Appendix_D_-_HWM_Plan.pdf

Contract No. FA2523-05-C-9001 01 July 2011

HAZARDOUS WASTE MANAGEMENT PLAN

Thule Air Base

CDRL CEV-15B

FINAL

OPR: GREENLAND CONTRACTORS

Chief of Environmental Engineering DSN 629-3840 ext. 2698 Supersedes CDRL CEV-15B, 01 July 2010 edition

CDRL CEV-15B Hazardous Waste Management Plan

Thule Air Base 3 01 July 2011

TABLE OF CONTENTS

1 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

2 GENERAL

2.1 Purpose

2.2 Scope

2.3 Regulatory Overview

3 ORGANIZATIONS AND RESPONSIBILITIES

3.1 Installation Commander, 821 ABG/CC

3.2 Accounting and Finance, 821 ABG/FM

3.3 Danish Liaison Officer, DLO

3.4 Occupational Health & Safety, GC/OHS

3.5 GC Civil Engineering, GC/CE

3.6 Base Supply, GC/LGS

3.7 GC Environmental Engineering, GC/EE

3.8 Defense Reutilization and Management Organization DRMO, GC/LGDRM

3.9 Fire Protection, GC/AMF

3.10 Generators of Hazardous Waste

4 HAZARDOUS WASTE CHARACTERISTICS

4.1 Characterization of Waste

4.1.1 Ignitable Waste (D001):

4.1.2 Corrosive Waste (D002):

4.1.3 Reactive Waste (D003):

4.1.4 Toxicity Characteristic Waste (D004-D43):

4.2 Listed Waste:

4.2.1 F-list

4.2.2 K-list:

4.2.3 P-list

4.2.4 U-list:

4.3 Hazardous Waste Mixtures

5 HAZARDOUS WASTE STORAGE

5.1 Hazardous Waste Accumulation Point

5.1.1 Requirements for HWAP

5.1.2 Documentation required in the HWAP

5.2 Hazardous Waste Storage Area

Thule Air Base 4 01 July 2011

5.2.1 Requirements for HWSA

5.2.2 Documentation for the HWSA

5.3 Closure Plans

6 LABELING

6.1 Hazardous Waste Label

6.2 Non Hazardous Waste Label

6.3 Hazard Class

7 TURN-IN PROCEDURES

7.1 Hazardous Waste Turn-in Procedure

7.2 Hazardous Materials Turn-in Procedure

7.3 EPA Provisional ID Number

8 CONTINGENCY, PREPAREDNESS AND SPILL RESPONSE

9 PERSONNEL TRAINING

APPENDICES

APPENDIX 1: DEFINITIONS AND TERMS

APPENDIX 2: HAZARDOUS WASTE INVENTORY AT THULE AB

APPENDIX 3: WASTE ANALYSIS PLAN

APPENDIX 4: BATTERY HANDLING PROCEDURES

APPENDIX 5: TURN-IN DOCUMENTS

APPENDIX 6: EMPTY CONTAINER MANAGEMENT FOR HWSA

APPENDIX 7: LOGBOOKS FOR HWSA

APPENDIX 8: INSPECTION CHECK LIST FOR HWAP/HWSA

APPENDIX 9: CLOSURE PLAN

APPENDIX 10: DRUM / SMALL ITEM SHEET

APPENDIX 11: NEW HWAP CHECK LIST

APPENDIX 12: DISTRIBUTION LIST

APPENDIX 13: 2011 REVIEW COMMENTS

Thule Air Base 5 01 July 2011

1 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

Title

: The title of this document is “Hazardous Waste Management Plan”. The acronym HWMP will be used throughout the document.

Classification

: This document is unclassified.

Responsibilities

: Greenland Contractors, Environmental Engineering (GC/EE) is the office of primary responsibility for developing and maintaining the HWMP. 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 HWMP that are essential in the accomplishment of necessary planning and in the preparation of supporting documents and reports.

References

: References referred to in the HWMP 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 HWMP will be 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.

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

Distribution

: The plan is distributed IAW the CDRL Summary distribution list, APPENDIX 12.

Thule Air Base 6 01 July 2011

2 GENERAL

2.1 Purpose

The purpose of the HWMP is to ensure that documented guidance for hazardous waste (HW) management is available to all installation personnel.

The documentation will include:

• Identification of all HW generators.

• Identification of all HW streams.

• Identification and description of all HW being produced.

• Implementation of proper procedures for handling, labeling, marking, storing, and disposing of HW.

• Monitoring the required performances with regard to HW management as described in this plan.

• Continued evaluation and update of the HW inventory and analysis plan.

• Establishment of procedures to ensure outside contractors' compliance with the Thule AB

HWMP.

• Revision and update of host-tenant support agreements and exercise support agreements (BOX-TOP, ICEX, etc.) by the Environmental Protection Committee to ensure that these comply with the HWMP.

The goal is to achieve a full state of awareness throughout the installation in order to protect employee health, provide a safe work environment, minimize adverse effects on the environment from the generation and disposal of HW, and minimize the disposal costs of the generated HW.

2.2 Scope

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

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

• Solid Waste Management Plan, CDRL CEV-15E

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

• Asbestos Management Plan, CDRL CEV-15A

• Slug (Wastewater) Management Plan, CDRL CEV-15J

• Storm Water Management Plan, CDRL CEV-15G

Thule Air Base 7 01 July 2011

2.3 Regulatory Overview

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

Federal Regulations: 40 CFR, Title 40, Parts 1-790 and Environmental Requirements

Parts 1-900 (Guidance)

49 CFR, Title 49, Parts 171-80 and Hazardous Material Parts 100- 199 (Guidance)

USAF: Final Governing Standards for Environmental Protection by United

States Forces in Greenland, prepared by HQ AFSPACECOM, referenced herein as FGS.

Thule AB: EPC Decisions

Host Country: Country to Country Agreement concerning Disposal of United

States Salvage:

Memorandum of Understanding (MOU), “An Agreement Concerning the Disposal of United States Salvage, Surplus or Excess Equipment and Supplies at USAF Aerospace Defense Command Bases and Sites in Greenland”, dated 29 June 1976 and 1987 Amendment.

Thule Air Base 8 01 July 2011

3 ORGANIZATIONS AND RESPONSIBILITIES

In order to ensure that hazardous waste is handled in an environmentally correct manner, it is important that the hazardous waste generators are fully aware of their responsibilities in the HW management program. These responsibilities are outlined in the following:

3.1 Installation Commander, 821 ABG/CC

The Installation Commander has the overall responsibility for the management of HW generated at Thule AB. The responsibility is implemented through the base Environmental Protection Committee (EPC), of which the Installation Commander is the chairman.

The incident commander will be designated IAW the Thule AB Continuity of Operations (COOP)/ Comprehensive Emergency Management Plan (CEMP) 10-2.

3.2 Accounting and Finance, 821 ABG/FM

The Accounting and Finance office assists in setting up accounts for fund management for the laboratory analysis and disposal costs of all HW.

3.3 Danish Liaison Officer, DLO

The Danish Liaison Officer serves as the official representative of Denmark and the Greenlandic Government (GG) concerning environmental issues at Thule AB.

3.4 Occupational Health & Safety, GC/OHS

The Occupational Safety & Health office performs safety and health inspections. Occupational Safety & Health is involved in an advisory role in any unknown situation waste handling personel encounter in relation to personal protective gear, correct signs, escape routes, ventilation and other work related potential hazards. By maintaining proper signs in English federal employees are warned about the potential hazards in handling hazardous waste.

3.5 GC Civil Engineering, GC/CE

The Civil Engineering office is responsible for the establishment of procedures to ensure that all projects are reviewed by GC Environmental Engineering. All projects must include special provisions to ensure that the disposal of HW is carried out in accordance with the HWMP, and that seasonal contractors properly dispose of HW generated, as a result of their activities at Thule AB.

3.6 Base Supply, GC/LGS

Base Supply is responsible for the operation of the Thule Air Base HAZMART (AFI 32-7086, Hazardous Materials Management (HAZMART)).

3.7 GC Environmental Engineering, GC/EE

Environmental Engineering is responsible for developing and implementing the HWMP.

GC Environmental Engineering will assist waste generators at TAB in identifying, characterizing and evaluating all HW.

• Supervise the waste generator on the correct procedures for handling, storing and turning in HW. Ensure seasonal contractors comply with the requirements for disposal of HW as outlined in this plan.

Thule Air Base 9 01 July 2011

• Conduct quarterly inspections of the Hazardous Waste Accumulation Points (HWAPs) and monthly inspections of the Hazardous Waste Storage Areas (HWSAs).

• Conduct required training for employees handling HW.

• Confirm that contractors, who want to dispose of their waste outside the DRMS system, have developed their own manifest tracking system to provide an audit trail from the point of generation to the ultimate disposal.

3.8 Defense Reutilization and Management Organization DRMO, GC/LGDRM The responsibilities of the DRMO include:

• Off-site shipment of HW.

• Maintaining records of DD Form 1348-1A (manifests). Manifests will be retained for a period of three years.

• File the U.S. EPA Uniform Manifest (EPA Form 8700-22).

• Operation and weekly inspection of the HWSA using the checklist in APPENDIX 8.

• Assisting the hazardous waste generators and GC Environmental Engineering in identifying proper labeling and packaging for transportation.

3.9 Fire Protection, GC/AMF

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

The Fire Chief’s responsibilities include:

• Providing technical assistance on fire protection aspects of HW management.

• Assisting in the required fire prevention training for employees handling HW.

• Inspecting HW accumulation areas for fire hazards.

3.10 Generators of Hazardous Waste

Any waste generator (Greenland Contractors or other contractors) that generates HW through its activities will handle it in accordance with the HWMP. The waste generator will notify GC Environmental Engineering whenever there is an inconsistency with the current generation of HW, or the generation of HW changes. It is the responsibility of the supervisor to ensure that the Hazardous Waste is handled correctly.

Each shop that generates Hazardous Waste, including turn-in of Non Hazardous Waste, will have a Point of Contact (POC) for the HW or a HazMat Specialist. The POC must have received hazardous waste handling training.

It is the obligation of any generator of Hazardous Waste to allocate the needed facility and manpower. This includes the time required for participation in training courses.

Contractors, including short term contractors, typically work at Thule AB during the summer.

Training these contractors to meet all requirements of this plan will be accomplished during orientation/pre-construction meetings by the Chief of Environmental Engineering or alternate.

GC will support contractors with basic services such as labels, spill kits etc. If a contractor generates hazardous waste, weekly inspections will be conducted.

Thule Air Base 10 01 July 2011

4 HAZARDOUS WASTE CHARACTERISTICS

Waste is hazardous if it can be harmful to human health and the environment when handled improperly.

Hazardous waste is a solid waste that:

1. Is a listed waste1 or

2. Exhibits a characteristic of a hazardous waste2 or typical hazardous materials characteristics3

The Waste identification process is shown in the flowchart below:

Solid waste

Is the waste listed? Does the waste exhibit any of the 4 characteristics specified?

No

The waste is hazardous waste

The waste is solid waste

See SWMP

Yes

No

Yes

Solid Waste The Hazardous Waste identification process is the first step in determining if the waste is solid or not.

Solid waste is: Garbage, refuse, sludge, and other discarded materials including solid, semisolid, liquid, and gaseous containing materials, resulting from industrial and commercial operations and from community activities.

It does not include solids or dissolved material in domestic sewage or other significant pollutants in water resources, such as silt, dissolved, or suspended solids in industrial wastewater effluent, dissolved materials in irrigation return flows or other common water pollutants.

1 See FGS appendix 1 2 See FGS appendix 1 3 See FGS Table C5.T1

Thule Air Base 11 01 July 2011

Outdated HM being stored for use and maintained beyond its shelf life, or due to a mission change, is no longer required. Thule AB normally downgrades this type of material to hazardous waste and it will be turned in to the DRMO as such. This is according to guidelines from DRMO, Norfolk who no longer has the capacity to handle HM and to ensure the HM to be used or resold. The only items shipped as HM are batteries from cars, trucks, UPS etc. that will be recycled.

4.1 Characterization of Waste

There are four Hazardous Waste characteristics. If a waste exhibits one or more of the four characteristics it is a Hazardous Waste. This can be determined by the user’s basic knowledge (MSDS) or by analyzing the waste.

The four characteristics are:

• Ignitable

• Corrosive

• Reactive

• Toxic

4.1.1 Ignitable Waste (D001):

A solid waste exhibits the characteristic of ignitability if a representative sample of the waste has any of the following properties:

• It is a liquid, other than an aqueous solution containing less than 24 percent alcohol by volume and has a flash point less than 60°C (140°F), as determined by a Pensky-Martens Closed Cup Tester, using the test method specified in ASTM Standard D-93-79 or D-93-80 or a Setaflash Closed Cup Tester, using the test method specified in ASTM Standard D-3278-78 or as determined by an equivalent test method.

• It is not a liquid and is capable, under standard temperature and pressure, of causing fire through friction, absorption of moisture or spontaneous chemical changes and, when ignited, burns so vigorously and persistently that it creates a hazard.

• It is an ignitable compressed gas as determined by appropriate test methods or USEPA.

• It is an oxidizer.

A flash point is the lowest temperature at which a liquid can emit a vapor that will ignite when exposed to an ignition source.

Oil based paint, cleaners, and contaminated fuel

Thule Air Base 12 01 July 2011

4.1.2 Corrosive Waste (D002):

Waste is corrosive if:

• It has a pH of less than 2

• It has a pH of greater than 12.5

• It is a liquid and corrodes steel (SAE 1020) at a rate greater than 6.35 mm (0.250 inch) per year at a test temperature of 55°C (130°F) as determined by the test method specified in NACE (National Association of Corrosion Engineers) Standard TM-01-69 as standardized in "Test Methods for the Evaluation of Solid Waste, Physical/Chemical Methods”

Strong acids such as battery acid and hydrochloric acid Bases such as sodium hydroxide

4.1.3 Reactive Waste (D003):

Waste is reactive if it is an unstable material that can pose a problem at any stage of the waste management cycle. A solid waste exhibits the characteristic of reactivity if a representative sample of the waste has any of the following properties:

• It is normally unstable and undergoes violent change readily without detonating.

• It reacts violently with water.

• It forms potentially explosive mixtures with water.

• When mixed with water, it generates toxic gases, vapors, or fumes in a quantity sufficient to present a danger to human health or the environment.

• It is a cyanide or sulfide bearing waste which, when exposed to pH conditions between 2 and 12.5, can generate toxic gases, vapors or fumes in a quantity sufficient to present a danger to human health or the environment.

• It is capable of detonation or explosive reaction if it is subjected to a strong initiating source or if heated under confinement.

• It is readily capable of detonation or explosive decomposition or reaction at standard temperature and pressure.

• It is a forbidden explosive.

Unexploded Ordnance (UXO) and flares

4.1.4 Toxicity Characteristic Waste (D004-D43):

Waste has a toxicity characteristic if it contains one or more compounds in a concentration higher than or equal to the regulatory level listed in the table below. These concentrations are determined using the EPA’s Toxicity Characteristic Leaching Procedure (TCLP) test method 1311 as stated in EPA publication SW-846. Where the waste contains less than 0.5 % filterable solids, the waste itself is considered to be the extract for the purpose of this section.

Thule Air Base 13 01 July 2011

EPA HW REGULATORY NO. CONTAMINANT LEVEL (mg/L)

D004 Arsenic 5.0

D005 Barium 100.0 D018 Benzene 0.5

D006 Cadmium 1.0

D019 Carbon Tetrachloride 0.5

D020 Chlordane 0.03

D021 Chlorobenzene 100.0 D022 Chloroform 6.0

D007 Chromium 5.0

D023 o-Cresol 200.0

D024 m-Cresol 200.0

D025 p-Cresol 200.0

D026 Cresol 200.0 D016 2,4-D 10.0

D027 1,4-Dichlorobenzene 7.5

D028 1,2-Dichloroethane 0.5

D029 1,1-Dichloroethylene 0.7

D030 2,4-Dinitrotoluene 0.13 D012 Endrin 0.02

D031 Heptachlor (and its epoxide) 0.008

D032 Hexachlorobenzene 0.13

D033 Hexachlorobutadiene 0.5

D034 Hexachloroethane 3.0

D008 Lead 5.0 D013 Lindane 0.4

D009 Mercury 0.2

D014 Methoxychlor 10.0

D035 Methyl Ethyl Ketone 200.0

D036 Nitrobenzene 2.0 D037 Pentachlorophenol 100.0

D038 Pyridine 5.0*

D010 Selenium 1.0

D011 Silver 5.0

D039 Tetrachloroethylene 0.7

D015 Toxaphene 0.5 D040 Trichloroethylene 0.5

D041 2,4,5-Trichlorophenol 400.0

D042 2,4,6-Trichlorophenol 2.0

D017 2,4,5-TP (Silvex) 1.0

D043 Vinyl Chloride 0.2

Thule Air Base 14 01 July 2011

4.2 Listed Waste:

A listed HW is a waste identified on one of four lists published in the EPA regulations. The lists are divided into

• F-list non-specific source wastes

• K-list specific source wastes

• P-list commercial chemical products

• U-list commercial chemical products

4.2.1 F-list

F-listed waste at Thule Air Base only applies to waste that is generated from the use of certain common organic solvents. Solvents used as solvent for their solvent properties, for example -used for degreasing and cleaning. The listing only covers solvents that are above a certain concentration before use. It is only F002 and F003 that are found in recurring waste streams at Thule Air Base.

Rags used for cleaning or degreasing and waste residue

4.2.2 K-list:

K-listed Hazardous Waste is from a specific source on the K-list. This list includes waste from certain wood-preserving chemical manufacturing, petroleum refining, and other manufacturing processes. This list is not relevant for Thule Air Base.

4.2.3 P-list

P-listed waste are certain unused acutely hazardous commercial chemical products. P-listed waste are not found in recurring waste streams at Thule AB.

4.2.4 U-list:

A U-listed waste is an unused commercial chemical product that is not acute. There are no recurring waste streams of this type at Thule AB.

Chemicals such as acetone, ethyl ether, and methanol

4.3 Hazardous Waste Mixtures

A HW mixture is a mixture of a listed HW and any other material, or a mixture of a characteristic HW and any other material - provided that the mixture still exhibits the hazard characteristic.

Thule Air Base 15 01 July 2011

Most mixtures of HW and other wastes or materials are classified as HW. Therefore, mixing a HW with a non-HW does not produce a non-hazardous mixture.

Hazardous Waste Residue:

• Any residue remaining in a container, or an inner liner removed from a container that held any commercial chemical product or manufactured chemical intermediate, having the generic name listed in Table AP1.T4 in the FGS, annotated “F”, "P" or "U" as the first character in the USEPA waste number.

• Any residue or contaminated soil, water, or other debris resulting from the cleanup of a spill into or on any land or water of any commercial chemical product or manufactured chemical intermediate having the generic name listed in Table AP1.T4 in the FGS, annotated “F”, "P" or "U" as the first character in the USEPA waste number.

Thule Air Base 16 01 July 2011

5 HAZARDOUS WASTE STORAGE

At Thule Air Base, there are two types of HW accumulation and storage points:

HWAP Hazardous Waste Accumulation Point

HWSA Hazardous Waste Storage Area

All HW will be accumulated in approved accumulation and storage points.

5.1 Hazardous Waste Accumulation Point

An HWAP is an area designated for the accumulation of HW at or near the point of generation.

Any shop which generates HW will have an HWAP in order to accumulate waste in accordance with the FGS. The requirements for the HWAP will ensure the waste is accumulated in a proper and environmentally safe manner.

An HWAP may be used to accumulate no more than 55 gallons of hazardous waste, or 1 liter (1 quart) of acute waste from each waste stream.

HWAPs are established at the different work places as listed in APPENDIX 2. In the event that new hazardous waste streams are identified, HWAPs will be established or the waste stream will be added to an existing HWAP in coordination with GC Environmental Engineering as soon as possible.

(See FGS 6.2.6/6.3.2 Hazardous Waste Accumulation Points).

5.1.1 Requirements for HWAP

The requirements for an HWAP are as follows:

1. All HW will be accumulated in an approved HWAP at or near the point of generation.

2. Will accumulate no more than 208 liters (55 gallons) of hazardous waste, or 1 liter (1 quart) of acute hazardous waste4

3. The hazardous waste generator will identify a primary and an alternate HWAP manager.

An appointment letter will be sent to GC Environmental Engineering, Fire Protection and DRMO. The appointment letter has to be renewed within 30 days when the appointed HWAP manager or alternate change.

, from each waste stream.

4. HW that contains free liquids will be placed in secondary containment. The secondary containment will have sufficient capacity to contain 10% of the volume of all containers, or the volume of the largest container, whichever is greater. ´

5. Each HWAP will be designed and operated to provide appropriate segregation for different waste streams, including those, which are chemically incompatible.

6. The HWAP will be segregated from all potential ignition sources, including electrical sources, open flames, heat sources, cutting and welding operations, any smoking areas and ashtrays at a distance of 50 ft.

4 The waste listed in Appendix 1 in FGS with a U.S EPA waste number with the designator “P” or the waste with (H) following the waste number.

Thule Air Base 17 01 July 2011

7. Signs:

• Signs will clearly mark the designated area. The text on the sign will, as a minimum, be “HWAP”.

• The HWAP will clearly be marked with black and yellow striped safety hazard tape or paint.

• Each HWAP will have warning signs (National Fire Protection Association or appropriate international sign) appropriate for the waste being accumulated at that site.

8. There is no time limit for accumulation in an HWAP.

9. Only 90% of a container will be filled in order to allow for expansion.

10. When amounts in paragraph 5.1.1.2 are met or the container is 90% filled, the container will be transferred to a HWSA within five working days. HW containers will be labeled as directed in Chapter 6.

11. Containers will be UN-approved except for containers for batteries.

12. Containers will be in a good condition (no rusting, bulging or structural defects).

13. A container holding hazardous waste will always be closed during storage, except when it is necessary to add or remove waste.

14. Container with flammable liquids will be grounded (especially when transferring liquid hazardous waste).

15. A contingency plan will be maintained and be easily accessible in each HWAP (chapter 8)

16. Emergency telephone or radio will be available at or near the HWAP (i.e. a phone in a nearby office is sufficient).

17. Appropriate spill absorbent for the waste stored will be available.

18. Personal protective equipment will be available in sufficient amounts and appropriate for the waste stored, e.g. an eye wash station.

19. The HWAP will be orderly and not contain items or materials that are not hazardous waste (exception: the accumulation of drainable batteries for recycling is permitted in bldg. 580 even though the batteries are considered Hazardous Material and not waste).

20. The Hazardous Waste Management Plan will be accessible at the HWAP.

21. Personal training requirements will be met. It is the responsibility of the shop supervisor to only assign personnel to HWAP duties after they have received hazardous waste training.

The requirements for HWAPs will be communicated as part of the training. Hazardous waste training is provided by GC/EE (Appendix 9).

22. The HWAP will be inspected at least once every quarter by GC Environmental Engineering. GC/EE will follow up on discrepancies from requirements.

23. The schedule for inspection of well managed HWAPs can be reduced by GC Environmental Engineering to two times per year.

Thule Air Base 18 01 July 2011

5.1.2 Documentation required in the HWAP

A binder will be maintained at each HWAP (the ‘HWAP binder’). A nearby office is an acceptable location.

1. A training record for the HWAP managers and the shop supervisor will be available in the HWAP binder. Training records for individual that handles hazardous waste may be located in the HWAP binder or in a central database (e.g. GC Human Resources).

2. Inspection checklist from internal inspections and inspections made by GC Environmental Engineering for the last three years will be available in the HWAP binder (Appendix 8).

3. An inventory list will be maintained in a HWAP binder. It is the responsibility of the HWAP manager to update the inventory list if hazardous waste streams are eliminated or new hazardous waste streams appear. Furthermore, changes in inventories will be communicated to GC/EE in order to assess changes in the requirements for personal protection equipment, spill response equipment and the specific contingency plan. It is the responsibility of GC/EE to verify all of the above during quarterly inspections.

4. If a user disposes of wastes not on the inventory list for a HWAP, the waste will be identified on a Drum/small item sheet (Appendix 10). Blank Drum/small items sheets will be available in the HWAP binder.

5. Turn-in documentation (Appendix 5) and Manifests for outgoing hazardous waste and analysis results/MSDS information for recurrent waste streams (waste characterization) for the last three years will be kept on file at the DRMO office, bldg. 935. A reference to where this documentation is filed will be available in the HWAP binder.

6. Access to this plan will be described in the HWAP binder.

5.2 Hazardous Waste Storage Area

A HWSA is an area designated for accumulation and storage of HW. In the HWSA, there is stored HW in quantities greater than 55 gallons received from one or more HWAPs. Testing and maintenance of emergency equipment is conducted at least annually.

There are no limitations volumetrically on the quantity of HW accumulated, and no requirements to the HWSA being located at or near the point of generation.

At Thule AB, there are the following HWSAs:

• Bldg. #604 – Funded HW storage. Operated by DRMO

• Bldg #937 – Potential HW pending analysis. Operated by DRMO.

When transporting hazardous waste to and from the HWSA drivers will have a valid ADR certificate (European transport certificate

5.2.1 Requirements for HWSA

1. Hazardous waste has a maximum Storage-Time of one year.

2. Storage of more than 55 gallons of hazardous waste or one quart of acute waste.

3. The Manager who is responsible for the shop will appoint an HWSA manager, an alternate and POC’s, and send an appointment letter to GC Environmental Engineering, DRMO and Fire Protection. The appointment letter has to be renewed when the appointed HWAP manager or alternate change.

Thule Air Base 19 01 July 2011

4. HW that contain liquids will be placed in secondary containment. Annual leak tests of the secondary containment will be performed.

5. The HWSA will be designed and maintained to prevent fire, explosions, and release of HW/HM into the environment.

6. Access will be controlled to prevent incidental contact.

• For outdoor facilities, the requirement is a fence with a lockable gate.

• For buildings, the requirement is a lockable entrance to the building.

• When outdoor facilities and buildings are not in use, fences and doors are kept locked. Keys are only entrusted to DRMO HAZMAT specialists, the Base Civil Engineer and the Fire Chief.

• The HWSA will be designed and maintained to prevent fire, explosions, and release of HW/HM into the environment.

7. A sign will be posted and will be visible from at least 25 feet from all approaches. The sign will have the following text:

English:

• "DANGER UNAUTHORIZED PERSONNEL KEEP OUT"

• “HAZARDOUS WASTE MANAGEMENT AREA"

Danish:

• ”Uvedkommende ingen adgang”

• ”Område med farligt affald”

Greenlandic:

• ”Navianartoq susassaqanngitsut iseqqusaanngillat”

• ”Tamanna nakkutigineqarpoq Navianartumik ilitsivik

8. Ignitable or reactive waste will be segregated from all potential ignition sources to prevent fire or explosions. These types of waste will be separated from all electrical sources, heat sources, open flames, cutting or welding operations, and smoking areas at a distance of 50 ft.

9. Aisle space will be wide enough to allow inspection of the drums. A minimum of 4 ft. is recommended along the center aisle, and a 2-ft vertical and horizontal aisle should be provided between the other rows.

10. Incompatible wastes will be properly segregated.

11. A contingency plan will be maintained and be easily accessible in each HWSA (chapter 8).

12. Personal protective equipment will be available in sufficient amounts and appropriate for the waste stored.

13. Emergency telephone or radio, Portable fire extinguisher and an eye wash station/bottles will be available.

Thule Air Base 20 01 July 2011

14. Spill absorbents appropriate for the waste stored will be available.

15. A Closure Plan for will be available (Appendix 9)

16. The HWSA will be inspected weekly by the HWSA manager (self-inspection, Appendix 8).

17. An operation log will be maintained for these areas by the local DRMO function. In this log the date, volume, type of waste transferred to or from the HWSA, a notification of the observations made, and the date and nature of any repairs or other remedial actions will be noted.

18. The DRMO function will prepare the EPA Uniform Manifest for all off-site shipments and maintain a copy of the manifests for at least three years after shipment. The HWSA manager will ensure that a DD Form 1348-1A, a DRMS Form 1930, and relevant support documents (MSDS, analysis report, log) accompany all HW turned in, and that the HW is funded by GC Environmental Engineering.

19. When stored in Bldg. #604, the containers will be placed on pallets and sufficient aisle space will be ensured between rows to allow forklift operation and ready access for inspection and possible leak response.

20. Incompatible hazardous waste will be segregated with (temporary) walls to avoid incidental mixing if a spill occurs.

21. The requirements of HWSAs is part of the Hazardous Waste Training provided by GC/EE to HWSA managers.

22. The HWSA is inspected once every quarter by GC Environmental Engineering and annually by Fire Protection. GC/EE will follow up on discrepancies from requirements.

5.2.2 Documentation for the HWSA

1. A training record for the individual that handles hazardous waste and their supervisor will be available at the HWSA.

2. Turn-in documents (Appendix 5) for the last three years will be available at the DRMO office and in the HWSA.

• 1348-1A

• 1930

3. A HWSA Logbook will be maintained at the HWSA by the HWSA manager (Appendix 7). The inventory will be updated immediately when changes occur.

4. The HWSA Logbook will be available to the Fire Department.

5. Inspection records for at least three years will be maintained at the HWSA (Appendix 8).

6. Manifests for outgoing hazardous waste for the last three years will be available in GC Supply.

The DRMO function (GC/LGDRM) is responsible for maintaining this documentation. When the turn in documents, analyses and checklists from inspections are no longer needed they are to be sent to GC Environmental Engineering

Thule Air Base 21 01 July 2011

5.3 Closure Plans

Every HW Storage Area (HWSA) will have a closure plan (see APPENDIX 9) before it is opened.

The plan will specify the procedures to be followed in order to achieve complete and safe closure. This includes:

1. Removal of all waste to another HWSA or by ship to CONUS.

2. Removal of all temporary dike walls. If spills have occurred on flexible liners, these should be containerized and disposed of as HW. If no spills have occurred, the liners may be disposed of in the sanitary landfill.

3. Removal of used pallets. If any spills have occurred on the pallets or they show any visible signs of contamination, the pallets should be dismantled and disposed of as HW, otherwise they may be disposed of at the sanitary landfill.

4. Handling of any polluted soil by treatment and disposal of this as HW.

It is the responsibility of the HWSA manager to ensure a complete and safe closure of the storage area. The closure will be coordinated with GC Environmental Engineering.

Thule Air Base 22 01 July 2011

6 LABELING

Containers will be properly marked to indicate their use for waste accumulation and stores.

The container will be marked with one of the three labels and hazard class.

All other markings on the container from previous use will be removed before it is used for waste accumulation.

6.1 Hazardous Waste Label

Yellow label: “HAZARDOUS WASTE” is used when the waste is determined to be hazardous. The information on the label will include:

Name: Organization (e.g. 821ABG/GC/SVCS, Bldg. #237)

Address: Thule Air Base, Greenland

City: APO AE 09704-5000

US-EPA id no.: e.g MIR 0000 36616

EPA waste no.: The EPA waste no. (stated by MSDS, or FGS, e.g. D001)

Accumulation start date: The date the drum is filled to 90% of its capacity

The proper shipping name and UN number will be written e.g., “Environmentally Hazardous Substances Solid N.O.S” UN: 3077.

White label: “THIS CONTAINER ON HOLD PENDING ANALYSIS” is used if the contents of the container are unknown and a sample will be collected for HW characterization and while awaiting analysis results: The information on the label will include:

Contents: e.g., Drum found on base

Origin of materials: Process or activity, e.g. Drum Project

Address: Organization (e.g., 821ABG/GC/OMEP, Bldg. #801)

Accumulation start date: Date of sampling

Black label: “USED BATTERIES” is used for batteries.

Shipper: Organization (e.g., 821ABG/GC/CEMR, Bldg.

#551)

Address: Thule Air Base, Greenland

City: APO AE 09704-5000

Contents: Used batteries/ hazardous waste

Thule Air Base 23 01 July 2011

6.2 Non Hazardous Waste Label

Green label: “NON-HAZARDOUS WASTE” is used when the waste is determined to be non-hazardous. The information on the label will include:

Shipper: Organization

(e.g., 821ABG/GC/SV, Bldg. #237)

Address: Thule Air Base, Greenland

City: APO AE 09704-5000

Contents: e.g., used developer

“Used oil” label is used for oil suitable for energy recovery (See SWMP). The information on the label will include:

Company: Organization

(e.g., 821ABG/GC/LGTM, bldg. #580)

Address: Thule Air Base, Greenland

City: APO AE 09704-5000

Source: e.g., Oil changes in WM

Contact: Hazmat specialist, Shop Supervisor or waste oil truck

“Drained used oil filter” label is used for oil filters. The information on the label will include:

Accumulation start date: The date the drum is filled to 90% of its capacity.

Below the “Accumulation start date” write shop name: GC/LGTM bldg. #580

Thule Air Base 24 01 July 2011

6.3 Hazard Class

The warning labels most commonly used at Thule AB are:

Flammable: Hazard class 3 Flashpoint is below 140º F (60º C).

Poisonous: Hazard class 6

Corrosive: Hazard class 8 pH-value is less than 2 or greater than 12.5.

Miscellaneous: Hazard class 9

All labels can be ordered from the DRMO, ext. 2785. The DRMO will identify the proper Department of Transportation (DOT) marking for each shipping container.

Thule Air Base 25 01 July 2011

7 TURN-IN PROCEDURES

7.1 Hazardous Waste Turn-in Procedure

The following procedure will be followed when HW is turned in:

1. Get a Material Safety Data Sheet (MSDS) or analysis test results and if required the logbook for HW.

2. The waste generator characterizes the hazardous waste.

3. Hazardous waste containing free liquids will always be over packed before turn-in.

Containers below 55 gallons will be placed in the salvage drum that is packed with absorbent material.

4. Label the container, see Chapter 6.

5. The waste generator will in cooperation with DRMO fill out the turn-in papers for HW:

a. Hazardous Waste Profile Sheet, (DRMS Form 1930), see APPENDIX 5.

b. DD Form 1348-1A, see APPENDIX 5.

6. Contact the DRMO, ext. 2785, for weighing and transportation.

7. All HW turn-in documents will be kept on file at the DRMO and the waste generator for a period of three years from the date of turn-in.

8. Contact GC/EE for funding.

7.2 Hazardous Materials Turn-in Procedure

The procedure for turn in of HM, only batteries, is the same as for HW, except for the following:

1. A DD Form 2521 or DD Form 2522 (half the size of a DD Form 2521) will be filled out instead of the DRMS Form 1930. The form will be filled out using the information given on the material’s MSDS.

2. The original price or an estimate price will be printed on the DD Form 1348-1A.

3. The strict regulations, which apply for packaging HW, do not apply for HM, but packaging will be appropriate for transportation.

7.3 EPA Provisional ID Number

Shortly (7 to 8 days) before the Pacer Goose departs from Thule AB to Norfolk, VA, EPA Form 8700-12 “RCRA Subtitle C Site Identification” is prepared for 821ABG/CC signature and consequently submitted to the Virginia Department of Environmental Quality IAW CDRL CEV-

18. The EPA Provisional ID Number will be renewed after 30 days of the initial number, if the HW has not reached its final location.

Thule Air Base 26 01 July 2011

8 CONTINGENCY, PREPAREDNESS AND SPILL RESPONSE

Contingency Plan: A document setting out an organized, planned, and coordinated course of action to be followed in case of a fire, explosion, or release of hazardous waste or hazardous waste constituents that could threaten human health or the environment.

The HW generators are responsible for the development and updating of the site-specific contingency plans for each HWAP/HWSA. GC Environmental Engineering will, if required, assist in the development and updating of the plans, which should be available in English, Danish and Greenlandic.

The plan has to be submitted to any function identified in the plan, and which the plan relies upon to provide emergency services, e.g. police department, fire department, hospital and emergency response teams.

The contingency plan will be designed to minimize hazards to human health or the environment from fires, explosions, or any unplanned sudden or non-sudden release of HW into the air, soil, and water. Specific requirements to be incorporated into the plan are described below.

Each contingency plan will contain the following information:

• The most important and most detailed portion of the contingency plan is the description of the emergency procedures that will be followed for HW-related emergencies. The plan should detail response actions that will be implemented in the event of a release, fire, and/or explosion at each accumulation site.

• Where HW is generated, accumulated, or stored will be evaluated to determine what kinds of emergency equipment may be necessary to abate emergencies that may be reasonably anticipated to occur at that location. A list of emergency equipment that may be used in the event of a HW incident.

• The emergency response equipment can include:

- Spill booms or absorbent pillows.

- Granular absorbents (one drum for every 300 gallons stored).

- Fire control equipment, as decided by GC/AMF.

- Chemical respirators suitable for the waste in storage.

- Emergency eyewash stations (bottle-type is sufficient).

- Gloves and boots.

- Face shields and safety glasses.

- Salvage drums.

Personal protective equipment will be available in sufficient amounts. GC Environmental Engineering will ensure, together with Fire Protection, that there is enough equipment and that it is properly maintained.

If there is a possibility that evacuation from a building or the installation may be necessary, the contingency plan will include an evacuation plan. The evacuation plan will describe signals used to begin evacuation and evacuation routes. Alternate evacuation routes will be described if the primary routes are blocked by the release of HW, fire, or explosion.

Thule Air Base 27 01 July 2011

9 PERSONNEL TRAINING

The Hazardous Waste Handler Course is mandatory for personnel that handle or otherwise manage HW, and their supervisor / superintendent / managers. Superintendents / supervisors / managers will participate a minimum of one time, while personnel who handle hazardous waste (i.e. POC for HWAP/HWSAs) will participate once a year.

The training is provided by GC Environmental Engineering. A notification is sent to the supervisor/ superintendent when a course is scheduled. The training will be conducted by qualified trainers who have completed an instructor training program in the subject, have comparable academic credentials, or experience.

The training will include but is not limited to:

• Chemical hazards of HW.

• Regulatory overview.

• Emergency procedures (response to spills, spill kits, clean-up, etc).

• Drum/container handling/storage and safe use of HW equipment.

• Personal protective equipment.

• Record keeping, inspections, contingency plans and storage requirements.

• Turn-in procedures (HW profiles, funding documents, etc).

Newly assigned personnel handling HW should be provided the training before starting the job.

Training records for personnel involved in the handling of HW will be kept on file by the organizations/departments, to which the employee in question is assigned, and retained for 3 years after termination of duty of the employee. Records will identify the employee's position and responsibility in handling HW, as well as the date when the training was received.

Thule Air Base 28 01 July 2011

APPENDICES

Thule Air Base 29 01 July 2011

APPENDIX 1: DEFINITIONS AND TERMS

Acute Hazardous Waste – Waste listed in Appendix 1 with a U.S. EPA waste number with the designator “P” or waste with (H) following the waste number. See FGS Appendix 1.

Characteristic Waste - Waste that exhibits any of the characteristics listed in the FGS, Appendix 1 (i.e. toxicity, corrosive, ignitability, reactivity).

Closed Container - A HW container where the lid is fastened with locking rings or bungs wrench-tight.

Container - Any device, in which a material is stored, transported, treated, disposed of, or otherwise handled.

Disposal - The utilization of those methods of treatment and/or containment technologies, as are approved in the FGS, section 11, that effectively mitigate the hazard to human health or the environment of the discharge, deposit, injection, dumping, spilling, leaking, or placing of any HW into, or on any land or water in a manner that, without application of such methods, such hazardous wastes or any constituent thereof may enter the environment or be emitted into the air or discharged into any waters including groundwater.

DOT - Department of Transportation.

DRMO (local) - Defense Reutilization and Marketing Office.

DRMS - Defense Reutilization and Marketing Service.

EPA - Environmental Protection Agency.

EPA Hazardous Waste Number - The number assigned by the EPA to each HW listed in the FGS, Appendix 1, and to each characteristic identified in the FGS, Appendix 1.

EPA Identification Number - The number assigned by the EPA to each generator, treatment, storage, or disposal facility. Thule AB EPA ID Number: MIR 0000 36616.

EPC - Environmental Protection Committee.

FGS - Final Governing Standards.

Flash Point - The minimum temperature, where there is sufficient vapor to ignite the source, if introduced to an external ignition source.

Generator - Any person or site whose act or process produce HW, identified or listed in the FGS. Thule AB is considered a small quantity generator.

Generating Activity - Every organization (including tenants), shop and/or work area possessing an operation or process that initially generates a HW stream.

Hazardous Waste Characterization - HW characterization is the identification, description, and qualification of a HW stream.

Thule Air Base 30 01 July 2011

Hazardous Waste Profile Sheet - DRMS-Form 1930, which describes the physical and chemical properties of a HW.

HTSC – Harris Technical Service Corporation.

HM - Hazardous Material.

HW - Hazardous Waste as defined in the FGS, Appendix 1.

HWAP – A Hazardous Waste Accumulation Point is a location designated for accumulation of HW from a specific process, in a container near its point of generation. The volume accumulated will not exceed 55 gallons for each HW stream or 1 quart (0,946 liters) of acute

HW.

HWSA – A Hazardous Storage Area is a designated location for waste from Accumulation Points. The HWSA is a storage area where more than 55 gallons of hazardous waste is stored, and more than one container per waste stream may be placed at the accumulation point.

Normal storage time at this point is one year for small quantity generators, but due to the Arctic conditions with a limited port season, this time requirement cannot always be met.

Listed Waste - A specifically identified chemical, which is listed in the FGS, Appendix 1.

Manifest - The shipping document originated and signed by the generator, which contains the information required by the EPA.

Manifest Document Number -The serial number assigned to the manifest by the generator for recording and reporting purposes.

N.O.S. – Not otherwise specified.

Secondary Containment – A system that is sufficiently impervious to contain leaks, spills and accumulated precipitation until the collected material is detected and removed.

Spill - The accidental spilling, leaking, pumping, pouring, emitting, or drumming of HM, which become HW when spilled into water or on any land.

Storage-time – The time that HW has been stored since the container has been finally closed at the HWAP.

Thule AB - Thule Air Base.

Waste Stream Code - A unique identification number assigned to each waste stream by GC Environmental Engineering after the identification of that waste stream.

Thule Air Base 31 01 July 2011

APPENDIX 2: HAZARDOUS WASTE INVENTORY AT THULE AB

The Hazardous waste inventory list also contains waste that in accordance with the FGS is not hazardous waste. Examples include radioactive detectors, asbestos containing materials and other wastes which are appropriate to manage and dispose as regulated waste.

HW inventory is developed based on the information provided by the individual shops

LIST OF RECURRING INDUSTRIAL GENERATED HAZARDOUS WASTE STREAMS

Type of Waste Waste

Stream Code

Sources (GC unless otherwise indicated)

Disposal Hazardous waste characteristics

Oil Rags HWAP-01 Vehicle Refueling 563, Vehicle Maintenance580, Air Greenland 606, M-Plant 1391 K-Plant 1401

BMEWS, SMART-1, 4002

DRMO Not HW

Rags with Solvent HWAP-02 Vehicle Maintenance 580 Enterprise 801

DRMO F003

Used Adsorbent HWAP-03 Basewide DRMO D001 Aerosol Spray Residue (except paint)

HWAP-04 Basewide DRMO D001

Batteries, Misc. HWAP-05 Basewide DRMO D002,D006, D008

Fluorescent Light Bulbs

HWAP-06 Basewide DRMO Universal Waste

Paint (oil-based) HWAP-07 Enterprise 801 DRMO D001 Paint (latex) HWAP-08 Enterprise 801 DRMO Not HW Paint related material (Thinner)

HWAP-09 Vehicle Maintenance 580, Enterprise 801

DRMO D001

Aerosol filter (paint can puncture)

HWAP-10 Vehicle Maintenance 580 DRMO D001

Used oil filters vehicle

HWAP-11 Vehicle Maintenance 580 DRMO D001

Used fuel filters, vehicle

HWAP-12 Vehicle Maintenance 580 DRMO D001

Drained fuel filters, fuel operations

HWAP-13 K-Plant 1401 DRMO D001

Drained oil filters, power production

HWAP-14 K-Plant 1401 DRMO D001

Antifreeze, non-recoverable

HWAP-15 Vehicle Maintenance 580 DRMO Not HW

Thule Air Base 32 01 July 2011

Stream Code

Sources (facility number)

Disposal Hazardous waste characteristics

Potash, used oil incineration

HWAP-16 K-plant 1401 DRMO Not HW

Break Fluid HWAP-17 Vehicle Maintenance 580 DRMO Not HW PCB ballasts, solid HWAP-18 Facility Maintenance 551 DRMO Not HW Old Mercury Switches

HWAP-19 Facility Maintenance 551 DRMO D009

Dry Cleaning Sludge HWAP-20 Laundry Services 237 DRMO F002 Lead Solder HWAP-21 Non-Secure Comm. 1411 DRMO D008 Aerosol Spray Residue - Paint

HWAP-22 Basewide DRMO D001

Dentist Waste (amalgam)

HWAP-23 Base Clinic 118

DRMO D009

Paint booth filters HWAP-24 Vehicle Maintenance 580 DRMO D005, D007, D008, D010

Used Chemical test kits

HWAP-25 Base Hospital 118 QES lab 555

DRMO Not hazardous waste

Radioactive Smoke Detectors

RAD-001 Non-Secure Comm. 1411 Bioenvironmental (Peterson)

Not HW

Medical Supplies past expiration date

MED-01 Base Clinic 118 Returned to McGuire AFB by

GC/LGT

P-042

Metal turnings and shavings - Brass

MET-01 Facility Maintenance 551, Enterprise 801, DET-1, SMART-1 1824, BMEWS, SMART-1 4002

DRMO D008

Stainless Steel turnings and shavings

MET-02 Facility Maintenance 551, Enterprise 801, DET-1, SMART-1 1824, BMEWS, SMART-1 4002

Landfill Not HW

Galvanized Steel turnings and shavings

MET-03 Facility Maintenance 551, Enterprise 801, DET-1, SMART-1 1824, BMEWS, SMART-1 4002

Landfill Not HW

Acid-resistant steel turnings and shavings

MET-04 Facility Maintenance 551, Enterprise 801, DET-1, SMART-1 1824, BMEWS, SMART-1 4002

Landfill Not HW

Construction Materials (Asbestos)

ASB-01 Basewide…