Appendix_E_-_Spill_Prevention-Response_Plan.pdf

A070 SPILL PREVENTION AND RESPONSE PLAN

Thule Air Base

DRAFT

8 July 2016

Greenland Contractors

Environmental Engineering Supersedes CDRL CEV‐15C, FY15 edition

INSTALLATION IMPLEMENTING INSTRUCTION

Date: This plan is current as of 8 July 2016

Requiring Office: 21 CES/CEIE

OPR: Greenland Contractors, Environmental Engineering

Subject: Spill Prevention and Response Plan (SPRP), Base Maintenance Contractor (BMC) deliverable 070

References: - Final Governing Standards (FGS), Chapter 18.

- TAB O-Plan 10-211, CE Contingency Response Plan

- Thule AB COOP/IEMP 10-2 (Continuity of Operations/ Thule

AB Installation Emergency Management Plan)

- REPORT AND RECOMMENDATIONS for the OIL SPILL

RESPONSE AND CONTINGENCY PLAN for THULE AIR BASE, GREENLAND (PCCI Marine and Environmental Engineering, 28 November 2011).

Purpose: The purpose of the SPRP is to implement criteria for the prevention, response and reporting of oil and chemical spills at Thule AB.

Discussion: Implementation of this plan provides documented guidance regarding spill prevention and response actions to ensure a safe, healthy and clean environment and ensure continuity of operations.

It is a comprehensive document applicable to all personnel working at Thule AB. It is designed to ensure installation compliance with FGS regulations governing spill prevention and response.

Applicability: The requirements of this plan apply to all base operations.

Approved by

821 ABG/CC:

Date CHRISTOPHER A. EAGAN, Colonel, USAF

Commander, 821st Air Base Group

A070 Spill Prevention and Response Plan

Thule AB 2 8 July 2016

TABLE OF CONTENTS

1 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

2 INFORMATION AND EMERGENCY CONTACTS

3 GENERAL

3.1 Purpose

3.2 Scope

3.3 Regulatory Overview

4 PREVENTION SECTION

4.1 Incident Commander (IC)

4.2 General Information

4.3 Potential Spill Locations

4.4 Arrangements for Emergency Services

4.5 Telephone number to emergency services

4.6 Prevention, Control and Countermeasures

4.7 Emergency Equipment

4.8 Communication systems

4.9 Evacuation Plans

4.10 Required Procedures

4.11 Site-specific procedures

4.12 Deficiencies in Spill Prevention and Control Measures

4.13 Worst Case Spill Scenarios

5 SPILL CONTROL SECTION

5.1 Responsibilities, duties, procedures and resources

5.2 Immediate response actions

5.3 Emergency Response Team

5.4 Procedures for ERT alert and response

5.5 Notification of Spills

5.6 Notification of IC, Installation Commander and local authorities

5.7 Assignment of responsibilities for making notifications

5.8 Surveillance procedures for early detection of spills

5.9 Critical Water and Natural resources

5.10 Additional Emergency Assistance Organizations

5.11 Cleanup procedure

5.12 Reuse and disposal of recovered substances and absorbent materials

5.13 General health, safety and fire prevention precautions

5.14 Public Affairs and releasing information

Thule AB 3 8 July 2016

6 REPORTING SECTION

6.1 Recordkeeping

6.2 Non-Reportable Spills

6.3 Reportable Spills

6.4 Notification of Host Country Authorities

6.5 Spill Response Training and Drills

6.6 Follow-up actions

APPENDIX 1: POTENTIAL SPILL LOCATIONS, HAZMAT STORAGE

APPENDIX 2: POTENTIAL SPILL LOCATIONS, TANKS AND TRANSFORMERS

APPENDIX 3: SPILL ROUTE MAPS

APPENDIX 4: DRAINAGE PATTERNS

APPENDIX 5: EVACUATION PLANS

APPENDIX 6: WATER PROTECTION AREAS

APPENDIX 7: SPILL MIGRATION PATHWAYS

APPENDIX 8: INVENTORY OF SPILL RESPONSE EQUIPMENT

APPENDIX 9: FUEL DISTRIBUTION PIPELINE MAP

APPENDIX 10: FUEL TRANSFER PROCEDURES

APPENDIX 11: SPILL ROUTE MAP, FLIGHTLINE

APPENDIX 12: SITE SPECIFIC CONTINGENCY PLAN (EXAMPLE)

APPENDIX 13: PETROLEUM PRODUCT CONTAMINANTS OF CONCERN

Thule AB 4 8 July 2016

1 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

Title: The long title of this plan is “Spill Prevention and Response Plan”. The short title is SPRP, and this title will be used as reference throughout the entire document.

Classification: The document is unclassified.

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

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

Reviews/Changes: This plan is updated every five years. The initial draft is submitted to the

BMC Deliverable distribution list and the BMC Fire Department. Any 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.

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

Thule AB 5 8 July 2016

2 INFORMATION AND EMERGENCY CONTACTS

As Thule AB is a remote site, no immediate support from outside installation agencies may be expected in case of emergencies. If an emergency occurs and Thule AB is not capable of responding, 21st Space Wing must be contacted.

Emergency Phone Numbers

List of persons to be contacted in case of an emergency situation and their phone numbers:

Department Extension

Main Base Fire Department or Ambulance 911

12 SWS Site I Fire Department or Ambulance 911

DET-1 Fire Department or Ambulance 911

821 SFS Security Forces 911

Storm Operations Center 2764

Civil Engineering Service Call 2111

GC Environmental Responder on Call (Service Call) 2111

GC Base Civil Engineer 2723

GC Environmental Engineering 2698

Spill Response Team Supervisor 2815

Marine Spill Team Supervisor 2712

821 SPTS/SG Medical Liaison Officer 2696

821 ABG Safety Officer 2709

821 SPTS/CE Civil Engineering 3274

Danish Liaison Officer 2276/2206

Danish Police Inspector 2406/1448

21 CES/CEIE DSN 834-1433

Thule AB 6 8 July 2016

3 GENERAL

3.1 Purpose

The purpose of the plan is to assure that documented guidance regarding spill prevention and response is available to all installation personnel. The plan will describe the procedures, methods, and equipment being used to prevent spills at Thule AB, as well as procedures to be followed in case of releases, accidents, and spills. The goal is to achieve a full state of awareness throughout the installation and in this way enable personnel to:

Be familiar with spill prevention and response procedures including related regulatory requirements.

Develop related planning documents (e.g. action plans) that will bring the installation into full compliance with regulatory requirements.

Quickly and appropriately respond to spills in a manner that will greatly reduce or eliminate contamination, which is the overall purpose.

Maintain a safe working environment at the installation.

3.2 Scope

The provisions of the SPRP apply throughout the whole installation and to all personnel.

Certain responsibilities are specifically assigned to selected individuals identified in the plan.

The SPRP limits its contents to spill prevention and response issues. The Thule AB

COOP/IEMP 10-2 (Continuity of Operations/ Thule AB Installation Emergency Management

Plan) is the overall response instruction for major spills and natural disasters at Thule AB.

3.3 Regulatory Overview

Thule AB: Final Governing Standards (FGS)

The Environmental Safety and Occupational Health Council (ESOHC) functions as the primary executive steering group for environmental compliance, conservation and pollution prevention programs. He ESOHC has two scheduled meetings annually and is chaired by 821 ABG/CC or designated representative.

Host Nation: The Greenland Government (GG) Authority has the primary role for environmental protection in Greenland outside the Defense Area. This include Greenlandic waters such as North Star Bay.

Thule AB 7 8 July 2016

4 PREVENTION SECTION

4.1 Incident Commander (IC)

The IC at Thule AB is the Fire Chief. The following table lists the IC and alternates.

TABLE 4.1

Roster listing the IC and alternates, IAW FGS C18.3.2.1

Title Responsibility Duties Duty

Phone

Tetra

Phone

Fire Chief Incident

Commander

First Responder

Evaluate spill situation. Provide guidance in spill containment, clean-up actions and restoration activities.

Coordinate HAZMAT personnel, Spill

Response Team and Marine Spill Team

3249 (88) 3249

Asst. Fire Chief, Tech.

Alternate IC

First Responder

Evaluate spill situation. Provide guidance in spill containment, clean-up actions and restoration activities.

Coordinate HAZMAT personnel, Spill

Response Team and Marine Spill Team

(88) 3158

Asst. Fire Chief, Operations

Alternate IC

First Responder

Evaluate spill situation. Provide guidance in spill containment, clean-up actions and restoration activities.

Coordinate HAZMAT personnel, Spill

Response Team and Marine Spill Team

(88) 4650

(88) 4652

(88) 4651

4.2 General Information

Facility Description

Thule AB is located 695 miles North of the Arctic Circle (76 32' North latitude, 68 50' West longitude), and 947 miles south of the North Pole on the northwest side of the island of

Greenland. It is approximately 550 miles east of the North Magnetic Pole.

The Thule Defense Area is a large land area that includes various base functions outside the

Main Base area (Appendix 6). Thule AB contains three distinct areas; Main Base, 12 SWS, and Det-1. The areas of the base are divided into building areas designated as 100 through

900 areas. The Group Headquarters and other support functions are located in the 400 area of the base. The area identified as the goal for consolidation efforts is within the 100 and 200 areas (See Figure 1) together with the flight line facilities in the 600 area. Also, some large facilities in the 500, 700, 800 and 900 areas, primarily with stand-alone heating systems, will remain.

Thule AB 8 8 July 2016

Figure 1: Thule AB Main Base Area

Thule AB is located in the valley of a glacially fed stream called North River. This area is designated by the Danish government as the Thule Defense Area. The Main Base is located on a relatively flat plain near the mouth of the stream. The active landfill at Thule is located southeast of the main base (Figure 3, taken from Final Landfill Assessment and Operations

Management Plan, 821st ABG, December 2005). DET-1 is located 3 miles east of the Main

Base (Figure 4) and 12 SWS located 12 miles northeast and 1,250 feet higher on a hill overlooking Wolstenholme Fjord (Figure 5). Lake Crescent is used for potable water production and is located 5 miles east of the main base (Figure 6).

The base mission consists of 12th Space Warning Squadron (12 SWS) and 23rd Space

Operations Squadron (DET-1, 23 SOPS) satellite tracking and control operation.

Figure 2: Map of Thule Air Base

Thule AB 9 8 July 2016

Figure 3: Thule AB Landfill area

Figure 4: Thule AB DET-1 area

Thule AB 10 8 July 2016

Figure 5: Thule AB 12 SWS area

Thule AB 11 8 July 2016

Water protection Areas There are three main water protection areas. They are the North Star River, North Star Bay, and Lake Crescent. Maps of these three locations are shown in Appendix 6 Water Protection

Areas

Maps of Locations

Figure 1 to Figure 5 above show maps of the locations covered by this plan. The locations are the Thule AB Main Base Area, Thule AB Landfill area, Thule AB DET-1 area, and the

Thule AB 12 SWS area

Critical water resources

Lake Crescent is a critical water resource to Thule Air Base functioning as water supply of potable water to Thule AB. Lake Crescent is the only approved potable water supply for all facilities at Thule AB. There is no direct protection of the water source in Lake Crescent and runoff from the watershed goes directly into the lake. Handling of chemicals and other water pollutants is not to take place in the proximity of the lake without taking special precautions.

Possible Migration Pathways

The possible migration pathways are shown in Appendix 7 Spill Migration Pathways. The red arrows indicate the flow direction.

Drainage Patterns

Drainage patterns are shown in Appendix 4

4.3 Potential Spill Locations

A significant spill is defined as an uncontained release to the land or water in excess of any of the following quantities:

For hazardous waste or hazardous substance identified as a result of inclusion in Table

AP1.T4 of the Final Governing Standards, any quantity in excess of the reportable quantity listed in the table;

For POL or liquid or semi-liquid hazardous material, hazardous waste or hazardous substance, in excess of 400 liters (110 gallons);

For other solid hazardous material, in excess of 225 Kg (500 pounds); or

For combinations of POL and liquid, semi-liquid and solid hazardous materials, hazardous waste or hazardous substance, in excess of 340 Kg (750 pounds).

If a spill is contained inside an impervious berm, or on a nonporous surface, or inside a building and is not volatilized and is cleaned up, the spill is considered a contained release and is not considered a significant spill.

All HAZMAT storage locations where there can be a significant spill are listed in Appendix 1.

Thule AB 12 8 July 2016

Bulk Storage sites for JP-8 are 12 Bulk Storage Tanks (BST) at Tank Farm North, Tank 98 at the pier and two BSTs at J-plant (bldg. 4016). Further, there are a large number of smaller organizational tanks at Thule AB. Appendix 2 lists the tanks that can produce a significant spill.

Bulk Storage, Handling and Transfer sites are listed in Appendix 2, with range and total quantity of spill.

4.4 Arrangements for Emergency Services

Emergency services are provided by Greenland Contractors. Security is provided by 821st

Security Forces Squadron. Sections 5.1.3 - 5.1.7 describe the role of each emergency response team.

4.5 Telephone number to emergency services

The telephone number to emergency services on a 24 hour basis is ext. 911.

For incidents where there is no imminent danger to human health or the environment, the incident can be reported to service call instead at ext. 2111.

4.6 Prevention, Control and Countermeasures

The potential sites where a significant spill can occur are listed in Appendix 1 and 2.

The slope of the terrain will cause all spills in the main base area to ultimately flow west, eventually reaching the North Star Bay (possibly via the North Star River).

Further, the Wolstenholme Fjord could be threatened by a major spill incident at 12 SWS.

Most indoor spills will be contained to the building in which the tanks or hazardous material are located. A spill will be contained using compound absorbent material and spill kits. The primary concern will be the safety of personnel and entry into the sewage system. All indoor potential spill locations must have appropriate spill kits available.

Site specific spill route maps for outdoor locations are provided in Appendix 3 and indicate the potential direction of flow.

Appendix 1 lists the areas where large amounts of hazardous materials and/or waste are stored. The table is listed according to building number, functional area, amount and type of material or waste. The hazardous material inventories from the individual shops are overseen by GC/EE and GC Supply, who maintain a database over the purchase and stock of hazardous materials.

In all cases spills will be collected in trucks to be temporarily disposed of in POL/water tanks designated for POL spills or stored at Bldg 604 for later shipment as hazardous waste. In case

Thule AB 13 8 July 2016 the storage capacity of Thule AB is not sufficient, the temporary use of capacity designated for other purposes will be coordinated with 821 ABG/CC and 21 CES. Potential options in decreasing order of priority include waste fuel trucks and tanks, tank farm rinsate tanks, other available tank capacity, and as a last option the containment areas at the tank farm.

4.7 Emergency Equipment

Appendix 8 contains an inventory of emergency equipment used by the Emergency Response

Team. Appendix 1 and 2 list emergency equipment present at potential spill locations.

4.8 Communication systems

At Thule Air Base there are the following communication systems, which can be used under a spill incident:

Telephone system

Tetra Land Mobile Radio system

In the initial phase of a spill incident, the alarm will go via the telephone system using 911.

4.9 Evacuation Plans

Evacuation plans for potential spill sites, where there is a possibility that evacuation would be necessary, are provided in Appendix 5. The signal for evacuations at Thule AB is fire alarms.

4.10 Required Procedures

Written procedures to preclude spills, inspections and recordkeeping requirements can be found in Appendix 10..

4.11 Site-specific procedures

In Appendix 12 an example of the contingency plans can be found. At each potential spill locations, these plans are posted with appropriate spill flow route maps or evacuation plans from Appendix 3 and 5, respectively.

4.12 Deficiencies in Spill Prevention and Control Measures.

The following deficiencies have been identified at Thule AB

TABLE 4.2

Deficiencies in TAB’s Spill Prevention and Control Measures.

Potential Spill Location Deficiencies North Star Bay Insufficient storage capacity for worst case spill

Insufficient support agreement planning

Thule AB 14 8 July 2016

4.13 Worst Case Spill Scenarios

The worst-case planning threshold for spills at Thule AB is 1.84 million gallons IAW FGS

Appendix AP2. Thule AB does not have the capability to respond to a spill of that magnitude without external support. The current designated storage capacity for spills is 12,500 gallons.

4.13.1 Tank ship operation

A disaster scenario at Thule AB would be if the tanker that delivers POL to Thule AB during the summer experienced a significant spill. More than 8 million gallons of JP-8 jet fuel are received annually. While Thule is unable to respond completely to a very large spill in the bay without external support, the likelihood of a major disaster affecting the ship while moored is very low. The following precautions are taken to avoid spills from the hoses (which would be in the thousands of gallons range):

The transfer hoses are pressure tested prior to use to minimize the risk of hose failure.

In case a weather warning calling for high-speed winds is issued the fuel transfer will be aborted temporarily. This minimizes the risk of a spill caused by rapid disconnection of hoses provoked by an immediate need to get the vessel to deeper water.

If a spill does occur the Marine Spill Team (MST) (section 5.1.7 and 5.3.3) will deploy a deflection boom and use skimmers to contain and recover fuel from the ocean surface.

Recovered diesel would be transferred to towable bladder tank, and transferred to holding tanks.

4.13.2 Tank Farm North

The Thule AB tank farm consists of twelve Bulk Storage Tanks (BSTs), each with a capacity of 2.1 million gallons. The BSTs all have secondary containment in the form of berms that incorporate double liners, drainage, and all tanks are equipped with level gauges and alarms.

The secondary containment berms are sized for 110% of the tank capacity. The tank farm is located on a hill side above the North River with the first tank being approximately a mile from the bay.

A critical failure of a BST could potentially release more than 2 million gallons fuel. The procedure for containing such an event would be to pump the spill from the secondary containment to an empty bulk storage tank. No BST is designated for this purpose and if all

BSTs are full the spill would remain in the secondary containment basin until a BST could be emptied. The probability of such a failure is very low.

The fuel transfer lines between Tank Farm North and buildings and tanks pass over the North

Star River. During high river flows or flooding these lines are potentially at risk. Even if the fuel transfer is aborted immediately following the detection of a leak, the volume of fuel in the pipelines is thousands of gallons.

Thule AB 15 8 July 2016

The strategy will be to deploy the LAMOR Near-shore Skimming System with the MST.

However, due to high water speed in the river, it will be a challenge to position the boom and recover such a spill completely and only partial recovery can be expected.

Thule AB 16 8 July 2016

5 SPILL CONTROL SECTION

The spill control section may be considered a contingency plan and is also often referred to as the spill response section. The scope of this section is to identify resources for cleaning up spills at installations and activities located in the Thule Defense Area, and to provide assistance to other agencies when requested.

5.1 Responsibilities, duties, procedures and resources

It is the responsibility of the personnel mentioned below to maintain the procedures necessary for implementing this plan. Such procedures shall ensure adequate training of personnel and implementation of environmental protection and pollution abatement procedures in their areas of responsibility. The personnel will designate additional project officers and monitors as required ensuring an effective program. These designated individuals will continuously inspect the work areas under their individual areas of responsibility. The names and telephone numbers of the project officers and monitors will be posted in prominent locations at potential spill sites.

The Emergency Response Team (ERT) consists of personnel from the GC Fire Department

(HAZMAT personnel) and designated individuals from GC Operations (the Spill Response

Team and Marine Spill Team).

The personnel involved in the process of containing and cleaning up spills at Thule AB

(including drills) are identified below. Other offices can be involved in follow-up actions.

5.1.1 Installation Commander (821 ABG/CC)

The Installation Commander exercises the overall responsibility for the management of spill prevention and response planning at Thule AB. The 821 ABG/CC is the chairperson of the

Environmental Safety Occupational Health Council (ESOHC).

Public affairs including all notifications to the DLO and/or external offices must be accomplished by or coordinated with the Installation Commander prior to execution. The

Installation Commander designates the Incident Commander (IC).

5.1.2 Danish Liaison Officer (DLO)

The Danish Liaison Officer serves as the official representative of Denmark, and Greenland

Self Rule at Thule AB.

5.1.3 Consolidated Service Center (GC/LGCM)

The Consolidated Communication Center (CCC) receives emergency calls (911) and activates responders. The CCC also operates the Service Call function.

Thule AB 17 8 July 2016

5.1.4 Security Forces Squadron (821 SFS)

During a spill situation, Security Forces will:

Evacuate personnel from the scene, if needed, based on the decisions of the Incident

Commander or the Fire Chief.

Secure the area as “Off Limits” to unauthorized personnel.

Coordinate the movement of specific personnel to assist at the incident scene.

Direct traffic.

5.1.5 HAZMAT Personnel and Incident Commander (GC Fire Department)

The Fire Department at Thule AB is the first responder to all incidents (exception: spills in North

Star Bay and Wolstenholme Fjord are responded to be the Marine Spill Team). The responsibilities include responding, containing and assessing all incidents to ensure that the scene is a safe and controlled incident site. It is the Fire Chief’s responsibility to designate an entry control point based on the incident situation. The Fire Chief or Assistant Fire Chief on duty is the designated Incident Commander (IC) by the installation commander.

The IC is responsible for directing and coordinating all spill response actions within Thule AB.

The IC will have the authority to utilize the expertise and resources of the Emergency

Response Team (ERT), or any other office of expertise in determining and performing response actions.

5.1.6 Spill Response Team (GC/OMUFM)

The Spill Response Team (SRT) consists of designated members mainly from the Utilities

Facilities Maintenance section, but personnel from the Transportation and Vehicle

Maintenance shops can also be appointed. Members must have received training in HAZMAT communication training and have a technical background. The task of the SRT is to respond to spills when requested by the Incident Commander or the Fire Chief in order to perform spill containment, recovery, disposal, and restoration activities within the Defense Area.

5.1.7 Marine Spill Team (GC/LGTT)

The Marine Spill Team (MST) consists of personnel in the Water Port operations section

(Pavements and Grounds, GC/LGTT) and selected persons from the Utilities Facilities

Maintenance section. Members must have received training in HAZMAT communication training and have a technical background. The task of the MST is to respond to spills when requested by the Incident Commander or the Fire Chief in order to perform spill containment, recovery, disposal, and restoration activities in North Star Bay and Wolstenholme Fjord.

5.1.8 Civil Engineering Flight Commander (821 SPTS/CE)

The Civil Engineering COR will oversee GC response efforts and act as the point of contact for follow-on actions and remediation efforts.

5.1.8 Environmental Engineering (GC/EE)

GC/EE has the responsibility of managing the Thule AB SPRP. In a spill situation, GC/EE is tasked to assist the IC in evaluating the situation and provide guidance on spill containment, Thule AB 18 8 July 2016 cleanup actions and restoration activities. GC/EE will manage a record of all spills at TAB and prepare all required reports and documentation.

5.1.9 Pavement and Grounds (GC/LGTT)

The GC Pavement and Grounds division will perform excavations and transport contaminated snow and/or soil as requested by Environmental Engineering.

5.1.10 Vehicle Maintenance (GC/LGTM)

The GC Vehicle Maintenance shop will ensure that emergency vehicles are operational to perform according to this plan. This includes boats.

5.1.11 Safety Organization

The Chief of Safety (821 ABG/SE) is notified of major spills. GC/OHS will provide technical expertise on safety hazards at the request of the IC or Chief of Safety.

5.1.12 GC Health Services (GC/SG)

GC Health Services (the base hospital) can be activated by the IC to provide medical expertise.

5.1.13 General Personnel

Each individual working at Thule AB including all seasonal contractors are tasked to report any spills to the Service Center ext. 2860 and to take every reasonable precaution to prevent spills.

Appendix 8 provides data on locations and quantities of spill response equipment at Thule AB.

This is to provide a better and more efficient emergency response to minor spills and to keep a total list of equipment available and updated. Shops can use the lists as a reference, if a spill occurs within their shop and additional spill response equipment is needed.

5.2 Immediate response actions

All permanent residents at Thule AB are obligated to react immediately, when a spill incident occurs and/or is first discovered (e.g. by calling 911, 2860 or 2111). Depending on the quantity of the spill, some personnel groups may be able to initiate an immediate response.

Immediate response actions can include

Restrict all sources of ignition

Check causes and stop source of spill if possible without undue risk of personal injury, stop source of spill or establish containment/diversionary devices to contain release.

Evacuate the area

Report the incident to the Consolidated Communication Center (CCC) ext. 911. For spills of less than 25 gallons of POL product the spill can be reported to GC/EE (ext

2698) if personnel at the scene are able to respond to the incident. Adequate response will be verified by GC/EE, Make the spill scene “Off Limits” to unauthorized personnel

Thule AB 19 8 July 2016

5.3 Emergency Response Team

The personnel involved in spill response actions can be divided in three groups; HAZMAT personnel, the Spill Response Team (SRT) and the Marine Spill Team (MST).

5.3.1 HAZMAT personnel

The HAZMAT personnel will complete the initial response to any spill situation and get it under control. HAZMAT personnel are trained professional responders (fire fighters) from the GC

Fire Department. Documentation for educational background for IC and fire fighters is available at GC Human Resources. The IC directs the HAZMAT personnel.

5.3.2 Spill Response Team (SRT)

The SRT will be notified by the IC and requested to initiate cleanup actions when the incident scene is considered under control and safe to enter. The SRT at TAB is limited in equipment and training, and is therefore not able to respond to all types of incidents. The role of the SRT is to provide work force for low-risk clean-up tasks and they will always work under the direction of the Incident Commander. Specific incidents they would not be able to respond include chemical spills were response activities require chemical protection suits and/or advanced respiratory protection equipment.

In order to provide the SRT with the skills needed to be effective, the training will include:

Training in how to act at spill locations

Performing a drill in cooperation with the HAZMAT team and The Spill Response Team

Safety at incident locations

Spill recovery waste disposal

Training in the use of Spill Response Equipment (Appendix 8) is accomplished with on-the-job training.

5.3.3 Marine Spill Team (MST)

The MST is a special team with training and equipment (Appendix 8) or responding to a spill in coastal open waters near Thule AB.

The effectiveness of the MST is maintained by exercising the deployment of the spill recovery assets listed in Appendix 8 annually.

The MST will begin mobilizing immediately following a spill incident during the tanker off-load operation (in preparation for activation) or as requested by the Incident Commander for other spill situations when spills in excess of 50 gallons affect coastal host nation waters. Spills of less than 50 gallons will not require the full mobilization of the team. However, team assets such as boats and personnel will be used in order to recover spills of this scale using floating adsorbing pads. The MST mobilization point is the boat pier near bldg. 984 where assets will be pre-positioned for the tanker off-load operation. Recovered oil will be transferred to towable

Thule AB 20 8 July 2016 bladder tanks that will be taken to the shore for transfer to holding tanks. The MST has the capability to recover and store up to 12,000 gallons without outside assistance, subject to limitations posed by environmental factors such as wind and current. Peterson AFB will be contacted for assistance in case of an emergency that Thule AB is not equipped for or otherwise able to respond to.

5.4 Procedures for ERT alert and response

The Incident Commander or alternate is on duty at all times. The ERT is activated through the

Consolidated Service Center.

When notified about a spill incident by the CCC the Fire Department responds immediately to contain the incident and initiate the clean-up. Access to CCC is available at all times by radio or phone. Initial response time for a HAZMAT spill is 7 minutes on the main base. Full response time is 22 minutes on the main base.

The IC may request the activation of the Spill Response Team and/or the Marine Spill Team.

The activation of teams is coordinated by the CCC. The individual team members are activated by telephone or radio.

5.5 Notification of Spills

For all spill incidents, the IC and Chief of Environmental Engineering or alternates are notified by phone or tetra. For emergencies reported through the emergency dispatch (ext.: 911) the following roster of persons are notified by phone or radio.

TABLE 5.1

Key personnel Roster regarding spill response

Person/organization Office symbol Office Email Phone duty tetra number

Phone home

CCC Hilltop (service center)

GC/LGCM N/A

(servicecenter@gc.gl)

911 N/A N/A

Incident Commander

GC/AMF fireofficer@gc.gl 3249 88 3249 3149

GC Env.

Engineering

GC/EE environmental@gc.gl 2698 88 2698 2698

Civil Engineering 821 SPTS/CE 821sptscedistro@us.af.mil 3274 88 3274 3274 Chief of Safety 821 ABG/SE monique.wright.1@us.af.mil 2709 88 2709 3432 GC BCE GC/CE jpl@gc.gl 2723 88 2723 2723 GC Site Manager GC/CC sgp@gc.gl 3808 88 3808 3808

Subsequent notification of reportable and non-reportable spills will occur through email as described in chapter 6.2 and 6.3.

Thule AB 21 8 July 2016

5.6 Notification of IC, Installation Commander and local authorities

When notifying the Fire Department, the following information should be provided:

Name of individual reporting spill

Location of spill

Number of injured personnel and nature of injuries

Substance spilled

Amount spilled (estimated)

Rate substance currently leaking (estimated)

Time spill occurred (estimated)

Extent to which the spill has traveled

Any pertinent information (e.g. other potential hazards)

All notification of the Installation Commander will follow the chain of command and be initiated by 821 SPTS/CE.

The Danish Liaison Officer (DLO) serves as the official representative of Denmark, and the

Greenlandic Government at Thule Air Base. All notifications to the DLO and/or external offices must be accomplished by or coordinated with the Installation Commander prior to execution.

The role of the DLO is discussed further in section 6.4.

5.7 Assignment of responsibilities for making notifications

All permanent residents and seasonal contractors at Thule AB are obligated to react immediately, when a spill incident occurs and/or is first discovered. Specific obligations depend on the size of the spill and the capacity of the shop to perform an appropriate response on their own.

Small POL Spill (< 3 gallons):

If the spill is small and can be responded to by the shop personnel, actions to control and clean up the spill will be initiated. GC/EE and/or Service Call must immediately be notified and will verify that the spill has been cleaned up appropriately. If a spill kit is used in the spill response action, this must be properly disposed of in accordance with the Hazardous Waste

Management Plan or guidance provided by GC/EE.

Medium POL Spill (3 – 25 gallons):

If the shop personnel can respond the spill, the above guidelines shall be used.

If the spill cannot be handled or occurs in areas of concern, the personnel on site will notify the

Alarm Center ext.: 911

Thule AB 22 8 July 2016

Large POL Spill (> 25 gallons):

The personnel on site will notify the Alarm Center ext.: 911

When receiving a 911 call, the Consolidated Service Center is responsible for notifications as described in section 5.5

Non-POL HAZMAT or Hazardous Waste Spills of any size:

The personnel on site will notify the Service Center ext.: 911. Service Call may be contacted instead if there is no imminent risk to human health or the environment. When receiving a call, the Consolidated Service Center is responsible for notifications as described in section 5.5.

Sewage spill incidents

Sewage spills and releases to the storm water drainage system must be reported to the CCC.

There is no reportable limits for sewage spills in the Final Governing Standards. The

Consolidated Communication Center provides the dispatch to Service Call (ext 2111).

When the sewage spill/release incident is below 1000 gallons, the Consolidated

Communication Center immediately notify:

GC Utilities Facilities Maintenance (GC/OMUFM)

GC Environmental Engineering (GC/EE)

If the sewage spill/release incident is 1000 gallons or above, the Consolidated Communication

Center will also notify location and volume of the sewage spill/release by telephone or radio to:

GC Site Manager (GC/CC)

GC Base Civil Engineer (GC/CE)

GC Environmental Engineering (GC/EE)

Further notification procedures are given in section 6.2, 6.3 and 6.4

5.8 Surveillance procedures for early detection of spills

The 2-person principle is used during fuel transfer processes. One operator is located at the facility where the transfer process begins – and one operator is located at the facility where the transfer process ends. Both operators are in radio contact to ensure quick response and a complete stop if a leak occurs.

The Preventive Maintenance Program (PMP) calls for regular inspections and maintenance of all bulk quantity tanks, the fuel pipeline system, and valves. Monthly inspections include check of corrosion, damages and leaks (Appendix 10). During the annual tanker off-load operation pipelines are continuously patrolled.

Inspections of HAZMAT storage areas are performed by GC/EE.

Thule AB 23 8 July 2016

5.9 Critical Water and Natural resources

GC/EE must notify 21 CES/CEIE if a spill occurs in sensitive areas or an area with natural resources. All reporting must be coordinated with 821 SPTS/CE and the Installation

Commander. The Thule Defense Area has several areas of concern that must be protected in the event of a spill. A prioritized list is given below:

1 Lake Crescent (drinking water resource)

2 North Star Bay (coastal water)

3 Wolstenholme Fjord (coastal water)

4 North Star River

5 Streams, rivers and lakes

6 Locations that cannot be properly cleaned and reestablished

Among the lakes in the area, Lake Crescent especially must be protected from any pollution, as this lake is used as Thule AB’s supply of potable water.

The North Star Bay and Wolstenholme Fjord are very vulnerable areas in case of POL

(Petroleum, oil and lubricant) spills during the tanker operations, or release of POL elsewhere at Thule AB. A spill may result in potential damage to the arctic environment around the Thule

Defense Area.

The many streams and rivers flowing through the Thule Defense Area lead to coastal waters, therefore any spill in these streams and rivers will eventually end up in the coastal waters.

Soil and Vegetation: In high arctic areas, natural degrading of contaminated soils happens very slowly due to the harsh conditions. Therefore inaccessible locations such as mountainsides are areas of concern.

In general the best way to protect critical water and natural resources is to prevent spills from entering the Storm Water Drainage System. Best management practices for various activities are described in the Storm Water Management Plan.

5.10 Additional Emergency Assistance Organizations

Following a major peacetime accident involving POL and/or hazardous materials Thule AB may require outside assistance. Actions required may range from simple suppression to highly complex and time-consuming operations with international and/or political implications. It is recognized that response to accidents occurring outside the Thule Defense Area may also be required. Such responses must be coordinated through the Thule AB Danish Liaison Officer

(DLO) using appropriate Greenlandic and Danish official channels (Grønlands Kommando).

Further details of actions to be taken during major peacetime accidents, including base

Thule AB 24 8 July 2016 evacuation, are outlined in Thule AB COOP/CEMP 10-2 (Continuity of

Operations/Comprehensive Emergency Management Plan).

The Arctic council member nations have committed to mutual assistance in the Agreement on

Cooperation on Marine Oil Pollution, Preparedness and Response in the Arctic (http://arctic-council.org/eppr/agreement-on-cooperation-on-marine-oil-pollution-preparedness-and-response-in-the-arctic/). Member nations include the United States, Canada and

Denmark (including Greenland).

5.11 Cleanup procedure

The cleanup procedure includes:

Risk assessment

Stop the source

Spill confinement

Spill clean-up

Follow-up actions

When a spill occurs and/or is first discovered, the first step is to assess the risks that may affect human health, the environment and property. Safety is always put first. The spilled material is identified according to material safety data sheets (MSDS) and the quantity of the spill is determined.

If considered safe, the first priority is to stop source of the spill. This may simply involve turning a container upright, plugging a leak from a drum and transferring the liquid from the damaged drum to a new one, closing a valve, or bypassing a pipeline.

The next step is to limit the impact of a spill by blocking, diverting, or confining the spilled material. Contained absorbents including the PIG socks and booms

(http://www.newpig.com/pig/US/) are used to stop the flow of a liquid before it has a chance to contaminate a water source or enter a drain. Temporary earth dikes and trenches can be used to confine and/or direct liquids and minimize the spill area.

Once the spill is confined and the leak has been stopped, the incident is reassessed and a plan of action for implementing the spill cleanup is developed. Spills are commonly absorbed with granulate. PIG pillows and mat pads are other alternatives for absorbing the remainder of the spill. Unused absorbents are not hazardous. However once the absorbents are saturated with oils, solvents, etc., they are considered hazardous waste and are disposed of properly in accordance with the Hazardous Waste Management Plan.

If a spill occurs in a water resource Thule AB has PIG absorbent pillows that absorb only organic liquids (such as POL). For large spills in open waters the MST has boats, skimmers and a collection boom available (Appendix 8).

Thule AB 25 8 July 2016

Follow-up actions involve the documentation and verification for the remedial actions and preparation of required reports as described in sections 6.2 and 6.3. If required, further action will be governed by DoDI 4715.08 “Environmental Remediation for DoD Activities Overseas”.

5.12 Reuse and disposal of recovered substances and absorbent materials

Waste oil and fuel from spill incidents is disposed of at the K-plant waste oil tanks for incineration. Wastes containing a large fraction of water are accumulated in Intermediate Bulk

Containers, POL Water tanks at the tank farm or two portable 6000 gallon contingency tanks located at the DLA yard, as directed by Environmental Engineering. After passage through an oil/water separator the water fraction can typically be discharged into the North Star River. Any required analyses will be coordinated with Environmental Engineering, who must approve any discharge. The POL fraction will be incinerated at the K-Plant.

Snow with non-volatile contamination will be transferred to 55 gallon drums and treated as

POL water after melting.

Absorbent materials are disposed of as regulated waste when used for spill incidents, and are therefore disposed off via the DLA (BMC Disposition Services located in building no # 935) in accordance with the Hazardous Waste Management Plan.

Snow with volatile fuel contamination will be disposed of at the weathering bed located at Tank

Farm North. The weathering bed is constructed with non-permeable concrete. Mixtures of soil, snow and contamination will be disposed of at the soil disposal site.

Contaminated soil is disposed off at a protected area west of hangar 1 (bldg. #1090) and 2

(bldg. #1091). Here the soil is awaiting land farming projects. The disposal site is divided into

4 sections:

Section A is used for soil contaminated with volatiles such as diesel fuel or gas.

Section B is used for soil contaminated with non-volatile oil such as machine oil and sand from oil water separator sand traps.

Section C is used for soil contaminated with lubricants such as hydraulic oil, gear oil etc.

Section D is reserved for contingency storage of a large amount of soil.

The date and type of spill is noted and the pile identified with GPS coordinates in an inventory that is being maintained in GC Environmental Engineering. No disposal will occur without the approval of GC Environmental Engineering.

Thule AB 26 8 July 2016

Mixtures of soil and absorbent material will be disposed of at the soil disposal site if soil makes up 25% or more of the recovered material. If there is less than 25% soil it will be turned out via

DLA.

POL collected in a water resource such as North Star Bay or North Star River will be treated as POL water. For quantities of POL water exceeding the Oil Water Separator capacity for

Thule (estimated 10,000 gallons per year) the POL water will be held in available tank capacity until additional oil water separators can be employed or transport off-site can be arranged.

5.13 General health, safety and fire prevention precautions

The IC will normally assume point of contact and act as Incident Commander until the area is safe and will:

Relay grid coordinates for the incident site to the Consolidated Communications

Center (CCC)

Establish appropriate cordons

Establish Entry Control Points (ECP)

In case of fire, call additional firefighting equipment and position personnel and equipment UPWIND if possible

In case of fire, a report will be submitted IAW AFI 32-2001.

If and when more firefighting equipment is needed, the IC/AFCO will determine so upon arrival at the spill area.

Oil and water absorbent compound will be used to absorb the fuel and then be removed to a safe place. If foam is used, it must be cleaned up as soon as the hazardous condition is neutralized.

If there is no fire, and the spill is neutralized e.g. by covering with foam, Fire Protection's role is limited to standby actions. Fire fighting vehicles will not be used to remove or wash oil and hydraulic fluid spills. The operation will be given to the agency responsible for recovering and decontamination of the spill. Agency and time will be annotated in the CCC activity log (ALOG).

5.14 Public Affairs and releasing information

Public affairs including release of any information to the press in event of a spill must be accomplished by or coordinated with the Installation Commander prior to execution. 821

ABG/CCE will coordinate PA function with the 21 SW PA office.

Thule AB 27 8 July 2016

6 REPORTING SECTION

6.1 Recordkeeping

When emergency procedures are invoked either directly to GC/EE or via the Alarm Center

IAW section 5.7 it is the responsibility of GC/EE to file reports.

Files of all spills must be documented in the GC/EE office. When notified of a non-reportable spill the GC/EE office will issue a “Spill Memo”. The Chief of Environmental Engineering or alternate will approve the report. All reportable spills will be documented through CDRL reports by GC/EE.

Furthermore, recordings of all 911 calls are being filed in the ALOG (Activity Log) in the

Consolidated Service Center. The ALOG is stored electronically on GC LAN.

6.2 Non-Reportable Spills

GC Environmental Engineering is tasked to notify and report spill incidents to USAF. Upon discovering a spill incident the 821 SPTS/CE must be notified within 15 minutes via phone call.

If 821 SPTS is unavailable GC Environmental Engineering will call 821 ABG/CC and/or 821

ABG/CD until one of them is contacted.

For non-reportable POL spills (larger than 3 gallons), all substantial non-POL hazmat spills and sewage spills larger than 50 gallons a memo will be submitted to 821 SPTS/CE and 21

CES/CEIE by email. Furthermore, all incidents involving fuel products will also be submitted to

821 SPTS/LGF.

The report must be submitted as soon as the remedial actions have been verified by GC/EE and no more than 72 hours after notification has been received by GC/EE. If the remedial actions have not been completed or cannot be verified within 72 hours, the report must include an estimated completion date.

The Spill Memo will contain the following sections

Name of installation

Date and time of incident

Actual damage or potential threats to human life, property, and plant or animal life

Location of incident and the nature of the terrain (including GPS coordinates for spills larger than 3 gallons).

Cause of incident

Type and estimated amount of pollutant

Remedial action to remove pollution

Assistance required

Thule AB 28 8 July 2016

Estimated or actual completion date of remedial action

Anticipated or actual reaction by the news media and public to the incident

Additional documentation, e.g. MSDS information and pictures.

Completion of remedial actions will be verified and documented by GC/EE. For POL spills of less than 3 gallon and sewage spill of less than 50 gallons, no memorandum will be prepared.

Instead GC/EE will keep a record of these which is available upon request.

6.3 Reportable Spills

GC Environmental Engineering is tasked to notify and report spill incidents to USAF. Upon discovering a spill incident the 821 SPTS/CE must be notified within 15 minutes via phone call.

If 821 SPTS/CE is unavailable, GC Environmental Engineering will call 821 SPTS/CC and/or

821 ABG/CD until one of them is contacted.

A spill is considered a reportable environmental incident if one of the following conditions is fulfilled:

The spill exceeds the reportable quantity (110 gallons for POL products). The reportable quantity for other chemicals is indicated in the Final Governing Standards (FGS), Appendix

1, Table AP1.T4

A spill occurs inside Thule AB and cannot be contained within any required berm or secondary containment

A water resource has been polluted

The IC determines that the spill is significant

A wastewater spill in excess of 1000 gallons

GC/EE will investigate and report in the same format as the memo requirements for non-reportable spills. Further, for reportable spills, GC/EE will provide data required by

Enforcement Actions, Spills and Inspections (EASI) database (URL:

https://www.my.af.mil/accgeoprod4/easi/). This shall be prepared within 18 hours of discovering the reportable incident. Information provided shall be fully coordinated with 821

ABG before being entered into EASI.

Furthermore, GC/EE will report spills of DLA-E owned fuel to DLA-E. Reports will be submitted within 24 hours of a reportable spill. Reports will be submitted using the format in AFI 23-201, Attachment 15.

Thule AB 29 8 July 2016

6.4 Notification of Host Country Authorities

When a significant spill occurs, inside the Thule Defense Area, which cannot be contained within the installation boundaries the Greenlandic authorities must be notified immediately.

Furthermore, the installation commander and the Environmental Executive Agent

(daniel.rodriguez@us.af.mil, DSN: 834-7305 or 1-719-556-7305) must be notified immediately.

A significant spill is defined as an uncontained release to the land or water in excess of any of the…