Appendix_D_-_HWM_Plan.pdf

Contract No. FA2523-15-C-0002 1 Dec 2015

A068 HAZARDOUS WASTE MANAGEMENT PLAN

Thule Air Base, Greenland

FINAL

GREENLAND CONTRACTORS

Environmental Engineering

Supersedes CDRL CEV-15B, FY-15

A068 Hazardous Waste Management Plan

Thule Air Base, Greenland 3 1 Dec 2015

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 HAZARDOUS WASTE CHARACTERISTICS

3.1 Characterization of Waste

3.1.1 Ignitable Waste (D001)

3.1.2 Corrosive Waste (D002)

3.1.3 Reactive Waste (D003)

3.1.4 Toxicity Characteristic Waste (D004-D43)

3.2 Listed Waste

3.2.1 F-list

3.2.2 K-list

3.2.3 P-list

3.2.4 U-list

3.3 Hazardous Waste Mixtures

3.4 Hazardous Waste Residue

3.5 Container Management

3.6 Lead-Based Paint

4 HAZARDOUS WASTE STORAGE

4.1 Hazardous Waste Accumulation Point

4.2 Hazardous Waste Storage Area

4.2.1 Requirements for HWSA

4.2.2 Documentation for the HWSA

4.3 Closure Plans

5 LABELING

5.1 Hazardous Waste Label

5.2 Non Hazardous Waste Label

5.3 Hazard Class

6 TURN-IN PROCEDURES

6.1 Hazardous Waste Turn-in Procedure

Thule Air Base, Greenland 4 1 Dec 2015

6.2 Hazardous Materials Turn-in Procedure

6.3 EPA Provisional ID Number

6.4 Hazardous Waste Tracking

7 CONTINGENCY, PREPAREDNESS AND SPILL RESPONSE

8 PERSONNEL TRAINING

APPENDICES

APPENDIX 1: DEFINITIONS AND TERMS

APPENDIX 2: HAZARDOUS WASTE INVENTORY AT THULE AB

APPENDIX 3: WASTE ANALYSIS PLAN

APPENDIX 4: TURN-IN DOCUMENTS

APPENDIX 5: INSPECTION CHECK LISTS

APPENDIX 6: CLOSURE PLAN

Thule Air Base, Greenland 5 1 Dec 2015

1 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

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

Classification: This document is unclassified.

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

References: References referred to in the HWMP do not appear in the plan, but they may be accessed through GC/EE or the Air Force Electronic Publication Library (AFEPL).

Reviews/changes: The HWMP will be reviewed and updated annually. The initial draft is submitted to BMC Deliverable distribution list. Any 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.

Distribution: The Final plan is submitted to the BMC Deliverable distribution list, tenant units, US/Danish Contractors and other organizations performing work at Thule AB.

Thule Air Base, Greenland 6 1 Dec 2015

2 GENERAL

2.1 Purpose

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

The documentation will include:

Identification of all HW generators.

Identification of all HW streams.

Identification and description of all HW being produced.

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

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

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

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

HWMP.

Revision and update of host-tenant support agreements and exercise support agreements (BOX-TOP, National Science Foundation, etc.) by the Environmental, Safety, Occupational Health Council (ESOHC) to ensure that these comply with the HWMP.

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

2.2 Scope

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

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

A071 Solid Waste Management Plan

A070 Spill Prevention and Response Plan

A067 Asbestos Management Plan

Thule Air Base, Greenland 7 1 Dec 2015

2.3 Regulatory Overview

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

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

Parts 1-900 (Guidance)

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

USAF: Final Governing Standards for Environmental Protection by United

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

Thule AB: ESOHC decisions

Host Country: Country to Country Agreement concerning Disposal of United

States Salvage:

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

Thule Air Base, Greenland 8 1 Dec 2015

3 HAZARDOUS WASTE CHARACTERISTICS

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

Hazardous waste is a solid waste that:

1. Is a listed waste1 or

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

The Waste identification process is shown in the flowchart below:

Solid Waste

The HW identification process is the first step in determining if the waste is solid or not.

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

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

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

Thule Air Base, Greenland 9 1 Dec 2015

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

3.1 Characterization of Waste

There are four HW characteristics. If a waste exhibits one or more of the four characteristics it is a HW. This can be determined by the user’s basic knowledge (Material Safety Data Sheets, MSDS – in future Safety Data Sheets, SDS) or by analyzing the waste.

The four characteristics are:

Ignitable Corrosive Reactive Toxic

3.1.1 Ignitable Waste (D001)

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

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

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

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

It is an oxidizer.

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

Oil based paint, cleaners, and contaminated fuel

Thule Air Base, Greenland 10 1 Dec 2015

3.1.2 Corrosive Waste (D002)

Waste is corrosive if:

It has a pH of less than 2

It has a pH of greater than 12.5

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

Strong acids such as battery acid and hydrochloric acid

Bases such as sodium hydroxide

3.1.3 Reactive Waste (D003)

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

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

It reacts violently with water.

It forms potentially explosive mixtures with water.

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

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

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

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

It is a forbidden explosive.

Unexploded Ordnance (UXO) and flares

3.1.4 Toxicity Characteristic Waste (D004-D43)

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

Thule Air Base, Greenland 11 1 Dec 2015

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

D004 Arsenic 5.0

D005 Barium 100.0

D018 Benzene 0.5

D006 Cadmium 1.0

D019 Carbon Tetrachloride 0.5

D020 Chlordane 0.03

D021 Chlorobenzene 100.0

D022 Chloroform 6.0

D007 Chromium 5.0

D023 o-Cresol 200.0

D024 m-Cresol 200.0

D025 p-Cresol 200.0

D026 Cresol 200.0

D016 2,4-D 10.0

D027 1,4-Dichlorobenzene 7.5

D028 1,2-Dichloroethane 0.5

D029 1,1-Dichloroethylene 0.7

D030 2,4-Dinitrotoluene 0.13

D012 Endrin 0.02

D031 Heptachlor (and its epoxide) 0.008

D032 Hexachlorobenzene 0.13

D033 Hexachlorobutadiene 0.5

D034 Hexachloroethane 3.0

D008 Lead 5.0

D013 Lindane 0.4

D009 Mercury 0.2

D014 Methoxychlor 10.0

D035 Methyl Ethyl Ketone 200.0

D036 Nitrobenzene 2.0

D037 Pentachlorophenol 100.0

D038 Pyridine 5.0*

D010 Selenium 1.0

D011 Silver 5.0

D039 Tetrachloroethylene 0.7

D015 Toxaphene 0.5

D040 Trichloroethylene 0.5

D041 2,4,5-Trichlorophenol 400.0

D042 2,4,6-Trichlorophenol 2.0

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

D043 Vinyl Chloride 0.2

Thule Air Base, Greenland 12 1 Dec 2015

3.2 Listed Waste

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

F-list non-specific source wastes

K-list specific source wastes

P-list commercial chemical products

U-list commercial chemical products

3.2.1 F-list

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

Rags used for cleaning or degreasing and waste residue

3.2.2 K-list

K-listed waste is from a specific source on the K-list. This list includes waste from certain wood-preserving chemical manufacturing, petroleum refining, and other manufacturing processes.

This list is not relevant for Thule AB.

3.2.3 P-list

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

3.2.4 U-list

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

Chemicals such as acetone, ethyl ether, and methanol

Thule Air Base, Greenland 13 1 Dec 2015

3.3 Hazardous Waste Mixtures

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

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

3.4 Hazardous Waste Residue

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

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

3.5 Container Management

Empty containers, which cannot be reused, present a problem. They add considerably to the quantities of solid waste to be disposed of, and if they have previously held HM, disposal may be environmentally unsafe and constitute high costs.

When disposing of used containers the following requirements will be followed:

Containers that have previously held non-HM can be disposed of as solid waste.

Containers having previously held HM or acute HM may be disposed of as solid waste if the container is completely empty. The definition of empty is:

A container that holds less than 2.5 centimeters (one inch) of residue on the bottom, or no more than 3% (by weight) of the total capacity of the container remain in the container (if the container is less than or equal to 110 gallons in size).

A container that has previously held an acute HM, as defined in the FGS, is considered "empty", only if it has been triple-rinsed with an appropriate solvent, or the liner has been removed. The manufacturer's Material Safety Data Sheet (MSDS) – future Safety Data Sheet (SDS) will be examined to determine if the material contains acute hazardous components.

A triple rinsing of a drum is performed using a solvent containing isopropyl alcohol, DF-8, or water depending upon the chemical that has been in the container (if in doubt, call BMC Environmental section, ext. 2698 for advice). The procedure is to pour approximately 10% of the rinsing solvent into the drum (5 gallons solvent in a 55 gallon drum). Close the bungs and slush well. Open the bungs and pour the material into a container suitable for this kind of solvent.

Repeat the rinse twice. The rinse solvent is treated as HW.

Thule Air Base, Greenland 14 1 Dec 2015

3.6 Lead-Based Paint

According to base maintenance contract hazardous waste includes lead-based paint.

On June 8, 2003, EPA issued a final rule to help accelerate the pace of lead-based paint removal from residences, and thereby reduce exposure to children and adults from the heath risks associated with lead. This final rule expressly allows residential lead-based paint waste to be disposed of in construction and demolition (C&D) landfills. Thus, residential lead-based paint waste may be disposed of in a C&D landfill or a municipal solid waste landfill.

GC Environmental Engineering has certified analytical reports on file for building materials with lead-based paint IAW the FGS requirement to characterize your waste stream to determine if they are hazardous.

Construction debris with lead-based paint does not meet the criteria of a hazardous waste (leachate testing IAW EPA and FGS.

Thule Air Base, Greenland 15 1 Dec 2015

4 HAZARDOUS WASTE STORAGE

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

HWAP Hazardous Waste Accumulation Point

HWSA Hazardous Waste Storage Area

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

4.1 Hazardous Waste Accumulation Point

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

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

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

In the event that new HW streams are identified, HWAPs will be established or the waste stream will be added to an existing HWAP in coordination with BMC Environmental section as soon as possible.

At Thule AB, HWAPs may be used to accumulate non-hazardous wastes that are unacceptable for landfill disposal IAW A071 Solid Waste Management Plan. This includes non-regulated wastes such as used glycol and e-waste as well as regulated waste that does not meet the definition of hazardous waste (e.g. PCB items such as ballasts). Requirements ‘g’ through ‘k’ in section 5.1.1 below only applies to containers used to store HW.

Documentation for HWAPs is located at BMC Disposition Services (turn-in documents, manifests), BMC Environmental section (waste analysis records, inspection records) and BMC Administration section (Training records for BMC employees).

The requirements for an HWAP are as follows:

a) A HWAP will be established at or near the point of generation.

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

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

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

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

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

Thule Air Base, Greenland 16 1 Dec 2015

f) Signs:

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

The designated HWAP area will be clearly marked, e.g. with black and yellow striped safety hazard tape or paint.

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

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

h) Containers will be UN-approved except for containers for batteries.

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

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

k) Containers with flammable liquids will be grounded.

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

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

n) Appropriate spill absorbent for the waste stored will be available.

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

p) The HWAP will be orderly and not contain items or materials that are not intended for disposal or recycling via BMC Disposition Services within the designated area.

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

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

Documentation for completed training for BMC personnel is available at BMC Administration section.

s) BMC Environmental section will inspect the HWAP at least once every quarter. GC/EE will follow up on discrepancies from requirements.

t) The schedule for inspection of well managed HWAPs can be reduced by BMC Environmental section to two times per year.

4.2 Hazardous Waste Storage Area

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

Thule Air Base, Greenland 17 1 Dec 2015

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

At Thule AB, there are the following HWSAs:

Bldg. #604 – Funded HW storage. Operated by BMC Disposition Services.

Bldg. #935 – Consolidation of HW, Waste under management. Operated by BMC Disposition Services.

Bldg. #937 – Potential HW pending analysis. Operated by BMC Disposition Services.

Drivers will have a valid ADR certificate (European transport certificate) when transporting hazardous waste to and from the HWSA.

4.2.1 Requirements for HWSA

a. HW that contains liquids will be placed in secondary containment.

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

c. Access will be controlled to prevent incidental contact.

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

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

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

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

English:

"DANGER UNAUTHORIZED PERSONNEL KEEP OUT"

“HAZARDOUS WASTE MANAGEMENT AREA"

Danish:

”Uvedkommende ingen adgang”

”Område med farligt affald”

Greenlandic:

”Navianartoq susassaqanngitsut iseqqusaanngillat”

”Tamanna nakkutigineqarpoq Navianartumik ilitsivik

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

Thule Air Base, Greenland 18 1 Dec 2015

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

g. Incompatible wastes will be properly segregated.

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

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

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

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

l. A Closure Plan will be available (Appendix 6)

m. The BMC Disposition Services will prepare the EPA Uniform Manifest for all off-site shipments and maintain a copy of the manifests for at least three years after shipment.

The HWSA manager will ensure that a DD Form 1348-1A, a DRMS Form 1930, and relevant support documents (MSDS/SDS, analysis report, log) accompany all HW turned in, and that the HW is funded by BMC Environmental section.

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

o. Incompatible HW will be segregated with (temporary) walls to avoid incidental mixing if a spill occurs.

p. The HWSA will be inspected weekly by the HWSA manager (self-inspection, Appendix 5).

q. The HWSA is inspected once every quarter by BMC Environmental section and annually by Fire Protection. BMC Environmental section will follow up on discrepancies from requirements.

r. Portable fire extinguishers, spill control equipment and decontamination equipment will be be available.

s. Bldg #604 and #937 are not heated during arctic winter season. Hence, no water is available to supply water hose streams, automatic sprinklers or water spray systems.

Instead, water is supplied from fire trucks and the fire hydrant system.

4.2.2 Documentation for the HWSA

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

b. Turn-in documents (Appendix 4) for the last three years will be available at the BMC Disposition Services office and in the HWSA.

1348-1A

c. A Hazardous Waste Log will be maintained at the HWSA by the HWSA manager. The inventory will be updated immediately when changes occur. The log will record number and type of containers with HW, name/address of the generator, appropriate hazard class, quantity, date, storage location and disposition data.

Thule Air Base, Greenland 19 1 Dec 2015

d. The Hazardous Waste Log will be made available to the Fire Department.

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

f. Manifests for outgoing HW for the last three years. If not provided, BMC Environmental section will request signed and dated manifests from DLA Disposition Services showing final destination.

The BMC Disposition Services is responsible for maintaining this documentation.

4.3 Closure Plans

Every HW Storage Area (HWSA) will have a closure plan (see APPENDIX 6) before it is opened.

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

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

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

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

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

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

Thule Air Base, Greenland 20 1 Dec 2015

5 LABELING

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

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

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

5.1 Hazardous Waste Label

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

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

Address: Thule Air Base, Greenland

City: APO AE 09704-5000

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

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

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

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

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

Contents: e.g., Drum found on base

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

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

Accumulation start date: Date of sampling

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

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

#551)

Address: Thule Air Base, Greenland

City: APO AE 09704-5000

Contents: Used batteries/ hazardous waste

Thule Air Base, Greenland 21 1 Dec 2015

5.2 Non Hazardous Waste Label

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

Shipper: Organization

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

Address: Thule Air Base, Greenland

City: APO AE 09704-5000

Contents: e.g., used developer

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

Company: Organization

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

Address: Thule Air Base, Greenland

City: APO AE 09704-5000

Source: e.g., Oil changes in WM

Contact: Hazmat specialist, Shop Supervisor or waste oil truck

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

Accumulation start date: The date the drum is filled to 90% of its capacity.Below the “Accumulation start date” write shop name

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

Thule Air Base, Greenland 22 1 Dec 2015

5.3 Hazard Class

The warning labels most commonly used at Thule AB are:

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

Poisonous: Hazard class 6

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

Miscellaneous: Hazard class 9

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

Thule Air Base, Greenland 23 1 Dec 2015

6 TURN-IN PROCEDURES

6.1 Hazardous Waste Turn-in Procedure

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

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

b. The waste generator characterizes the hazardous waste.

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

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

d. Label the container, see Chapter 6.

e. The waste generator will in cooperation with BMC Disposition Services fill out the turn-in papers for HW:

1. Hazardous Waste Profile Sheet, (DRMS Form 1930), see APPENDIX 4

2. DD Form 1348-1A, see APPENDIX 4

f. Contact the BMC Disposition Services, ext. 2785, for weighing and transportation.

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

h. Contact BMC Environmental section for funding.

6.2 Hazardous Materials Turn-in Procedure

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

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

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

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

Thule Air Base, Greenland 24 1 Dec 2015

6.3 EPA Provisional ID Number

Shortly (7 to 8 days) before the Pacer Goose departs from Thule AB to Norfolk, VA, EPA Form 8700-12 “RCRA Subtitle C Site Identification” is prepared for 821 ABG/CC signature and consequently submitted to the Virginia Department of Environmental Quality (A069 Hazardous Waste Permit). The EPA Provisional ID Number will be renewed after 30 days of the initial number, if the HW has not reached its final location.

6.4 Hazardous Waste Tracking

Training for hazardous waste specialists in tracking hazardous waste is currently scheduled for December 2015. Hazardous waste storage and turn-in is intended to be tracked through EESOH-MIS (Environmental Enterprise Safety Occupational Health Management Information System) database.

Thule Air Base, Greenland 25 1 Dec 2015

7 CONTINGENCY, PREPAREDNESS AND SPILL RESPONSE

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

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

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

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

Each contingency plan will contain the following information:

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

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

The emergency response equipment can include:

- Spill booms or absorbent pillows.

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

- Fire control equipment, as decided by BMC Fire Protection.

- Chemical respirators suitable for the waste in storage.

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

- Gloves and boots.

- Face shields and safety glasses.

- Salvage drums.

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

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

Thule Air Base, Greenland 26 1 Dec 2015

8 PERSONNEL TRAINING

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

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

The training can be accomplished by completing a Danish language e-learning module developed by BMC Environmental section.

The training includes

Chemical hazards of HW.

Regulatory overview.

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

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

Personal protective equipment.

Record keeping, inspections, contingency plans and storage requirements.

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

All hazardous material and hazardous waste is transported by ADR-certified personnel in accordance with host nation regulations. HM and HW transportation training is part of a valid ADR-certificate.

Thule Air Base, Greenland 27 1 Dec 2015

APPENDICES

Thule Air Base, Greenland 28 1 Dec 2015

APPENDIX 1: DEFINITIONS AND TERMS

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

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

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

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

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

DOT – Department of Transportation.

DRMS – Defense Reutilization and Marketing Service.

EPA – Environmental Protection Agency.

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

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

ESOHC – Environmental, Safety, Occupational Health Council

FGS – Final Governing Standards.

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

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

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

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

Thule Air Base, Greenland 29 1 Dec 2015

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

HTSC – Harris Technical Service Corporation.

HM – Hazardous Material.

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

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

HW.

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

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

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

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

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

N.O.S. – Not otherwise specified.

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

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

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

Thule AB – Thule Air Base.

Waste Stream Code – A unique identification number assigned to each waste stream by BMC Environmental section after the identification of that waste stream.

Thule Air Base, Greenland 30 1 Dec 2015

APPENDIX 2: HAZARDOUS WASTE INVENTORY AT THULE AB

HW inventory is based on the information provided by eachindividual shop at Thule AB. It contains federal hazardous waste generated on a recurring basis at the shop level.

LIST OF RECURRING INDUSTRIAL GENERATED HAZARDOUS WASTE STREAMS

Type of Waste Waste Stream Code

Sources (GC unless otherwise indicated)

Disposal Hazardous waste characteristics

Rags with Solvent HWAP-02 Vehicle Maintenance 580

Facility Maintenance 551

Facility Maintenance 801

M-Plant 1391

J-Plant 4016

BMC Disposition Services

F003

Fuel contaminated Adsorbent

HWAP-03 Basewide BMC Disposition Services

D001

Aerosol Spray Residue (except paint)

HWAP-04 935 BMC Disposition Services

D001

Batteries, Misc. HWAP-05 Basewide BMC Disposition Services

D002,D006, D008

Fluorescent Light Bulbs HWAP-06 Basewide BMC Disposition Services

D009

Paint (oil-based) HWAP-07 Facility Maintenance 801 BMC Disposition Services

D001

Paint related material (Thinner)

HWAP-09 Vehicle Maintenance 580

Facility Maintenance 801

BMC Disposition Services

D001

Aerosol filter (paint can puncture)

HWAP-10 935 BMC Disposition Services

D001

Used oil filters vehicle HWAP-11 Vehicle Maintenance 580

Airport Ground Equip 1408

BMC Disposition Services

D001

Used fuel filters, vehicle HWAP-12 Vehicle Maintenance 580 BMC Disposition Services

D001

Drained fuel filters, fuel operations

HWAP-13 K-Plant 1401 BMC Disposition Services

D001

Drained oil filters, power production

HWAP-14 J-Plant 4016 BMC Disposition Services

D001

Old Mercury Switches HWAP-19 Facility Maintenance 551 BMC Disposition Services

D009

Dry Cleaning Sludge HWAP-20 Laundry Services 237 BMC Disposition Services

D001

Lead Solder HWAP-21 Non-Secure Comm. 1411 BMC Disposition Services

D008

Aerosol Spray Residue - Paint

HWAP-22 Basewide BMC Disposition Services

D001

Paint booth filters HWAP-24 Vehicle Maintenance 580 BMC Disposition Services

D005, D007, D008, D010

Aerosol cans HWAP-26 Basewide BMC Disposition Services

D003

Filter, florescent light bulb crusher

HWAP-27 935 BMC Disposition Services

D009

Thule Air Base, Greenland 31 1 Dec 2015

Waste from different sources that is part of the same waste stream may be mixed prior to disposal. When BMC Disposition Services is listed as disposal method the waste is annually shipped to Norfolk, Virginia as hazardous waste.

Batteries (HWAP-05)

The waste stream consists of collected batteries of mixed types. The HWSA manager sorts the batteries and secures them against short-circuiting prior to shipping. The following battery waste streams are established in the HWSA:

Rechargeable gel cell batteries (HWAP-05A)

Alkaline batteries (HWAP-05B)

Lithium batteries (Li-SO2) (HWAP-05C)

Rechargeable nickel-cadmium (NiCad) batteries (HWAP-05D)

Mercury batteries (HWAP-05E)

Silver batteries (HWAP-05F)

Drainable batteries are recyclable and are treated as HM and turned in as such. Only batteries which are not recycled will be managed as HW.

Brass turnings

While brass turnings can exhibit the hazardous characteristic of toxicity (IAW 2011 analysis results) they are not treated as hazardous waste because brass is collected for recycling.

Fluorescent Light Bulbs (HWAP-06)

Accumulated fluorescent light bulbs are being crushed by the BMC Disposition Services. A filtered unit collects the mercury and leave metal and glass parts in a drum. The metal and glass can be disposed as solid waste. A HW analysis on this material was completed in 2010.

Aerosol cans (HWAP-26)

Accumulated aerosol cans are punctured by the BMC Disposition Services. Residue is collected as hazardous waste and the punctured cans are disposed of as solid waste at the base landfill

Regulated, non-hazardous waste streams

Medical Supplies past expiration date

Occasionally the base hospital has medical supplies (such as Epinephrine shots) that need to be disposed of due to expiration. The established procedure is to ship such supplies back to the origin (McGuire AFB) as they are controlled substances.

Thule Air Base, Greenland 32 1 Dec 2015

Contaminated Soil

Procedures for sampling, disposal and treatment of contaminated soil are provided in the spill prevention and response plan.

Asbestos containing waste

Waste containing potentially friable asbestos is disposed as the Asbestos Landfill IAW the Asbestos Management Plan.

PCB wastes

PCB wastes are collected for disposal by the BMC Disposition Services. While technically not a HW, PCB ballasts (a recurring waste stream) is collected at a HWAP in order to ensure compliance with FGS requirements for PCB waste and storage.

Unacceptable Wastes Details on solids waste streams not accepted at the sanitary landfill and methods of disposal are described in more detail in the solid waste management plan. HWAP basewide are used to collect these streams to the extent they are disposed of via BMC Disposition Services. This includes oily rags, used glycol, surplus HAZMAT without EPA waste codes etc. MSDS/SDS information is generally used to document user knowledge (i.e. that the materials are, in fact, not hazardous waste).

Used Oil Fuel

Used oil and other petroleum, oil and lubricating (POL) products may be used for energy recovery, when the POLs have been analytically tested and found to contain less than:

Arsenic: 5 ppm maximum Cadmium: 2 ppm maximum Chromium: 10 ppm maximum Lead: 100 ppm maximum Flash Point: -2 F (-20 0C) as a minimum and 449.6 F (232 0C) as a maximum, the temperature range is established based on the requirements of the local burner

Total Halogens: 1000 ppm maximum

At Thule AB, used oil is burned at the K-plant. Grab samples from the accumulation points are analytically tested once a year. When used oil is ready for turn in at the K-plant, the operation will be coordinated with BMC Environmental section. All drums holding used oil will be labeled with a label stating

“USED OIL”.

Used oil and other POL products generated by seasonal contractors may be used for energy recovery, when the POL meets the above standard.

When used oil generated by seasonal contractors is ready for turn-in, the seasonal contractor will contact BMC Environmental section. Used oil will not be accepted for turn-in to the K-Plant unless approved by BMC Environmental section. BMC Environmental section will request

Thule Air Base, Greenland 33 1 Dec 2015 documentation from the seasonal contractors regarding the source and the accumulation of the used oil. If satisfactory documentation cannot be provided, the contractor will ensure that the used oil is sampled for hazardous waste characteristics.

The only means of transferring the used oil to the K-Plant is by using the waste refuel truck available in BMC Utility Facility Maintenance section. Support from BMC Utility Facility Maintenance section can be provided on request for normal BMC activities. Seasonal contractors will request a “Requisition” through GC.

Thule Air Base, Greenland 34 1 Dec 2015

APPENDIX 3: WASTE ANALYSIS PLAN

The HW analysis plan is based on the information provided by each individual shop at Thule AB.

If changes occur in the HW streams, these will be communicated to GC/EE so that the HW analysis plan can be updated accordingly. It is the responsibility of the HWAP/HWSA managers in cooperation with GC/EE to perform the annual sampling of the waste streams. Parameters are analyzed according to the EPA Toxicity Characteristic Leaching Procedure (TCLP) test method 1311 as stated in SW-846 (SW-846 is EPA Waste's official compendium of analytical and sampling methods that have been evaluated and approved for use in complying with RCRA regulations).

Outside the regular waste streams, samples will be taken from unknown (i.e. no MSDS/SDS information is available) wastes for analysis. Appropriate analysis will be selected based on the matrix of the sample (aqueous, solid, POL etc.). All HW do require an analytical report, appropriate MSDS/SDS information (in English) or a memorandum from GC/EE specifying user knowledge to be included with the turn-in documents (Appendix 4).

Thule AB has a very limited capability to perform local testing. Flash point determination by a Pensky-Martens Closed Cup Tester, using the ASTM standard test method D-93-80 can be performed on the base Fuel Laboratory.

Waste Stream Parameters (TCLP) Analysis Frequency Last Performed

HWAP-04 Metals, Ignitability, Volatiles, Semivolatiles

Each Shipment 2012

HWAP-07 Metals, Ignitability, Volatiles, Semivolatiles

Each Shipment 2011

HWAP-09 Metals, Ignitability, Volatiles, Semivolatiles

Each Shipment 2011

HWAP-10 Metals, Ignitability One time analysis 2007 HWAP-20 Volatiles, Metals Each Shipment 2011 Used Oil Metals, Ignitability, Volatiles, Semivolatiles, Sulfur Annually 2014

Oil-water separator sludge

Metals, Semivolatiles, Volatiles Each Shipment 2012

Break Fluid Metals, Semivolatiles, Volatiles One time analysis 2009 Metal shavings and turnings

Metals One time analysis 2011

Pot ash from Used Oil incineration

Metals One time…