Appendix_I_-_Slug_Mgmt_Plan.pdf

Supersedes 01 July 2010 edition signed 16 February 2011

CDRL CEV–15J

SLUG MANAGEMENT PLAN

Thule Air Base, Greenland

FINAL FY-12

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

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 ORGANIZATIONAL ROLES AND RESPONSIBILITIES

3.1 Installation Commander, 821 ABG/CC

3.2 Danish Liaison Officer, DLO

3.3 Environmental Engineering, GC/EE

3.4 Occupational Health & Safety, GC/OHS

3.5 Civil Engineering, GC/CE

3.6 Utilities and Facilities Maintenance, GC/OMUFM

3.7 Fire Protection, GC/AMF

4 POTENTIAL SPILLS AND BATCH DISCHARGES (SLUGS)

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

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: 2011 REVIEW COMMENTS

Thule Air Base, Greenland 5

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 (OPR) for establishing, implementing and maintaining the SMP. The instructions given in the SMP are applicable to all organizations and tenant units at Thule AB.

Organizations and tenant units are authorized to extract and reproduce those sections of the SMP that are essential in the planning and 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 SMP is subject to change if any of the applicable laws, regulations, or requirements is altered.

Distribution

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

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2 GENERAL

2.1 Purpose

The purpose of the SMP is to identify activities that have a significant potential for spills or batch discharges (slugs) to the sanitary wastewater system at Thule AB, and provide guidelines or instructions for prevention and control.

2.2 Scope

The scope of the SMP is to describe the sanitary wastewater system at Thule AB, and identify activities that have a significant potential for spills or batch discharges (slugs). Storm water runoff is not drained to the sanitary wastewater system. Activities and best management practices related to storm water runoff are outlined in the Storm Water Management Plan, CDRL

CEV-15G.

Related environmental plans may need to be consulted:

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

• Hazardous Waste Management Plan, CDRL CEV-15B

• Hazardous Material Management Plan

The provisions of the SMP apply throughout Thule AB and to all personnel. Certain responsibilities are assigned to selected individuals identified in Section 3.

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

3 ORGANIZATIONAL ROLES 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 Environmental Engineering, GC/EE

Greenland Contractors, Environmental Engineering (GC/EE) is the office of primary responsibility (OPR) for establishing, implementing and maintaining the SMP.

3.4 Occupational Health & Safety, GC/OHS

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

3.5 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.

3.6 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.

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4 POTENTIAL SPILLS AND BATCH DISCHARGES (SLUGS)

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 a very low population density, approximately 65 miles from the nearest village. The climate is described as arctic desert.

Due to very low temperatures, the sanitary wastewater system (SWWS) on base consists of insulated black steel pipes located above ground with heat tracing. The wastewater runs gravitationally through the steel pipes 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 drainage 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

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. 622, and Bldg. 1408 plus an outdoor wash ramp near the harbor (no facility number assigned). In all facilities, the wash water 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.

During summer 2011 a new wash ramp has been established in Bldg. 605 (Hangar 3). The wash ramp is intended for washing larger vehicles from the Pavement and Ground Department. These vehicles were washed previously in bldg. 836. Bldg 836 is now scheduled for demolition in accordance with the consolidation plan for Thule AB and the wash ramp has been abandoned.

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

There is only one existing parts washer at Thule AB. It is located in Bldg 580 (Vehicle Maintenance).

Thule Air Base, Greenland 10

The water from the parts washer in Bldg. 580 is led to an oil/water separator and from there to the SWWS. 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. Temporary drain covers are used to prevent accidental chemical spills from reaching the SWWS. The covers can be removed for floor cleaning and other activities requiring use of the drain.

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.

Temporary drain covers are used to prevent accidental chemical spills from reaching the SWWS. The covers can be removed for floor cleaning and other activities requiring use of the drain.

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.

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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

Storage of petroleum, oil and lubricants (POL), and hazardous materials at the auxiliary power plant at J-site is located in a room with a sump drained directly to the SWWS. 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.

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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

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.

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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

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.

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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.

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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.

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APPENDICES

Thule Air Base, Greenland 19

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

APPENDIX 2: SEWAGE SYSTEM

Thule Air Base, Greenland 21

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@us.af.mil Todd.degarmo@us.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: 2011 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

NOTE: Comments 1 -9 are recommended.

1 CEANN 21 CES 9 Section

4.3.3 S Some of the paragraphs in this section do not

pertain to the title "Water from washing of aircrafts/vehicles". Wastewater from fire training ops, snowmelt, and remediation are discussed, Suggest changing the title to more accurately reflect the various activities you're talking about in the section.

Improve organization A The paragraphs are updated to include only the oil/water separators used for treatment of water from washing aircrafts/vehicles.

2 CEANN 21 CES 9 Section 4.3.3, 2nd para

S In the 2nd para, it is mentioned that Bldg 836 is scheduled for demo, but doesn't explain what activities occur in that bldg and how these activies are relevant to the waste water system. If vehicles are being washed in this facility, why not just add this facility in the first sentence? If it's something other than vehickes or aircraft, suggest explaining what is being washed and if there is an OWS associated with that bldg. Without some kind of explanation, it's not clear why Bldg 836 is even being mentioned. The next sentence indicates "all activities including the previous wash rack has been abandoned" - it is not clear what activities are being referred to - the activies in Bldg 836?

Needs clarification. A The paragraph is updated with clarification of previous activities in bldg 836.

3 CEANN 21 CES 9 Section 4.3.3, 4th para

S What is the mobile Brita filter system used for -vehicl/aircraft washing operations? Suggest giving a brief description.

Needs clarification. A The paragraph is deleted. The mobile Brita filter system is not used for washing vehicle processes, but to segregate POL water from the tankfarm.

4 CEANN 21 CES 10 Section 4.3.5, 2nd para

C If Bldg 4016 is at the BMEWS site, rather than saying the wastewater is being discharged to "the sewage system", suggest saying the watewater is being discharged to a septic tank and from which it is dispersed over a mountainside.

Clarification M There is no longer a parts washer located in bldg 4016. The paragraph is updated to reflect this.

5 CEANN 21 CES 10 Section 4.3.5

S General question/suggestion - have you looked at replacing the existing parts washers with closed loop, zero discharge systems; and at a certain frequency the concentrated wastewater and sludge are collected in a drum and disposed of with the rest of the hazardous waste generated at Thule?

Recommendation M There is no longer a parts washer located in bldg 4016. The parts washer located in bldg 580 is scheduled for replacement during summer 2012.

6 CEANN 21 CES 10 Section 4.4, para

S As you've done in section 5.2.1, recommend stating that "temporary drain covers are used to prevent accidental chemical spills from reaching the SWWS. The covers can be removed for floor cleaning and other activities requiring use of the drain."

Recommendation A The paragraph is updated with recommendation.

7 CEANN 21 CES 10 Section 4.5

S See above comment #6 Recommendation A The paragraph is updated with recommendation.

8 CEANN 21 CES 11 Section 4.5.3

S See comment #5 Recommendation M There is no longer a parts washer located in bldg 4016. The paragraph is updated to reflect this.

9 CEANN 21 CES 21 APP 3 A Change @peterson.af.mil to @us.af.mil AF changed email addresses. A Email address distribution list is updated IAW CDRL Distribution List.

10 CEANN 21 CES Add 21 CES/CEAN comments and GC response to plan

AF and GC agreed to add comments to all the plans, A 21 CES/CEAN comments and GC response are added to the plan.

4.6 Conclusion