap, e.g. where cars are washed, an oil/water separator system has been installed to withhold the oil and non-emulsifying soap (Masava) is applied for the washing process.

The Facility Manager requests maintenance if required outside normal routine. GC Utilities and Facilities Maintenance is responsible for the maintenance of the oil/water separators.

Maintenance of oil water separators involves draining them and cleaning them. The drained liquid is collected by a mud pump and left for evaporation on a weathering bed. The weathering bed is located near the land farm area in the western part of the main base area. The bed consists of an earth dike with a liner to protect the surroundings from leaking.

If solid and semi-solid sludge is present in the oil water separator it will be disposed of via the

DRMO.

5.3.4 Sand/Grease Traps

The discharge of solid or viscous pollutants that might obstruct the SWWS is prohibited.

The Facility Manager requests maintenance if required outside normal routine. GC Utilities and Facilities Maintenance is responsible for the maintenance of the sand/grease separators.

Thule Air Base, Greenland 14/21 01 July 2010

5.3.5 Cross Connections

Cross connections between the SWWS and the drinking water system is a problem related to drinking water. The Backflow Prevention Program includes control and removal of cross connections in accordance with AFI 32-1066, and is not a part of this plan.

5.4 Prevention of Accidental Spill

As many times previously mentioned the backbone of spill prevention in relations to the SWWS is the segregation. A description of correct handling of hazardous materials is stated under 6.2, but there are other types of unwanted materials as listed in FGS Chapter 4.3.1, 4.3.2 and 4.3.3.

From the perspective of the SWWS, they have to be treated like hazardous substances.

More information on prevention of accidental spill is included in the Hazardous Waste Management Plan (CDRL CEV-15B) and the Spill Prevention and Response Plan (CDRL CEV- 15C).

5.5 Emergency Response

Emergency Response procedures are included in the Spill Prevention and Response Plan

(CDRL CEV-15C).

Non-routine discharge of wastewater is approved by GC Environmental Engineering.

5.6 Notification

In case of an unintended discharge, notification will be given to the Consolidated Communications Center (alarm center) who will notify key personnel IAW rosters.

Environmental incidents are reported and investigated IAW 21 SW Instruction 32-302 paragraphs 3.7.2, 4.1.2, 4.1.3, 4.1.4, 4.1.5, 4.1.7, 4.2.2, 4.2.3, 4.2.4, 4.2.5, 4.3.2, 4.3.3, 4.3.4, Attachment 1, 2 (dated 1 Oct 2008), and HQAFSPC/A7AQ letter dated 7 Nov 2007. Initial reports are made to 821 ABG/CC and 21 CES/CEAN within 24 hours.

For Category 3, the Environmental Incident Investigation Board (EIIB) report and NOTAM are completed IAW 21 SW Instruction 32-302 Attachment 1 and 2, within 7 days after the investigation is completed. The investigation documents are signed and forwarded to 821 ABG/CC and 21 CES/CEAN within 7 days of its completion. Reports must be received within 17 days of the investigation commencement.

For Category 4, an internal investigation consisting of a one page summary report or NOTAM is performed IAW 21 SW Instruction 32-302 Attachment 2. The investigation documents are forwarded to 821 ABG/CC and 21 CES/CEAN within 10 days.

As requested by 821 ABG/CC a waiver from performing an EIIB is submitted within 7 days of the incident, or an EIIB category lesser than the parameters is requested within 24 hours of the incident. Any waiver request is submitted to 821 ABG/CC and 21 CES/CEAN.

HQAFSPC/A7AQ letter dated 7 Nov 2007 waives the requirement to report sewage spills smaller than 110 gallons.

Thule Air Base, Greenland 15/21 01 July 2010

5.7 Employee Training

GC personnel and contractors who handle hazardous substances or perform activities that could contribute to spill or batch discharges should be trained in appropriate Best Management Practices by the individual shop. Such training should emphasize pollution prevention, awareness of possible pollution sources and local measures to contain spillage in a way that makes it possible to contain the spillage, e.g. how to stop pumps that discharges water from floors into the SWWS.

GC Environmental Engineering training programs include:

• Hazardous Waste Handling, in accordance with “Hazardous Waste Management Plan

(CDRL CEV-15B)”

• Chemical Hazard Communication, in accordance with “Hazardous Material Plan”

• Spill Response Training, in accordance with “Spill Prevention & Response Plan (CDRL

CEV-15C)”

Scheduled training dates are communicated through GC’s Personnel Department, and sign up is available for everyone through GC’s intranet.

The individual participant will receive a certificate from GC Environmental Engineering. GC Environmental Engineering will keep a record of the training for 3 years.

5.8 Sludge Disposal

A wastewater treatment plant is not been installed at Thule AB, therefore, no wastewater treatment sludge is produced.

Thule Air Base, Greenland 16/21 01 July 2010

6 EFFLUENT MONITORING

The daily volume of direct effluent discharge from Bldg. 984 to North Star Bay is monitored by an open channel flow meter based on standardized Venturi flume principles. The flow meter was installed in January 2009.

IAW FGS, Table C4.T2, sampling of effluent is performed monthly at Bldg. 984 and 4002. A 24-hour time proportional composite sample consisting of 24 aliquots is collected by automatic sampling equipment. Alternately, a grab sample is collected manually.

IAW FGS, Paragraph C4.3.1.3 the monthly collected effluent samples are tested for conventional pollutants as pH, Total Suspended Solids (TSS) and Biochemical Oxygen Demand

(BOD5).

IAW FGS, Paragraph C4.3.1.4 the records on date, time and exact place of sampling and testing, analyst, test results, procedures and daily volume are retained for at least three years.

Thule Air Base, Greenland 17/21 01 July 2010

7 WATER POLLUTION COMPLAINTS

In general, USAF remains current with Greenland environmental activities and regulations IAW Statement of Work, Paragraph 18.11.

All official environmental correspondence sent to organizations outside of the 21 SW is approved by 821 ABG/CC and 21CES/CEAN prior to release. In addition, copies of all official incoming environmental correspondence are forwarded to 821 ABG/CC and 21 CES/CEAN within five days of receipt.

IAW FGS, Paragraph C4.3.1.5 and C4.3.2.2, water pollution complaints from individuals or host nation water pollution control authorities are investigated, involving the Environmental Executive Agent, as appropriate.

All correspondence and investigations are documented and records are retained for ten years.

So far, no complaints are received.

Thule Air Base, Greenland 18/21 01 July 2010

APPENDICES

Thule Air Base, Greenland 19/21 01 July 2010

APPENDIX 1: DEFINITIONS

Thule AB

Thule Air Base

DWTS Domestic Wastewater Treatment System

Any DoD or host nation facility designed to treat wastewater before discharging to waters of the host nation and in which the majority of such wastewater is made of domestic sewage.

SWWS Sanitary Wastewater System; defined as the existing piping system for wastewater on Thule AB

Seasonal Contractors A company awarded a contract by the government for construction or repair projects. Usually projects performed during the summer season at Thule AB.

Tenant Units These are other organizations assigned to Thule Air Base, which occupy some base facilities.

Process Wastewater Any water originated from manufacturing processes – including water coming from military installations

New sources A source built or substantially modified on or after 1 October 1994, that directly or indirectly discharges pollutants to the wastewater system

Substantial Modification Any modification to a facility the cost of which exceeds $1,000,000, regardless of the funding source

Waters of the Host Nation Surface waters including the territorial seas recognized under customary international law

Hazardous substances

A substance that is defined as either hazardous materials or hazardous waste in accordance with Appendix 1 of the FGS

EPC

Environmental Protecting Committee

Facility Manager An individual appointed to a facility/building whose primary responsibility is to ensure the facility is kept in a good state of repair. This includes ice and snow removal in front of doorways, stairways, ramps etc. during the winter.

Thule Air Base, Greenland 20/21 01 July 2010

APPENDIX 2: SEWAGE SYSTEM

Thule Air Base, Greenland 21/21 01 July 2010

APPENDIX 3: DISTRIBUTION LIST

The PDF document is distributed via email IAW CDRL Summary list.

Distributed in PDF format

21 Space Wing

21 CES/CEAN

William.ritchie@peterson.af.mil Todd.degarmo@peterson.af.mil

21 SW/PMD

21sw.pmd.thule@peterson.af.mil

821 Air Base Group 821 ABG/CC Commander

821SPTS.PM@thule.af.mil

821 Support Squadron 821 SPTS/CE Flight Commander

821SPTS.CE@thule.af.mil

Greenland Contractors, Thule Air Base

All GC organizations (on GC LAN) mailto:William.ritchie@peterson.af.mil� mailto:Todd.degarmo@peterson.af.mil� mailto:821SPTS.PM@thule.af.mil� mailto:821SPTS.CE@thule.af.mil�

APPENDIX 4: 2010 REVIEW COMMENTS

Ite m # Office

Symbol Org

Pa ge

Pa ra

Cr iti ca l, Su bs ta nt iv e or A dm in is tr at iv e

Comment Rationale Accept Modify Reject

Rationale

1 CEANN 21 CES 9 4.3.3 C Add: Use Non‐emulsifying soap for vehicle washing. FGS C4.3.2.1.5. Oil and Grease. The discharge of the following oils, which can pass through or cause interference to the DWTS, is prohibited: petroleum oil, non‐ biodegradable cutting oil, and products of mineral oil origin. If you emulsify the oil in soap (gets heavier and sinks), it gets discharged out of the OWS which violates FGS.

M The use of non‐emulsifying soap is outlined and stated in subsection 5.3.3.

2 CEANN 21 CES 10 4.5 C Add: Use temporary drain covers for use when chemicals may spill. The covers can be removed for floor cleaning and other activities requiring use of the drain.

FGS C4.3.2.1.6.4. This will prevent accidents from entering the outside waterways.

M The use of drain covers is outlined and stated in subsection 5.2.1.

3 CEANN 21 CES 11 4.5.1 C If this room is ever used for decontamination, can this water be collected? Thule needs to collect this water. The hospital decontamination water can get anything from hazardous materials to biological agents into it that you don’t want to release back into the environment. Thule needs to sample this water before it is released or collected as hazardous waste.

FGS C4.3.1.2.3 A All decontamination incidents are handled by the Fire Department in an outdoor mobile emergency system. The system collects all decontamination water for hazardous waste characterization.

4 CEANN 21 CES 14 5.6 A Change: EIBB to EIIB. Add: Environment Incident Investigation Board (EIIB) the first time it is used so the reader knows what EIIB means.

Typo and clarification. A Typo corrected and clarification added.

5 CEANN 21 CES 9 4.3.4 C What chemicals of concern are coming from the “rinsing” process that would require their disposal as a hazardous waste? Wouldn’t there be similar chemicals generated in the “washing” process? And if so, why wouldn’t these chemicals also be disposed of as a hazardous waste?

FGS C6 A The rinsing process is designated as a dry‐cleaning process, where methylene chloride is used. Only conventional detergents are used for the washing process.

6 CEANN 21 CES 10 4.3.5 C Recommend: List the contaminants from the parts washers that would be expected to be introduced into the SWWS and their estimated quantities. What is the “remaining slug” that is being referenced here?

A The parts washer waste and slug will be characterized.

7 CEANN 21 CES 10 4.3.5 C Characterize parts washer waste. If HW, collect discharge and dispose as HW.

FGS C6: Discharge from B4016 goes directly to environment when discharged over cliff. This could lead to spill of hazardous waste.

A The parts washer waste and slug will be characterized.

8 CEANN 21 CES 10 4.4 C Third paragraph mentions that in certain facilities there is a potential for a spill to enter a floor drain and sump that leads directly to the SWWS; recommend (removable) floor drain covers be installed and a shallow berm be installed around the sump pits to prevent accidental releases from entering the SWWS.

FGS C6 M The use of drain covers is outlined and stated in subsection 5.2.1.

9 CEANN 21 CES 10 4.5 S Recommend explaining what is meant by “ Special interest has been made to these locations“.

Self explained M "Speciel interest has been made these locations" is clarified in subsections 4.5.1, 4.5.2, 4.5.3 and 4.5.4.

10 CEANN 21 CES N/

A

N/A C Add to plan monitoring to determine if effluents have exceeded those limits.

FGS C4.3.1 discusses effluent limits, but the plan does not specify any monitoring to determine if effluents have exceeded those limits.

A Section 6 is added to the plan.

Effluent samples are tested for conventional pollutants as pH, Total Suspended Solids (TSS) and Biochemical Oxygen Demand (BOD5) to determine if effluents have exceeded limits.

11 CEANN 21 CES N/

A

N/A C Add to plan monitoring frequencies as required by FGS. FGS, Table C4.T2. Monitoring Requirements requires monitoring at specified frequencies based on MGD of effluent, but the plan does not specify any monitoring performed.

A Section 6 is added to the plan.

Effluent samples are tested monthly based on MGD of effluent.

12 CEANN 21 CES N/

A

N/A C Add to plan a system to investigate water pollution complaints as required by FGS.

FGS Sections C4.3.1.5 and C4.3.2.2 specify that a system for investigating water pollution complaints from individuals or host nation water pollution control authorities will be established, involvingthe Environmental Executive Agent, as appropriate.

Then the plan does not specify any system.

A Section 7 is added to the plan.

System is specified to investigate water pollution complaints.

CEANN 21 CES

5 1.1

"…in the distribution list, APPENDIX 4." The distribution list is Appendix 3, per the table of contents. Suggest correcting. Accuracy.

A "Appendix 4" corrected to "Appendix 3".

CEANN 21 CES

7 3.6 Domestic wastewater treatment system is not a proper noun and should not be capitalized. Grammatical correctness.

A Capitals deleted.

CEANN 21 CES

8 4.1

"A plan for Spill and Batch Discharges…" Spill and batch discharges should not be capitalized because they are not proper nouns. Sme with wastewater system. Same for domestic wastewater treatment system. Grammatical correctness.

A Capitals deleted.

CEANN 21 CES

8 4.1 Sanitary wastewater system is not a proper noun and should not be capitalized. Grammatical correctness.

A Capitals deleted.

CEANN 21 CES

8 4.2

Storm water is not a proper noun and should not be capitalized. Grammatical correctness.

A Capitals deleted.

CEANN 21 CES

9 4

"To prevent corrosion, a number of additives are used and subsequent discharged into the SWWS." "Subsequent" should be subsequently (adverb). Recommend changing. Grammatical correctness.

A "Subsequent" corrected to "subsequently".

CEANN 21 CES

9 4.3

Storm water drainage system should not be capitalized.

Building #610 and Building #614 in Para. 5 should be capitalized. Grammatical correctness.

A Capitals deleted. Building corrected to Bldg.

CEANN 21 CES

9 4

If two oil/water separators are "…non‐functional and abandoned," suggest deleting this since it is irrelevant to the plan. Irrelevant and extranneous.

A Sentence deleted.

CEANN 21 CES

9 4 "Crescent road." Road should be capitalized (also in last line of paragraph). Grammatical correctness.

A "Cresent Road" is capitalized.

CEANN 21 CES

9 4 "…or while tanking the plans fuel…" What does that mean? Clarity.

A Paragraph deleted.

CEANN 21 CES

9 4.3.3

Suggest deleting these two paragraphs and replacing with one that states a non‐emulsifying soap is used for all vehicle washing.

Update to include non‐emulsifying soap is now being used.

M The use of non‐emulsifying soap is outlined and stated in subsection 5.3.3.

CEANN 21 CES

9 4.3.4

"…methylene chloride is used. Residuals from the rinsing process are required to be treated as hazardous waste and collected for disposal to ensure nothing is introduced to the SWWS." 1. A discharge "description" should contain not just the nature of the discharge, but the volume and frequency of the discharge to the sanitary sewer system as well. 2. Because methylene chloride is hazardous, there should be a reference to where in the HWMP it is covered to indicate the how it is "ensure(d)" that "nothing is introduced to the SWWS." There are no indicated "practices" to prevent accidental spills or control toxic solvents.

1. FGS C4.3.2.1.6.1 Description of discharge practices, including non‐ routine batch discharges. 2.

C4.3.2.1.6.4. Necessary practices to prevent accidental spills.

C4.3.2.1.6.5. Necessary measures to control toxic organic pollutants and solvents.

A Residuals from the rinsing process is listed as Dry Cleaning Sludge (HW Code: HWAP 20) in the Hazardous Waste Management Plan, Appendix 2.

10 4.3.6

"A small amount of water…" Volume? Frequency of discharge into SWSS? 1. Chorine: What type of chlorine?

Calcium hypochlorite? Flammable, explosive, and toxic.

What procedures are in place for emergency response or spill?

C4.3.2.1.6.4. Necessary practices to prevent accidental spills.

C4.3.2.1.6.5. Necessary measures to control toxic organic pollutants and solvents. C4.3.2.1.6.7. Proper procedures and equipment for emergency response, and any subsequent plans necessary to limit damage suffered by the treatment plant or the environment.

A Paragraph added. "The endless pool is emptied out and cleaned every second month. The volume of water introduced to the SWWS is estimated to be 12 m3. The concentration of calciumhypochlorite is 1.5 ppm".

CEANN 21 CES

10 4.3.7 Storm water drainage system should not be capitalized. Grammatical correctness.

A Capitals deleted.

CEANN 21 CES

4.4 1

"Storage of chemicals, toxic…pollutants and solvents.

Handling and storage…managed by Hazardous Waste Management Plan." Sodium hypochlorite (used at water treatment plant) and ? Calcium hypochlorite (possibly used at pool) are not listed or addressed in the HWMP, CDRL

CEV‐15B.

FGS, Greenland‐4, Wastewater:

C4.3.2.1.6.2. Description of stored chemicals.

R Sodium hypochorite and calciumchlorite are listed in the Hazardous Material Management Plan, not the Hazardous Waste Management Plan.

CEANN 21 CES

4.5 1

"Special interest has to be made…" This does not address the "necessary practices to prevent accident spills." What is being done to insure accidental releases do not occur?

Signs over the sinks with emergency contact information?

Information provided to newcomers to Thule AB?

C4.3.2.1.6.4. Necessary practices to prevent accidental spills.

C4.3.2.1.6.5. Necessary measures to control toxic organic pollutants and solvents.

M "Speciel interest has been made these locations" is clarified in subsections 4.5.1, 4.5.2, 4.5.3 and 4.5.4.

CEANN 21 CES

11 4.5.1 "Despite designated as a decontamination room…." Should be "Despite designation…" OR "Despte being designated…" Grammatical correctness.

A Sentence deleted.

CEANN 21 CES

11 4.5.2 Floor drain should not be hyphenated. Grammatical correctness.

A Hyphenation deleted.

11 4.5.1

Hospital: There are no hazardous materials or waste at the hospital? Although "medical supplies past expiration date" (expired pharmaceuticals) are provided to DRMO, are there are "practices" to insure personnel do not dump them into sinks, toilets, drains, etc? What about X‐ray machines and the mercury and/or silver used to "fix" the radiographs?

The X‐ray film contains silver. Ethanol, formaldehyde?

Solvents or acids? Cerrobend? (x‐ray putty ‐‐ contains lead and cadmium).

C4.3.2.1.6.5. Necessary measures to control toxic organic pollutants and solvents.

A As a part of the Environmental Awareness Program at Thule AB (newcomer briefings), all personnel are informed to return expired medical supplies to the hospital or DRMO.

CEANN 21 CES

11 4.5.3 "…storage of POL and hazard materials…" ? Hazardous materials. Adjective modifying materials. Grammatical correctness.

A "Hazard" corrected to "hazardous".

CEANN 21 CES

11 5 Hazardous materials and hazardous waste are not proper nouns and should not be capitalized. Grammatical correctness.

A Capitals deleted.

CEANN 21 CES

4.6 2

"There is no immediate risk for contamination of the SWWS…" from hazardous materials, hazardous waste… This is not true as proven by the statement "The only possibility…will be discharges through sinks and toilets."

That is an immediate risk. Suggest deleting paragraph in its entirety.

A Paragraph deleted.

CEANN 21 CES

11 5 "…where the storm drains are flooded and hereby partly submerging…" Should be "thereby." Grammatical correctness.

A "Hereby" corrected to "thereby".

CEANN 21 CES

12 5 "Based on the analyses in section 5, the following…" It IS Section 5. Did you mean Section 4? Clarity and accuracy.

A "Section 5" corrected to "section 4".

CEANN 21 CES

12 5 Hazardous waste and hazardous materials are not proper nouns and should not be capitalized. Grammatical correctness.

A "Section 5" corrected to "section 4".

12 5.1.1

1. "Hazardous Materials has to be…" Should be "Hazardous materials have to be…" 2. Plan must contain information on how hazardous waste and hazardous materials are prevented from entering the SWSS. That information cannot be referenced back to the HW management plan. This plan should be a stand‐alone document.

1. Grammatical correctness. Plural subject needs a plural verb (have.

"Has" is a singular verb). 2.

C4.3.2.1.6 through C4.3.2.1.6.7 of the FGS.

M Subsection 5.1.1 is extranneous and therefore deleted.

CEANN 21 CES

12 5.1.2

"To prevent damage…all discharge of trucked and hauled waste have to be done after consultation…." Should be "…all discharges of trucked and hauled wastes have to be done…." Grammatical correctness.

A Singular corrected to plural.

CEANN 21 CES

12 5.1.4

Should be "Intentional" (adjective) not "Intentionally" (adverb). Grammatical correctness.

A "Intentionally" corrected to "intentional".

CEANN 21 CES

12 5.1.4

"Intentionally non‐routine batch discharges…, it is recorded…" Should be "are recorded" and the "it" should be deleted. Grammatical correctness.

A "It" deleted. "Is" corrected to "are".

CEANN 21 CES

12 5.1.5 Storm water drainage system is not capitalized. Grammatical correctness.

M Subsection 5.1.5 is extranneous and therefore deleted.

CEANN 21 CES

5.2 1 This plan should be a "stand alone" document without the need to find and reference another plan.

G4.3.2.1.6. Spills and Batch Discharges (slugs). Activities or installations that have a significant potential for spills or batch discharges will develop a slug prevention plan.

M Subsection 5.1.1 is extranneous and therefore deleted.

CEANN 21 CES

5.2 1

What "surface" water from where is being discharged?

What chemical constituents are in those surface waters?

How it is ensured that those waters do not contain any hazardous materials or waste? A description is required.

G4.3.2.1.6. Spills and Batch Discharges (slugs). Activities or installations that have a significant potential for spills or batch discharges will develop a slug prevention plan.

M Subsection 5.1.5 is extranneous and therefore deleted.

12 5.1.1

"As mentioned in paragraph 5.3…" 5.3 follows 5.1.1, so this shouldn't be past tense ("mentioned"). Suggest "As is addressed in paragraph 5.3, …." Grammatical correctness.

M Subsection 5.1.1 is extranneous and therefore deleted.

CEANN 21 CES

13 5.3.2 Storm water drainage system is not capitalized. Grammatical correctness.

A Capitals deleted.

CEANN 21 CES

13 5.3.3 Oil water separators should not be capitalized because it is not a proper noun. Grammatical correctness.

A Capitals deleted.

CEANN 21 CES

Ap pe nd ix

Todd Degarmo's comment, Item #2. Section 4.5 was not updated per his 2009 comments and should have been. A plan should be a "stand alone" document without the need to find and reference another plan. The information from Section 5.2.1 of the SPRP should be included in this plan ‐‐ not simply referenced.

G4.3.2.1.6. Spills and Batch Discharges (slugs). Activities or installations that have a significant potential for spills or batch discharges will develop a slug prevention plan.

A The use of drain covers is outlined and stated in subsection 5.2.1.

4.6 Conclusion