Appendix_J_-_Installation_HAZMAT_Management_Plan.pdf

Thule Air Base Installation HAZMAT Management Plan

Installation HAZMAT Management Plan

Thule Air Base, Greenland

OPR: GREENLAND CONTRACTORS

Chief of Environmental Engineering DSN 629-3840 ext. 2698 Supersedes Hazardous Material Management Process Nov 2009

October 2011

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TABLE OF CONTENTS

1 LETTER OF INSTRUCTION

1.1 SECURITY AND ADMINISTRATIVE INSTRUCTIONS

2 GENERAL

2.1 INTRODUCTION

2.2 PURPOSE

2.3 SCOPE

2.4 REGULATORY OVERVIEW

3 ORGANIZATION AND RESPONSIBILITIES

3.1 HMMP TEAM

3.2 HMMP TEAM COMPOSITION

3.3 IHMP OBJECTIVES

4 HAZARDOUS MATERIAL CHARACTERISTICS

4.1 DEFINITIONS OF HAZARDOUS MATERIALS (HAZMAT)

4.2 HAZMAT PRODUCTS LISTED FOR SUBSTITUTION IF POSSIBLE

4.3 PRODUCTS NOT CONSIDERED AS HAZMAT

4.4 HAZMAT AUTHORIZATION PROCESS

5 LABELING OF HAZMAT PRODUCTS

6 HAZMAT STORAGE AREAS

6.1 SHOP INVENTORY AND MATERIAL SAFETY DATA SHEETS (MSDS)

6.2 GENERAL HOUSEKEEPING OF HAZMAT STORAGE AREAS

7 ACRONYMS

8 APPENDICES

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1 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

Title: The title of this document is “Installation HAZMAT Management Plan”. The acronym, IHMP, will be used throughout the document.

Classification: The title and the document are unclassified, and do not fall within the scope of directives governing the protection of information affecting National Security and specified in the United States Air Force (USAF) directives, in the Air Force Instruction (AFI) 31-series.

Responsibilities: Greenland Contractors, Environmental Engineering (GC/EE) is the office of primary responsibility for developing and maintaining the IHMP. Organizations are authorized to extract and reproduce those sections of the IHMP that are essential in the accomplishment of necessary planning and in the preparation of supporting document and reports.

References: References referred to in the IHMP 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 IHMP will be reviewed and updated annually. Furthermore, the plan is subject to change if any of the applicable laws, regulations, or requirements is altered.

Distribution: Initial distribution for review purposes:

Todd DeGarmo, Civ USAF AFSPC 21 CES/CEANP

Capt Robert Marcucci, 821 SPTS Civil Engineer Flight CC/QAE

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2 GENERAL

2.1 Introduction

The purpose of the Installation HAZMAT Management Plan (IHMP) is to provide the Air Force installation with a standardized way to handle HAZMAT from cradle to grave. Although the focus is on HAZMAT, the broader purpose is to protect the environment, safety and health of potentially all Thule residents.

According to AFI32-7086 the Installation Hazardous material management process (HMMP) team functions is to provide an oversight for three major areas which are the IHMP, the Weapon system HAZMAT Program (WSHP) and the ODS Program.

This program assigns specific functional area responsibilities for HMMP execution at all levels.

The key to effective HMMP management is cross-functional cooperation to be achieved through the establishment of HMMP teams at all levels.

At Thule AB the HMMP is facilitated by BMC and according to the Statement of Work (SOW) the HMMP team does not manage the WSHP, The ODS Program is set out in CDRL CEV-20 and the IHMP describes the HAZMAT Pharmacy requirements for authorizing, procuring, issuing, and monitoring HAZMAT which is described in this plan.

2.2 Purpose

In accordance with the U.S. Air Force Instruction (AFI) 32-7086, Hazardous Materials Management; this document represents the Installation HAZMAT Management plan (IHMP) for Thule AB, Greenland.

The purpose of the IHMP is to ensure that documented guidance for Hazardous material (HAZMAT) management is available to all installation personnel.

The documentation will include:

• Identification of Shops using HAZMAT

• Identification of HAZMAT storage

• HAZMAT tracking at Thule AB

• Procedures for HAZMAT procurement and authorization

The goal is to achieve a full state of awareness throughout the installation of hazardous material (HAZMAT). The IHMP ensures the purchase of only the smallest quantities of hazardous materials necessary by focusing on eliminating or, reducing the introduction of hazardous material into the installation

Throughout this document the abbreviation BMC is used for Base Maintenance Contract the point of contact for the BMC is GC Environmental Engineering (email: Environmental@gc.gl).

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2.3 Scope

The provisions of the IHMP 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 functions may need to be consulted:

• Pollution Prevention Management Plan, CDRL CEV-15D

• Halon and Refrigerant Management Plans, CDRL CEV-20

• Hazardous Waste Management Plan, CDRL CEV-15B

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

2.4 Regulatory Overview

In accordance with USAF policy, Thule AB is required to comply with the following regulations.

Thule Air Base: Final Governing Standard (FGS) EPC decisions

USAF: AFI32-7086 November 2004 AFI32-7080 May 1994 AFI32-7080 AFSPCSUP August 2006

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3 ORGANIZATION AND RESPONSIBILITIES

In order to ensure that HAZMAT is handled in a correct manner, it is important that the personnel using HAZMAT are fully aware of their responsibilities in the HAZMAT management program

(HMMP).

3.1 HMMP Team

The HMMP team is a represented by BMC personnel and is chaired by GC/EE. The chair will report to the EPC. The team will meet as required, at least quarterly.

3.2 HMMP Team Composition

The HMMP team will include, but is not limited to, representatives from:

GC/EE Representing Environmental Engineering and Bioenvironmental Engineering GC/OHS Occupational health and safety GC/AMF Fire Protection GC/SG Surgeon General GC/LGS Representing Supply, HAZMART and DRMO

Other functional representatives such as finance, requirements, communications, and tenant units may also be members of the HMMP team.

The Objectives of the HMMP is outlined in the new draft CHARTER is added as Appendix 1 of this IHMP.

3.3 IHMP Objectives

The IHMP supports accomplishment of the Ari Force mission by minimizing and effectively managing dependence on HAZMAT within acceptable levels of mission and ESOH risk and reducing associated HAZMAT life cycle costs.

The specific objectives of the IHMP are to:

1. Supports accomplishment of the Ari Force mission by minimizing HAZMAT usage

2. Focus to improve process efficienciet

3. Provide standardized HAZMAT service to costumer

4. Purchase, store and issue HAZMAT in smallest quantities required to support mission

Requirements

5. Ensure HAZMAT issue and use conform to appropriate ESOH requirements

6. Track HAZMAT by shop, facility and where applicable

7. Enter all required HAZMAT data into EESOH-MIS the resent established HAZMAT tracking program at Thule AB

8. Provide HAZMAT data to support Air Force requirements

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4 HAZARDOUS MATERIAL CHARACTERISTICS

A material is considered to be a hazardous material if it exhibits either a health hazard and/or a physical hazard.

4.1 Definitions of Hazardous Materials (HAZMAT)

A commonly accepted definition (OSHA 29CFR 1910.1200) of hazardous materials includes products which are carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agents which act on the hematopoietic system, and agents which damage the lungs, skin, eyes, or mucous membranes.

Physical hazard means a product for which there is scientifically valid evidence that it is a combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, an oxidizer, pyrophoric, unstable (reactive) or water-reactive.

Typical hazardous materials characteristics as they are defined in the Final Governing Standard (FGS) Table C5.T1:

1. The item is a health or physical hazard. Health hazards include carsinogens, corrosive materials, irritants, senzitizers, toxic materials, and materials which damage the skin, eyes, or internal organs. Physical hazards include combustible liquids, compressed gasses, explosives, flammable materials, organic peroxides, oxidizers, pyrophric materials, unstable (reactive) materials, and water-reactive materials.

2. The item/or its disposal is regulated by the host nation because of its hazardous nature.

3. The item contains asbestos, mercury, or polychlorinated biphenyls.

4. The Item has a flashpoint below 93˚C (200˚F) closed cup, or is subject to spontaneous heating or is subject to polymerization with release of large amounts of energy when handled, stored, and shipped without adequate control.

5. The item is a flammable solid or is an oxidizer or is a strong oxidizing or reducing agent with a standard reduction potential of greater than 1.0 volt or less than -1.0 volt.

6. In the course of normal operations, accidents, leaks, or spills, the item may produce dusts, gases, fumes, vapors, mists, or smokes with one or more of the above characteristics.

7. The item has special characteristics, which in the opinion of the manufacturer or the DoD

Components could cause harm to personnel if used or stored improperly.

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4.2 HAZMAT Products listed for substitution if possible

AFI32-7080 by May 1994, implements the EPA’s 17 Industrial Toxics as part of the Pollution Prevention Program. The EPA’s 17 industrial toxics are specifically target for reduction; these are listed in Table 1 below.

Table 1: List of EPA-17 Industrial Toxic Chemicals:

1. Benzene 10. Methyl Ethyl Ketone

2. Cadmium & Cadmium Compounds 11. Methyl Isobuthyl Ketone

3. Carbon Tetrachloride 12. Nickel & Nickel Compounds

4. Chloroform 13. Tetrachloroethylene

5. Chromium & Chromium Compounds 14. Toluene

6. Cyanide & Cyanide Compounds 15. 1,1,1-Trichloroethane

7. Lead & Lead Compounds 16. Trichloroethylene

8. Mercury & Mercury Compounds 17. Xylenes

9. Methylene Chloride

These are compounds covering a wide spectrum of toxics, many of which are volatile organic compounds and are commonly found in fuels, paints and solvents.

However, the EPA’s 17 industrial toxics (table 1) are specifically target for reduction in the AFI32-7080. EPA has changed the list of priority chemicals to different 31 products this list can be found at http://www.epa.gov/osw/hazard/wastemin/priority.htm. This list is also taken into consideration for products of substitution.

Furthermore, the Final Governing Standard (FGS) prohibits all procurement of products containing polychlorinated biphenyls (PBCs).

4.3 Products not considered as HAZMAT

Commonly accepted criteria (OSHA 29CFR1910.1200(b)(6)) for products not considered being HAZMAT is as follows below. These considerations are consistent with the Final Governing Standards (FGS) intent and will be considered valid for Thule AB.

1. Any hazardous waste as such term is defined by the Solid Waste Disposal Act. The specific handling this at Thule AB is outlined in CDRL CEV-15B.

2. Any hazardous substance as such term is defined by the Comprehensive Environmental Response.

3. Tobacco or tobacco products

4. Wood or wood products

5. Articles hereby meant as:

Manufactured item other than a fluid or particle:

- Which is formed to a specific shape or design during manufacture.

- Which has end use function(s) dependent in whole or in part upon its shape or design during end use.

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- Which under normal conditions of use does not release more than very small quantities, e.g., minute or trace amounts of a hazardous chemical, and does not pose a physical hazard or health risk to employees.

6. Food or alcoholic beverages which are sold, used or prepared in a retail establishment and foods intended for personal consumption by employees while in the workplace.

7. Any drug, as that term is defined in the Federal Food, Drug and Cosmetic Act.

8. Cosmetics which are packed for sale in a retail establishment, and cosmetics intended for personal consumption by employees while in the workplace.

9. Any consumer product or hazardous substance, as those terms are defined in the Consumer Product Safety Act and Federal Hazardous Substances Act respectively.

10. Nuisance particles where the chemical manufacturer or importer can establish that they do not pose any physical or health hazard.

11. Ionizing and nonionizing radiation

12. Biological hazards

A List of typical products which are not hazardous according to the criteria above have been prepared as a guideline for users. Products on this list will not be tracked nor does their use require authorization, this list is added as Appendix 2.

4.4 HAZMAT Authorization Process

Any non-BMC HAZMAT requests are reviewed for informational purposes only. GC/EE may provide guidelines and recommendations for substitutions and will track the material in EESOH-

MIS.

It is the responsibility of the requester to provide a Material Safety Data Sheet (MSDS) in English, prepared by the manufacture that fulfils CFR and/or EU requirements when a new product is requested.

The MSDS, AF Form 3952 is forwarded to GC/EE when a new product is requested for purchase. After review from GC/EE and approval of the MSDS by the EESOH-MIS datastewards GC/EE will enter the product in the EESOH-MIS. The user is notified and they can purchase.

The process is shown in figure 1 below.

Furthermore, amounts of procured HAZMAT in pounds (lbs) must be reported to the BMC.

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Figure 1 Flowchart showing the HAZMAT authorization procedure

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The documents, MSDS and AF Form 3952 request, can be sent by email to:

Environmental@gc.gl

A form indicating the information needed to receive a material stock number, MSN number, for EESOH-MIS is attached as Appendix 3. AF Form 3952 is added as Appendix 4. The instruction how to fill out the AF Form 3952 can be found in AFI32-7086.

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5 LABELING OF HAZMAT PRODUCTS

All HAZMAT products shall contain a label. The chemical manufacturer or distributor shall ensure that all hazardous products leaving the workplace are labled, tagged or marked with:

1. Identity of the hazardous product

2. Appropriate hazard warnings

3. Name and address of the chemical manufacturer, importer or other responsible party

In case a products label has become damaged, obscured, illegible or otherwise does not convey the information required or if a product is contained in a non-original container a label will have to be made.

Presently DD Form 2522 is commonly used at Thule AB when a new label is needed. This is filled out as follows:

1. The Name of the product

2. Hazard code if available

3. The MSN-number of the product

4. The individual part number of the product if this is at hand

5. Item name

6. The Hazardous Materials Identification System

(HMIS)

7. Specific hazards can be identified if there is any.

In case the product is labled with The Global Harmonized System (GHS) the classifications can be added to this box

8. PPE can be marked in this box

9. The manufacturer importer or other responsible party identification

10. Procurement year if available

Figure 2 DD Form 2522, Hazardous Chemical warning Label

The Final Governing Standard requires as mentioned above, identity of the hazardous product, appropriate hazard warnings and name and address of the chemical manufacturer, importer or other responsible party. Therefore when using DD Form 2522 it is important to fill out box number 1 - Product identity, box 3 – MSN-number, box 6 or 7 - appropriate hazard warnings, when knowing HMIS warnings fill out box 6 and when knowing GHP warnings use box 7, box 8

– it is very important to consider the kind of PPE needed when using the product hence it is important to relate to box 8 and box 9 a – company name.

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6 HAZMAT STORAGE AREAS

Materials must be stored in a safe and secure area to limit access and prevent inadvertent release.

6.1 Shop Inventory and Material Safety Data sheets (MSDS)

All shops must keep an updated inventory list of the HAZMAT contained in the shop and keep a file containing of Material Safety Data sheets (MSDS) of all their products. These shop inventories shall match the inventory entered to the EESOH-MIS by the BMC Environmental Engineering department.

As part of the IHMP the BMC Environmental Engineering department will update an Installation listing of all HAZMAT storage locations for shops and HAZMART Pharmacy this list is added as Appendix 5.

6.2 General Housekeeping of HAZMAT Storage Areas

All HAZMAT dispensing areas will be properly maintained. Drums/containers must not be leaking. Drip pans will be placed under containers as necessary to collect drips or spills.

Container contents will be clearly marked and dispensing areas will be located away from catch basins and storm drains.

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7 ACRONYMS

AB Air Base

AF Air Force AFI Air Force Instruction BMC Base Maintenance Contract DRMO Defense Reutilization and Marketing office EESOH-MIS Enterprise Environmental, Safety & Occupational Health –

Material Inventory System ESOH Environmental, Safety & Occupational Health EPA U.S. Environmental Protection Agency EPC Environmental Protection Committee FGS Final Governing Standard GC Greenland Contractors GC/EE Greenland Contractors Environmental Engineering HAZMART Hazardous Materials Pharmacy HAZMAT Hazardous Material HMMP Hazardous Material Management process IHMP Installation HAZMAT Management Plan MSDS Material Safety Data Sheet MSN Material Stock Number ODS Ozone Depleting Substances ODSP Ozone Depleting Substances Program POC Point of Contact

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8 APPENDICES

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APPENDIX 1: DRAFT CHARTER

CHARTER

Thule Air Base - Hazardous Materials Management Process (HMMP) Team

1. PURPOSE: This charter establishes the Thule AFB Hazardous Materials Management Process (HMMP) Team (hereinafter the “Team”).

2. MISSION: The mission of the Team is to implement the HMMP in accordance with paragraph 1.2.1 of the Air Force Instruction (AFI) 32-7086, Hazardous Materials Management.

3. OBJECTIVES: The Team will focus on trustful, cooperative, information-sharing as well as open discussion and deliberation on HMMP. The objectives of the Team are to:

• protect the safety and health of Air Force personnel, non-BMC, BMC and surrounding community

• protect and preserve natural resources and the environment

• support the accomplishment of the Air Force mission by minimizing dependence on hazardous materials (HAZMAT)

• collect and maintain HAZMAT data on standardized automated data processing equipment, EESOH-MIS

• manage mission critical requirements for Class I and II Ozone Depleting Substances

(ODS)

• coordinate all regulatory reporting requirements are being accomplished

• Manage the installation process for distributing, tracking and proper storing of hazardous materials at TAB

4. FUNCTION: The HMMP Team will provide oversight for two of the major areas covered in the AFI 32-7086 the Installation HAZMAT Management Program (IHMP) and the Ozone Depleting Substances Program (ODSP). The Team will:

• support in the establishment of supplemental policies and procedures for the HMMP as needed

• ensure HMMP requirements are integrated into host-tenant agreements, Support Agreement Procedures

• ensure HMMP training requirements are established

• utilize cross feed among the functional areas and other installations to accomplish the HMMP objectives

5. MEETINGS: The Team will meet quarterly. Additional meeting dates will be determined by consensus of the Team. Meeting agendas and minutes will be coordinated through the chair.

Tenant Units, USAF and BMC shops are invited to the meetings when it is estimated nessesary.

6. DECISION-MAKING: Each member of the Team has the authority to speak and act for the organization they represent. Decisions by the Team will be by consensus. Decision-making will be shared in which all parties can either agree or disagree to actively support a decision binding the whole Team. Consensus will be reached when: each Team member has articulated their point of view and it has been considered by the Team, each Team member has fully considered everyone else's point of view; and, each Team member can accept the final decision and will support it (does not necessarily mean the Team member agrees with the decision).

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7. COMPOSITION: The HMMP Team will be comprised of individuals representing

GC/EE

GC/OHS

GC/LGS

GC/AMF

Air Force functional areas

Other functional areas invited for HMMP includes tenant units, USAF shops, BMC shops, contractors and any other entity as required.

Each member will designate alternates with full power and authority to represent them in their absence. GC/EE will chair the HMMP team.

8. The effective date of this charter shall be the signature date of the EPC Chair.

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APPENDIX 2: EXEMPTION LIST

In order to facilitate the use of common products without unnecessary bureaucracy Thule AB has an exemption list from the requirements set forth in the Hazardous Material Management Process. Products on the list can be used safely without training.

HAZMAT EXEMPTION LIST

The following products are exempted from being tracked in EESOH-MIS and being listed on inventory lists and in MSDS binders. Proper disposal requirements are not exempted.

Office supplies including

• Screen cleaners

• Correction ink

• Printer ink cartridges

• Glue sticks

• Markers and Pens

• Antistatic agents

Ordinary soap including

• Hand soap, including liquid soaps and shampoo.

• Ordinary dishwashing detergent (i.e. not detergent for industrial machine washing)

• Cleaning agents (non-industrial)

Miscellaneous products including

• Small, dry batteries (for flashlights, watches, hand tools etc.)

• Bug Repellants

• Perfume, including air fresheners

• Hand sanitizers

• Disinfection swipes (paper towels with disinfection agent)

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APPENDIX 3: INFORMATION NEEDED TO RECEIVE A MATERIAL STOCK NUMBER, MSN

NUMBER, FOR EESOH-MIS

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APPENDIX 4: AF FORM 3952 IS ADDED AS AN EXAMPLE

This AF form is to can be found at http://www.e-publishing.af.mil/shared/media/epubs/AF3952.xfdl, the instruction on how to fill out this form is given in AFI32-7086.

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APPENDIX 5: INSTALLATION LISTING OF ALL HAZMAT STORAGE LOCATIONS FOR

SHOPS AND HAZMART PHARMACY

EESOH-MIS SHOP NAME RESPONSIBLE

ORGANISATION

EESOH-MIS

SHOP CODE

HAZMAT STORAGE

BUILDING

HAZMART Pharmacy GC Supply

GC/EE HAZ99 #935, #933, #555, HG2, HG9

GC, QES Laboratory GC/EE TH0501 HG4 GC, Medical Clinic GC/EE TH0601 #118 Dentist GC/EE TH0602 #118 GC Operations, Transportation, Ramp Services

GC/EE TH0901 HG4, HG7, HG8, HG9

GC Operations, Transportation, Pavement and Grounds

GC/EE TH0902 HG3, #836, #580

GC Operations, Transportation, Transportation Services

GC/EE TH0903 HG3

GC Operations, Transportation, AGE

GC/EE TH0904 #1408

GC Operations, Enterprise, Painting

GC/EE TH1101 #801

GC Operations, Enterprise, Fixed Price Projects

GC/EE TH1102 #801

GC Operations, UFM, Heating

GC/EE TH1201 #1401,#935, #341, #241

GC Operations, UFM, Power

GC/EE TH1203 #1391, #4016

GC Operations, UFM, Bowling Pinsetter

GC/EE TH1204 #608

GC Operations, UFM, Fuels

GC/EE TH1205 #1307, #616, #614

GC Operations, UFM, Polynea

GC/EE TH1206 #999, #993

GC Operations, UFM, Flightline

GC/EE TH1207 #1105

GC Operations, UFM, UFM

GC/EE TH1208 #551, #200

GC Operations, UFM, BMEWS

GC/EE TH1209 #4002

GC Operations, UFM, DET-1

GC/EE TH1210 #1825

GC Operations, UFM, Water Treatment

GC/EE TH1211 #1411, #1411, #608

GC Operations, UFM, Refrigiration

GC/EE TH1212 #551

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GC Operations, Fire Mainbase

GC/EE TH1301 #628, #619

GC Operations, Fire BMEWS

GC/EE TH1302 #4002

GC Operations, Non Secure Communications

GC/EE TH1401 #1950, #1411

GC Operations, ATCALS

GC/EE TH1402 #1950, #1411

GC Operations, Vehiecle Maintenance, Maintenance

GC/EE TH1601 #580

GC Operations, Vehicle Maintenance, Refuling

GC/EE TH1602 #562

GC Operations, Vehicle Maintenance, Paint Shop

GC/EE TH1603 #580

GC Operations, Vehicle Maintenance, Boat Team

GC/EE TH1604 #580

GC Services, Activities, Fitness

GC/EE TH1901 #608

GC Services, Activities, Community Center

GC/EE TH1902 #362

GC Services, Housing

GC/EE TH2101 #608, #237, #107,

Basewide depots

GC Services, Food Services

GC/EE TH2201 #4002, #1824, #107

GC Services, Supply

GC/EE TH2401 #935

GC Construction GC/EE TH3001 #2405 GC Adminiatration GC/EE TH3201 #274, #564, #619 BAE-Systems, PMEL

Thule BAE

TH9001 #561

BAE-Systems, BMEWS

TH 9002 #4002

BAE-Systems, LAN

TH9003 #112

Air Greenland Air Greenland TH9004 HG4 Harris Harris TH9005 #1824

821 SFS 821 SFS TH9006 #363

NRG NRG TH9007 #1391

Canadian Air Force Canadian Air Force TH9008 HG7

AAFES,

BX

AAFES TH9009 #1410, #251

12 SWS 12 SWS TH9010 #4002

AAFES,

TOW-Club

AAFES TH9011 #236

NSF NSF TH9012 #2503, #628, #353, Camp Tuto Base Camp

Shaw Engineering Shaw Engineering TH9013 Private Organisations Gocart Club, Skeet Club, RC car Club

TH9014 - Gocart Club by the SAC- Ramp

- Skeet Club by the beach

- RC car Club by abandoned Runway near HG2

MTH MTH TH9015 #2405

GC Boat Guild GC/EE TH9016 Installation TAB GE Americom GE Americom TH9017 #4002

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