Appendix_F_-_PPM_Plan.pdf

CDRL CEV-15D

POLLUTION PREVENTION MANAGEMENT PLAN

Thule Air Base, Greenland

Final, FY-15

OPR: GREENLAND CONTRACTORS

Chief of Environmental Engineering DSN 629-3840 ext. 2698 Supersedes CDRL CEV-15D, FY-14

CDRL CEV-15D Pollution Prevention Management Plan

Thule Air Base 3 FY-15

TABLE OF CONTENTS

1.0 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

2.0 THULE AB P2MAP METHODOLOGY AND ORGANIZATION

2.1 Introduction

2.2 Opportunity Assessment

2.3 Results of Opportunity Assessment

3.0 POLLUTION PREVENTION MANAGEMENT PLANS

3.1 Hazardous Process Authorization

3.2 Hazardous Waste

3.3 Municipal Solid Waste

3.4 (Green) Affirmative Procurement of Environmentally Friendly Products

3.5 Energy Conservation

4.0 AIR AND WATER POLLUTANT REDUCTION

4.1 Air Pollutant Reduction

4.2 Water Pollutant Reduction

4.2.1 Secondary Containment

4.2.2 Wastewater Treatment

APPENDIX 1 DISTRIBUTION LIST

APPENDIX 2: 2014 REVIEW COMMENTS

Thule Air Base 4 FY-15

1.0 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

Title: The title of this document is “Pollution Prevention Management Plan”. The acronym P2P will be used throughout the document.

Classification: The document is unclassified.

Responsibilities: Greenland Contractors, Environmental Engineering (GC/EE) is the office of primary responsibility for developing and maintaining the P2P. The instruction given in this plan is applicable to all organizations and tenant units at Thule AB. Organizations are authorized to extract and reproduce those sections of the P2P that are essential in the accomplishment of necessary planning and in the preparation of supporting document and reports.

Reviews/Changes: The P2P will be reviewed and updated annually IAW the CDRL and distributed accordingly. A draft is submitted to the requiring office, 21 CES/CEIE, by 1 Nov for review. Review comments, if any, will be provided by 21 CES/CEIE 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 P2P will be distributed to the organizations listed in the distribution list, APPENDIX 3.

Thule Air Base 5 FY-15

2.0 THULE AB P2MAP METHODOLOGY AND ORGANIZATION

2.1 Introduction

Pollution prevention is a risk reduction strategy for environmental aspects that generate pollution.

An aspect is a process or set of process that generate an impact, e.g. handling of diesel or solid waste generation. The preference is to eliminate risk if possible, or reduce or otherwise manage the risk if it cannot be eliminated.

In descending order of preference, the selection of objectives shall use the P2 hierarchy summarized below.

1. Elimination of an aspect’s impacts through a change in policy or procedures; the reengineering of a system, facility, activity, or process; or the implementation of an environmentally benign substitute material.

2. Reduction in the significance of an aspect’s impacts through a change in policy or procedures; the reengineering of a system, facility, activity, or process; or the implementation of an environmentally benign substitute material.

3. Reduction in the significance of an aspect’s impacts through on-site recycling and reuse.

4. Reduction in the significance of an aspect’s impacts through return to off-site recycling and/or off-site reuse

5. Reduction in the significance of an aspect’s impacts through the implementation of operational controls.

6. No reduction in significance; the aspect continues to generate impacts, unmitigated; targets and objectives are associated with the aspect are focused on mere compliance.

When an aspect has been selected for pollution prevention the process of setting up objectives and management plans (MAP) is called an Opportunity Assessment (OA).

2.2 Opportunity Assessment

The method used to identify P2 process improvements or options is referred to as an Opportunity Assessment (OA). This effort assesses all pollutant sources, examines material usage and waste generation by type and volume, and determines the most practical and economical options for reduction. This generally involves examining each process involving a targeted pollutant to determine ways to avoid use or generation of that substance. The OA includes a review of existing installation plans such as the Hazardous Waste Management Plan and Solid Waste Management Plan which identify waste streams. Additional detailed baseline information characterizing material use and waste streams for each process may be gathered concurrently with the assessment process.

Trained installation personnel, contractors, and/or Major Command (MAJCOM) teams may perform OA. The OA team members at Thule Air Base are representing Environmental Engineering, Occupational Safety and Health, Supply, and Engineering. The OA team members will be selected from some of the following listed subjects:

Thule Air Base 6 FY-15

1. Involve people who work directly with the processes and materials of concern. They are most familiar with practices and probably know where changes can be made.

2. Involve members from other organizational elements that may be affected by changes in procedures or practices. Contact your customers - involve other shops and offices.

3. Include people with a wide variety of backgrounds to gain different perspectives and approaches to problem identification and problem solving.

4. Involve suppliers or potential suppliers, if possible. Seek their advice - they are generally looking for new customers or expanded sales and can offer sound advice.

2.3 Results of Opportunity Assessment

Solid Waste

Implement Recycling Program

Recycling of solid waste streams would reduce the amount of solid waste going to the landfill.

The recycling program at Thule was descoped from the BMC with DCR 06-086 in 2006. In 2008 TetraTech prepared a QRP (Qualified Recycling Program) Initial Assessment Report. A final QRP Business Plan for Thule Air Base was prepared by TetraTech in 2011.

An ongoing QRP funded cable survey will provide the basis for recycling the metal in the extensive abandoned cable routes within the defense area.

Waste Incineration

Waste incineration could reduce the amount of solid waste going to the landfill.

The construction of a solid waste disposal facility has been identified as MILCON project WWCX 06-3001. The project is priority 10 among MILCON projects for Thule AB. A Waste to Energy (WTE) study was completed by TetraTech in 2011. The report contains attractive Returns-of- Investment but the assumptions have been questioned by 21 CES.

A QRP proposal to install a small scale burner for food waste at the base dining hall facility has been suggested as a realistic alternative.

A QRP proposal to shred car tires and use for landfill cover has been suggested.

Base initiatives

In 2011, a scrap steel pile containing approximately 8000 tons of scrap metal was collected for recycling, earning $550,000 for the QRP of Peterson AFB. Since then bulk metal from demolitions continues to be collected for the purpose of recycling. The current scrap metal storage site has been relocated and is now in a fenced area (the so-called DLA yard) and are recycled as part of the QRP of Peterson AFB

Thule Air Base 7 FY-15

GC collects car tires and cable scrap (copper) for recycling. Lead-Acid batteries are collected and shipped for recycling. Electronic waste is collected and disposed of through DLA Disposition Services – useable items such as functional TV-sets and computers are reused at federal prisons.

In 2013 glycol recovery was implemented through the procurement of a vacuum distillation unit.

Waste Water

Waste Water Treatment

A Waste Water treatment plant would reduce the amount of pollutants Thule AB dispose into the Host Nation waters.

The construction of a waste water treatment plant has been identified as MILCON Project WWCX 10-3003. The project is scheduled for FY16+.

A feasibility study was finalized in 2011 by ISC. The final report from this study concludes that a solution to treat wastewater costing a maximum of $750,000 will not be able to treat the volume of wastewater at TAB to the requirements set forth in the FGS. The MILCON project is therefore the only way to advocate for funding for a wastewater treatment facility due to the size of the investment. The chances of funding this plant are remote.

Repair Sewage Lines, Main Base

In 2010 and 2011 Thule has experienced a number of reportable wastewater spills. The original sewage system is very old and there is a constant risk of leakages. WWCX 11-1128 is a three-phased SRM project scheduled from FY14 through FY16 targeted at these old lines. The first phase has been funded and completed in 2014. The next two phases remain unfunded at this time.

Base Initiatives

Minimize the risk of further incidents by extraordinary flushings to keep the system from clogging

up. These flushings are accomplished by pumping water through a maintenance hatch. They do not follow a specific schedule but are requested by utility maintenance staff when they suspect a build-up is in progress.

Air Emissions

Reduce CO2 emissions

A large number of energy conservation projects will all contribute to a reduction in CO2 emissions from Thule AB. The main MILCON projects are WWCX 09-1011 Replace M-Plant Cooling Water System and WWCX 04-3004 Power Plant Upgrade, M-Plant.

Base Initiatives

A comprehensive energy conservation strategy has been implemented using base consolidation and implementation of new technologies. The Energy Conservation Task Group (ECTG) meets twice annually to adjust and improve the strategy, in particular to adjust to lower funding levels.

Thule Air Base 8 FY-15

Hazardous Waste

Thule does not generate a lot of hazardous waste. Most of the waste disposed through DLA Disposition Services is non-hazardous waste that Thule does not have the capacity to dispose of to the Thule landfill.

Source reduction through substitution

Substitution efforts are an integral part of base operations to perform source reduction on hazardous waste. Examples in recent years include the introduction of more water based paints, and the elimination of chlorinated solvents.

Base initiatives

The amount of universal hazardous waste has been reduced with the procurement of a fluorescent light bulb crusher in 2010. The bulbs are crushed and the mercury captured in a series of filters.

This allows the glass and metal parts of the bulbs to be disposed of as solid waste.

An arrangement with DLA Disposition Services in Norfolk and the Thule BMC exists for used car batteries and other excess materials. The batteries are being recycled in the United States. Thule would not otherwise have any option except to dispose of the batteries as hazardous waste.

Storm Water

Cleanup historical fuel spills

Historical fuel spills are a source of pollution in the form of fuel sheens and fuel seeping into the host nation waters through the storm water system.

Base initiatives

An effort to risk-based targeted cleanup projects of residual contamination of historical fuel spills and other areas of concern IAW DoDI 4715.8 Environmental Remediation for DoD Activities Over-seas has been partially completed. WWCX 10-1110 Preliminary Assessment/Site Investigation identified six locations for additional characterization. These investigations have been funded as WWCX 10-1012 Site Characterization/Health Determination. The project will determine if remedia-tion is required.

Interim solutions have been established in the form of adsorbent booms, earth dikes, trenches etc.

to minimize the pollution to the host nation waters. 21 CES/CEIE has worked to identify and receive funding for pollution containment and hot spot cleanup at the M-plant – the site where fuel seeping has caused the most problems. These projects were completed in 2011.

The process used at Thule is not true landfarming; no microbes, enxymes or nutrients are added.

The soil gets screened and aerated during the summer. In 2012 a report was prepared on the envi-ronmental effects of “landfarming” at Thule AB. They were shown to be very limited. Projects to deal with remaining stockpiles of abandoned soil have been identified.

The construction of a weathering pit for oil water separator waste has been proposed for a QRP funded alternative to the existing dirt dike which does contribute to storm water pollution (project

WWCX 15-1006).

Thule Air Base 9 FY-15

3.0 POLLUTION PREVENTION MANAGEMENT PLANS

3.1 Hazardous Process Authorization

When a hazardous material is required in a BMC shop, an authorization process must be initiated, if the material is not previously authorized or if the shop exceeds the authorization limit. If a shop is authorized to use a product for a specific process and the authorization limit is not exceeded, the shop is not required to consult the Environmental Engineering function (GC/EE) for approval and authorization.

Detailed information about the EESOH-MIS system can be obtained via guides published on the EESOH-MIS support portal at https://www.eesoh-mis.com/

Product Evaluation

The product will be evaluated within the following areas as a minimum.

Material information

Process information to include information such as:

- Amount of material required/requested and amount used per task

- Duration and frequency of task

- Personnel Protective Equipment

- Generation of waste

Substitution Efforts

If a product causes unnecessary exposures to employees, a substitution effort will be initiated in cooperation between the shop requesting the hazardous material and the OSH function.

If a product is creating unnecessary hazardous waste or other wastes, which cannot be drained to the sanitary sewer or disposed at the sanitary landfill, a substitution effort will be initiated in cooperation between the shop requesting the hazardous material and Environmental Engineering.

Assessments within the following areas are initiated

Occupational safety and health issues

Technical processes

Environmental regulations

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 the current standardized Air Force HAZMAT tracking database, EESOH-MIS (Enterprise Environmental, Safety, and Occupational Health Management Information System).

When a new product is requested, it is the responsibility of the requester to provide a Material Safety Data Sheet (MSDS) or Safety Data Sheet (SDS) in English, prepared by the manufacturer that fulfills current U.S. and/or European Union legal requirements.

Thule Air Base 10 FY-15

The MSDS and AF Form 3952 will be 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 data stewards GC/EE will enter the product in the EESOH-MIS. The user is notified by receiving a material stock number (MSN) and he/she can proceed with the purchase. Furthermore, amounts of procured HAZMAT in pounds (lbs) must be reported to the BMC (GC/EE)

HAZMAT requests and consumption information can be submitted by email to:

Environmental@gc.gl

EPA has listed 31 substances as priority chemicals in the National Waste Minimization Program.

This program is used for guidance by GC/EE when reviewing HAZMAT requests and considering candidates for substitution to products with a lesser environmental impact at Thule AB. The 31 chemicals are listed below

1. 1,2,4-Trichlorobenzene 17. Hexachloroethane

2. 1,2,4,5-Tetrachlorobenzene 18. Methoxychlor

3. 2,4,5-Trichlorophenol 19. Naphthalene

4. 4-Bromophenyl phenyl ether 20. Pendimethalin

5. Acenaphthene 21. Pentachlorobenzene

6. Acenaphthylene 22. Pentachloronitrobenzene

7. Anthracene 23. Pentachlorophenol

8. Benzo(g,h,i)perylene 24. Phenanthrene

9. Dibenzofuran 25. Polycyclic Aromatic Hydrocarbons

10. Dioxins and Furans 26. Polychlorinated biphenyls

11. Endosulfan, alpha & Endosulfan, beta 27. Pyrene

12. Fluorene 28. Trifluralin

13. Heptachlor & Heptachlor Epoxide 29. Cadmium

14. Hexachlorobenzene 30. Lead

15. Hexachlorobutadiene 31. Mercury

16. Hexachlorocyclohexane

Furthermore, the Final Governing Standard (FGS) prohibits all procurement of products containing polychlorinated biphenyls (PBCs). The PCB replacement plan (CDRL CEV-12) describes base procedures used to substitute PCB articles when found.

In addition to the list above substituting is part of the review process, mostly inspired by Danish (European) OHSA standards (to include substituting epoxy, isocyanates and other chemicals affecting occupational health where possible). For example, the chemical hydrofluoric acid is present in many fluxing agents and these are being substituted by the BMC

3.2 Hazardous Waste

TAB generates limited quantities of hazardous waste (HW) as a result of maintenance and cleaning operations. TAB is responsible for categorizing HW generated, ensuring that HW is managed and stored in accordance with state and federal regulations, and all disposal shipments are in accordance with state and federal regulations. DLA Disposition Services is responsible for ensuring that the off-site treatment, storage, and disposal (TSD) facilities to which TAB may ship wastes are operated in compliance with RCRA.

Thule Air Base 11 FY-15

HW such as lead acid and gel-cell batteries, spent fluorescent tubes, PCB containing electrical equipment and spent solvent are managed IAW the Hazardous Waste Management Program (CDRL CEV-15B) and reported in the Hazardous Waste Report (CDRL CEV-14).

The following treatments can be applied to reduce the amount of hazardous waste

3.2.1 Treatment Technologies

The treatment technologies listed below are provided as baseline treatment/disposal technologies for the use of determining suitability of host nation disposal alternatives. These technologies should not be implemented without consultation with the Environmental Executive Agent, or the Combatant Commander, if there is no Environmental Executive Agent. All hazardous waste generated on Thule AB is currently being disposed of via DLA Disposition Services.

Fuel substitution (Organics) Units are operated so that destruction of hazardous constituents are at least as efficient, and hazardous emissions are no greater than those produced by incineration.

Biodegradation of Organics Wastes are degraded by microbial action. Such units will be operated under aerobic or anaerobic conditions so that the concentrations of a representative compound or indicator parameter (e.g., total organic carbon) have been substantially reduced in concentration. The level to which biodegradation must occur and the process time vary depending on the hazardous waste being biodegraded.

Recovery of Organics Wastes are treated to recover organic compounds. This will be done using, but not limited to, one or more of the following technologies: distillation; thin film evaporation; steam stripping; carbon adsorption; critical fluid extraction; liquid extraction; precipitation/crystallization or phase separation techniques such as decantation, filtration and centrifugation when used in conjunction with one of the above techniques.

Chemical Degradation of Organics The wastes are chemically degraded in such a manner that hazardous constituents are destroyed and harmful emissions controlled.

Stabilization or Fixation of Heavy Metals Wastes are treated in such a way that soluble heavy metals are fixed by oxidation/reduction, or by some other means which renders the metals immobile in a landfill environment.

Recovery of Heavy Metals Wastes are treated to recover the metal fraction by thermal processing, precipitation, exchange, carbon absorption, or other techniques that yield non-hazardous levels of heavy metals in the residuals.

Reactives Any treatment that changes the chemical or physical composition of a material such that it no longer exhibits the characteristic for reactivity defined in FGS Chapter 20 (Appendix 1).

Corrosives Corrosive wastes, as defined in FGS Chapter 20, will be neutralized to a pH value between 6.0 and

9.0. Other acceptable treatments include recovery, incineration, chemical or electrolytic oxidation, chemical reduction, or stabilization.

Thule Air Base 12 FY-15

3.3 Municipal Solid Waste

Municipal Solid Waste is the largest fraction of waste generated at TAB. Thule AB has 12 ea 8 m3 dumpsters and 82 ea 6 m3 dumpsters. Dumpsters are emptied weekly or when necessary and transported to the landfill.

Recycling efforts have decreased the amount of solid waste refuse generated. Materials that are recycled at TAB include toner cartridges from printers and copiers, used oil, cable scrap, tires, glycol and vehicle batteries.

Materials used for operation and maintenance of the site are continually inventoried to ensure their complete use. Expiration dates, properly sealing containers, and using open containers completely before opening a new one are key issues. Monitoring of this area reduces the amount of solid waste generated and prevents the potential disposal of a hazardous waste in the municipal solid waste stream.

All unserviceable vehicle batteries will be turned in through the GC Supply at Thule Air Base.

Shipping boxes will be custom made in sizes that will hold no more than 2 layers of batteries in height and will be lined inside with heavy gage plastic. The vehicle batteries are recycled by DLA Disposition Services after shipment from Thule.

3.4 (Green) Affirmative Procurement of Environmentally Friendly Products

Air Force installations are required to implement affirmative procurement programs for materials with recycled content according to Resource Conservation and Recovery Act, Subtitle F (Section 6002) and E.O. 13423, Strengthening Federal Environmental, Energy, and Transportation.

An affirmative procurement program is implemented for US purchases IAW the Thule AB BMC supply regulations. Purchase of Environmental Protection Agency (EPA) designated items through US sources complies with the Thule AB Affirmative Procurement Plan (CDRL CEV-15H).

Exceptions are justified and documented. This requirement does not apply to non-appropriated funds purchases that, if any, will be separately identified.

3.5 Energy Conservation

Energy conservation continues to be a focus area for TAB. In order to reduce consumption and associated pollution/air emissions substantially one has to look at the main power and heat producing plant at Thule AB, the M-Plant (building 1391). M-Plant produces 98% of the power at Thule Air Base.

M-Plant is currently not highly energy efficient as seen on the pie charts below.

Energy Goal:

Energy Goal for Thule is continue to reduce energy intensity by 1.5% each year until FY20.

This will result in a 37,5% reduction from FY03-Baseline.

Energy numbers:

Thule's Total Power & Heat Consumption for FY-03 was 7,158,454 Gl JP-8 Thule's Total Power & Heat Consumption for FY-13 was 5,629,824 Gl JP-8

Thule Air Base 13 FY-15

M-Plant performance:

High Efficiency Plant Potential (Comparison)

Thule is continuing to reduce facility energy consumption as the base is being consolidated and modernized, Smaller scale examples include: Climate shell insulation on existing as well as new facilities 8E.g new BX, new Dorm 101 and 102), turning heat of obsolete facilities, installation of LED lights, Installation of EMCS (energy monitoring and control system). On space utilization side, newer smaller facilities substitute larger older heated facilities. E.g. New VM replaces existing bldg.

#580 and #561. Constructing training functions and city council facility in bldg. #201, made old city council facility obsolete (#445) and #346 ready for close down or other usage.

However, the larger energy conservation potentials is to replace production equipment at M-Plant and convert the surplus heat production from steam to hot water and reconfigure the distribution net accordingly. These are also the initiatives requiring the largest investments and organizational coordination.

Thule Air Base 14 FY-15

It should be observed Thule is - due to its harsh artic climate - not in a suitable position to produce any noteworthy renewable energy and is not able to meet Federal leadership intentions on this matter in a feasible way. Therefore Thule needs to focus even more on reducing its energy consumption. In this regard it is worth to note, that due to the fact that Thule is located in cold climate, passive initiatives (climate shell insulation) is particular beneficial compared to similar investments in moderate climate areas.

When existing production has been optimized a next step could be to consider establishing a Waste-to-energy facility. It is important that a waste-to-energy plant fits within the overall supply strategy for the base.

Thule has an energy task group, report actual energy consumption, inspire and propose strategies and project ideas for leadership to interest and bring enough focus for project funding. GC/CE briefs and provides input to this group.

Following list shows relevant focus areas.

Activity Remarks

M-Plant Production Efficiency Improvement & Repair. WWCX05-3001

Co-Related to Repair Heat Distribution, Main Base. MILCON

Repair/Convert Heat Distribution, Main Base.

WWCX11-1130 + 11-1131

Principle is to change from steam based to hot water based sys-tem. Smaller partly distribution net conversions projects ongoing.

UEWR Consolidation. WWCX03-3001 Relocate/Close poorly insulated Bldg 4012, 4016. MILCON

Consolidate & Optimize Heat Production (D-Plant) Key words: Close K-Plant. Hot water boilers, waste oil burner. Im-plement partly district heat. Close E-Plant

Space optimization/Facility Close Down Close down 346(7,500GL)? 571? 700 area? More 300-area?

Substat.454?

EMCS /AEMR - Implementation Energy meters & Increase Temp control/surveillance

Helps identify/understand energy streams. Reduce heat in hang-ars & storage / weekends & nights. Etc.

Replace old HVAC Aggregaters E.g. 12 SWS, Dining Hall, HG#7 and HG#8

Improve Climate Shell Industrial Facilities E.g. 605.606,628, 801,935, 1408,1408,1409

Solid Waste Disposal Facility WWCX06-3001 MILCON- ECIP

3.5.1 Electricity

In FY14 Thule Air Base consumed 50.5 GWh of electrical power. (In FY03 54.7 GWh was produced/consumed at TAB). More than 60% of this power is consumed directly on the two mission related facility complexes, 12 SWS & DET-1. It is therefore challenging to obtain noteworthy electrical power consumption reductions outside the missions. However, there are three large specific consumers: Heat tracing for water & sewage pipes, electrical hotplugs for vehicles and electrically heated facilities. This is where future focus on reduction in power demand is recommended invested.

In the past decade reduction in electricity has amongst others been obtained by:

The top 15 large light installations have been replaced with more energy efficient solutions.

Examples include facility 12 SWS, Hangar 3,4,5,6,7,8.

Weather dependent reduction in the "on-period" hotplug, average reduc. 2-3 weeks.

Close down of electrically heated facility #517 and #837, due to consolidation effects.

Additional electrically heated facilities are programmed to come: e.g. #1103 and#974.

Energy efficient appliances have become standard issue on base. This is being implemented as equipment is replaced.

LED technology has been introduced and is under implementation, e.g. street lights.

Frequency converters are becoming more common on pumps and HVAC aggregate.

Thule Air Base 15 FY-15

A pilot project with a small solar panel unit was installed by BMC in summer of FY14.

Besides direct savings, long term energy savings benefits from many smaller energy reductions will reflect in:

Smaller/less production equipment. (Also less investment costs).

Smaller or fewer refueling operations.

Less service personnel Less dorms less transportation Less energy.

Thule Air Base 16 FY-15

4.0 AIR AND WATER POLLUTANT REDUCTION

4.1 Air Pollutant Reduction

The emission-generating activities at Thule AB can be categorized as stationary and mobile sources.

Stationary sources can emit fugitive and/or stack emissions. Fugitive emissions are those that do not pass through a stack, vent, or other functionally equivalent opening. An example is VOC loss from fuel storage tanks; the tank loses VOC through tank vents and fugitive losses occur during refueling activities. Stack emissions include units such as combustion sources (e.g., boilers and generators). This inventory also includes the use of ozone depleting substances (ODS).

The combustion sources at Thule AB consist of diesel emergency generators, portable diesel generators, diesel fire pumps, natural gas boilers, water heaters, and furnaces. All diesel combustion units at Thule AB use JP-8 for fuel. In addition, there is a fire fighting training area, a dry cleaning facility and a rock crusher. Thule AB has aboveground storage tanks (AST) for gasoline, JP-8 and used oil.

4.2 Water Pollutant Reduction

4.2.1 Secondary Containment

In accordance with FGS all organizational tanks containing over 50,000 gallons must be provided with a secondary containment area.

Bulk storage tanks and hydrant tanks at TAB are provided with dikes supported by a two-layer membrane and liner. The dikes were established during the period from 2000 to 2004. There is no water run off from the dikes.

Bulk storage tanks at BMEWS are provided with a secondary containment, similar to double walled tanks. Water is removed from a drain valve.

Other organizational tanks are surrounded by a dirt dike.

All new tanks are double walled.

Removal of dike water is carried out by CE Operations and Maintenance.

Records must be kept that indicate all water removed from containment dikes was visually inspected for the presence of contamination, typically a sheen of fuel. CEE will conduct all visual inspections and maintain the records.

Water with sheen must be vacuumed out and discharged into an oil/water separator. At the Bulk Storage Tanks (BST) on the North Tank Farm, “oil only” absorbent beam must be used around the pump wells.

If there is no visible oil film on the surface of the dike water, it is permitted to dispose of the dike water into the nearby creek, without passing it through an oil/water separator. The Tank Farm personnel must obtain approval for this procedure by CEE.

4.2.2 Wastewater Treatment

There is no wastewater treatment at TAB. To eliminate hazardous waste in the wastewater, oil and water separators are installed in the maintenance shops and hazardous material generated is collected at the Hazardous Waste Accumulation Points.

Thule Air Base 17 FY-15

For further treatment of the wastewater, a wastewater plant is suggested and four alternatives will be able to meet the effluent demands of the Final Governing Standards.

The wastewater treatment plant is designed for a population equivalent of 1.600 PE at 10°C. The load was estimated on the background of the samples taken for characterization of the wastewater in September 2004 and of the production of drinking water.

The recommended activated sludge plant is designed for stabilized sludge, so the total sludge age in the treatment plant is greater than necessary for meeting the effluent requirements for BOD removal. In fact the plant will be able to remove part of the nitrogen as well, which makes the size of the plant more than sufficient. Therefore it is not a question of whether the plant can meet the effluent requirements during variation in load but of whether the produced activated sludge from the plant is stabilized properly.

For the design of the wastewater treatment in the detailed project phase, it is important to define the maximum load to the treatment plant by measuring the daily flow and the hourly peak flow of wastewater during high season at Bldg. #984. It is also important to register the variation of the temperature of the wastewater, especially during the winter, to decide the minimum and maximum temperature of the wastewater.

Removal/Precipitation of Metals

The metals in the wastewater will to an extent be precipitated/bonded to the sludge and it is therefore expected that the metal content will drop and thereby comply with the FGS on the discharge on metal containing wastewater to surface waters.

Sludge

Prior to deposit at the landfill, the sludge must be stabilized according to the FGS to ensure that odors or other nuisances do not occur. For this reason, the stabilization process is included in the wastewater treatment proposals.

It is assumed that the amount of sludge/compost produced annually does not exceed 5000 tons as mentioned, among others, in section C7.3.16 in the FGS.

The classification of the sludge as Class A or B compost with respect to the use for agricultural applications is considered to be irrelevant. If, however, the compost can be classified as Class A compost there is no restrictions on the use.

Thule Air Base 18 FY-15

APPENDIX 1 DISTRIBUTION LIST

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

21 Space Wing Civil Engineering Squadron

21 CES/CEIE

21 SW/PMD

donald.chase@us.af.mil

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

821 Air Base Group 821 ABG/CC Commander

821SPTS.cc.wf@peterson.af.mil

821 Support Squadron 821 SPTS/CE Flight Commander

821SPTSCEDISTRO@US.AF.MIL

Greenland Contractors, Thule Air Base All GC organizations (on GC LAN) GC Intranet

Thule Air Base 19 FY-15

APPENDIX 2: 2014 REVIEW COMMENTS

GC Reply:

Comment no.1: The following has been added to the description “These flushings are accomplished by pumping water through a maintenance hatch. They do not follow a specific schedule but are re-quested by utility maintenance staff when they suspect a build-up is in progress.”

Comment no.2: Suggested text has been inserted.

Comment no.3: Due to contractual requirements of the Base Maintenance Contract, CDRL CEV- 15H is still titled ‘Affirmative Procurement Plan’. No changes have been made.