Appendix G - Wastewater Slug Prevention Plan.pdf

Contract No. FA2523-15-C-0001

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A073 WASTEWATER SLUG PREVENTION PLAN

Thule Air Base, Greenland

FINAL

A073 Wastewater Slug Prevention Plan

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INSTALLATION IMPLEMENTING INSTRUCTION

Date: This plan is current as of 9 June 2022.

Requiring Office: 21 CES/CEIE

OPR: Vectrus Services, Environmental Engineering (VS/EE).

Subject: Wastewater Slug Prevention Plan (WSPP), Base Maintenance

Contractor (BMC) Deliverable A073.

Reference: Final Governing Standards (FGS) for Greenland, C4.3.2.1.6

Purpose: To implement a Wastewater Slug Prevention Plan for Thule Air Base

(Thule AB), Greenland.

Discussion: The FGS use the term ‘slug’ to reference ‘spills and batch discharges’

(FGS 4.3.2.1.6). This plan is about the prevention of spills and unauthorized batch discharges into the Thule AB’s wastewater distribution system.

This plan lists best management practices for the prevention of slugs entering the Thule AB wastewater distribution system. Implementation of the plan will 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 on wastewater slug prevention.

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

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TABLE OF CONTENTS

1 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

1.2 Regulatory Overview

2 ORGANIZATIONAL ROLES AND RESPONSIBILITIES

2.1 Installation Commander, 821 ABG/CC

2.2 Danish Liaison Officer, DLO

2.3 Base Maintenance Contractor (BMC), Vectrus Services (VS)

3 POTENTIAL SPILLS AND BATCH DISCHARGES (SLUGS)

3.1 Introduction

3.2 Facility Layout of the Sanitary Wastewater System (SWWS)

3.3 Discharge Practices

3.4 Storage of Chemicals, Toxic Organic Pollutants and Solvents

3.5 Floor Drains

3.6 Conclusion

4 SLUG MANAGEMENT AND OPERATIONS

4.1 Discharge Practice and Non-routine Batch Discharges

4.2 Buildings, Containment Structures and Equipment

4.3 Spill Emergency Response

4.4 Employee Training

4.5 Sludge Disposal

5 EFFLUENT MONITORING

6 WATER POLLUTION COMPLAINTS

APPENDIX 1: DEFINITIONS AND TERMS

APPENDIX 2: SANITARY WASTEWATER SYSTEM (SWWS)

APPENDIX 3: NON-ROUTINE DISCHARGE OF WASTEWATER

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1 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

Title: The title of this document is “Wastewater Slug Prevention Plan”. The acronym WSPP is used throughout the document.

Classification: The document is unclassified.

Responsibilities: Vectrus Services, Environmental Engineering (VS/EE) is the office of primary responsibility (OPR) for establishing, implementing and maintaining the WSPP. The instructions given in the WSPP are applicable to all organizations and tenant units at Thule AB. Organizations and tenant units are authorized to extract and reproduce those sections of the WSPP that are essential in the planning and preparation of supporting documents and reports.

Reviews/changes: The WSPP will be updated within 30 days of changes occurring. Any review comments received will be incorporated in the final version of the plan within 30 days.

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.

1.2 Regulatory Overview

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

Thule AB: Final Governing Standards, Chapter 4

The Environmental Safety and Occupational Health Council now called the EMS Cross-Functional Team (CFT) functions as the primary executive steering group for environmental compliance, conservation and pollution prevention programs.

The EMS CFT has four scheduled meetings annually and is chaired by 821 ABG/CC or designated Government representative.

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2 ORGANIZATIONAL ROLES AND RESPONSIBILITIES

In order to ensure that spills and batch discharges (slugs) are handled in an environmentally correct manner, it is important that all personnel are fully aware of their responsibilities in the

WSPP.

2.1 Installation Commander, 821 ABG/CC

The Installation Commander has the overall responsibility for wastewater slug prevention at Thule AB. The responsibility is implemented through the base EMS CFT, of which the Installation Commander is the chairperson.

2.2 Danish Liaison Officer, DLO

The Danish Liaison Officer serves as the official representative of the Danish and the Greenlandic governments concerning environmental issues at Thule AB.

2.3 Base Maintenance Contractor (BMC), Vectrus Services (VS)

The responsibilities of the BMC include but are not limited to

• Implementation and update of the WSPP.

• Batch discharges of trucked wastewater.

• Inspection and maintenance of the SWWS, i.e. the pipes and tank systems.

• Inspection and maintenance of the domestic wastewater treatment system (DWTS), i.e. the wastewater outlet to host nation waters in Bldg. 984.

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3 POTENTIAL SPILLS AND BATCH DISCHARGES (SLUGS)

3.1 Introduction

A plan for spills and batch discharges is required by C4.3.2.1.6 of the FGS. Activities or installations that have a significant potential for spills or batch discharges (into the wastewater system) will develop a slug prevention plan. Each plan must contain the following minimum requirements:

• Description of discharge practices, including non-routine batch discharges.

• Description of stored chemicals.

• Plan for immediately notifying the DWTS of slug discharges and discharges that violate prohibitions under this section, including procedures for subsequent written notification within five days.

• Necessary practices to prevent accidental spills. This would include proper inspection and maintenance of storage areas, handling and transfer of materials, loading and unloading operations, control of plant site runoff, and worker training.

• Proper procedures for building containment structures or equipment.

• Necessary measures to control toxic organic pollutants and solvents.

• Proper procedures and equipment for emergency response, and any subsequent plans necessary to limit damage suffered by the treatment plant or the environment.

It should be noted that spills from the SWWS, e.g. due to pipe failures or blockages, are not part of the scope of this plan. Reference is made to A070 Spill Prevention and Response Plan.

Further, Thule AB does not have a wastewater treatment plant and there are no chemical or biological treatment systems to protect. This does not make slug prevention less of a priority as any substance entering the wastewater distribution system is destined for direct discharge into the host nation waters. Compliance with FGS prohibitions on hazardous (FGS C4.3.1.2.3 & C4.3.2.1.4), oil and grease (FGS C4.3.2.1.5) discharges can only be met through effective slug prevention.

Thule AB does not have any categorical industrial dischargers (direct or indirect) as defined in FGS C4.3.3, i.e. electroplating activities.

3.2 Facility Layout of the Sanitary Wastewater System (SWWS)

Thule AB is situated in an area with a very low population density, approximately 65 miles from the nearest village. The climate is described as arctic desert.

There are three approved point sources for direct discharge of wastewater. The primary discharge point is Bldg. 984 located on the pier at the main base. At 12 SWS, wastewater is directed to a septic tank in Bldg. 4002, from where it is dispersed over a mountainside. A separate discharge point is used for the limited amount of wastewater from Bldg. 4016 due to the distance to Bldg.

4002.

Direct discharges from any other location or facility must be approved by VS Environmental Engineering using the form provided in Appendix 3. The FGS standards will be applied to assess if an action is permissible.

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Due to very low temperatures, the SWWS on base consists of insulated pipes located above ground with heat tracing. There are two main pump stations (located in Bldgs. 364 and 1404) to ensure the proper flow of wastewater. However, the wastewater can mostly run gravitationally through the pipes to Bldg. 984, where it is discharged through an underwater pipeline into the North Star Bay.

Wastewater from Bldgs. 107, 555, 605, 1201, 1307, 1951, 1971 and 1824 (DET-1) is collected in a tank. A special truck collects the contents. The contents are discharged into the SWWS at Bldg. 984.

The majority of water directed to the SWWS originates from household sources like showers, washrooms, laundry rooms and kitchens. The only direct drainage from floors outside the dormitories are in Bldgs. 107, 118, 236, 1411 and 4016. In all other situations, the water is pumped or manually poured into the SWWS.

No storm water leads to the SWWS.

Consult Appendix 2 for a diagram of the SWWS on the main base.

3.3 Discharge Practices

The main discharges made to the SWWS are what can be expected for a population of approximately 600 people without any major industrial contributors.

Discharges of sanitary wastewater collected by truck Some of the wastewater is transported by truck, as mentioned in section 3.2.

Water from boilers and heating system On main base, both high-pressure steam and hot water systems are used to supply heat. Heat is produced at four different locations: Bldgs. 1391, 241, 341 and 1401. Due to high levels of impurities in boiler water, it is necessary to replace the water and discharge to the SWWS. A number of chemical additives intended for corrosion control in the boilers are therefore discharged into the SWWS.

Further heating is produced on low-pressure systems at multiple decentralized locations. From those places, only small amounts of boiler water are expected to be discharged to the SWWS – primarily in case of maintenance of the systems.

Blowdown water from boilers does not contain any regulated pollutants and is discharged to host nation water bodies.

These activities are considered routine and permitted batch discharges.

Water from washing of aircraft/vehicles Aircraft are not washed at Thule AB, except for the small helicopter operated by Air Greenland.

The helicopter is washed in HG-4 (Bldg. 606), where the water is directed through an oil/water separator to the SWWS.

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The following facilities have ground vehicle washing ramps with oil/water separators that discharge into the SWWS: Bldgs. 580, 622, 605 and 1408. From there the water is discharged through the sewage system directly to the North Star Bay.

Water from the laundry shop In the laundry shop, Bldg. 237, clothes are rinsed or washed. The rinsing process is designated as a dry-cleaning process. Methylene chloride was previously used, but has been substituted with Hydroclene Fluid. Residuals from the rinsing process are required to be treated as hazardous waste and collected for disposal to ensure nothing is introduced to the SWWS.

Conventional detergents are used for the washing process. Water from the washing process is led to the SWWS directly from the machines. In case of spillage, the water will be recovered in a drain, from which the water will be pumped to the SWWS.

Water from parts washers There is only one existing parts washer at Thule AB. It is located in Bldg. 580 (Vehicle Maintenance).This washer does not use solvents.

The water from the parts washer in Bldg. 580 is directed to an oil/water separator and from there to the SWWS. Any remaining slug is transferred to storage drums.

Discharge of water from swimming pool During the spring of 2016, an endless pool was installed at the Sport and Fitness Center in Bldg.

608. The endless pool is emptied out and cleaned every second month. The volume of water introduced to the SWWS is estimated to be 12 m3. The concentration of chlorine is 1.5 ppm (which is about five times the concentration in drinking water) and not considered a hazardous. These discharges are considered routine and permitted batch discharges.

Intrusion of Storm Water Although the SWWS is segregated from the storm water drainage system, the division might be compromised. The pipes of the SWWS are situated in the ditches and culverts that form the storm water drainage system. As the segregation between the SWWS and the storm water drainage system is the guarantee against unintended pollutants that have been washed off by the surface water, it is important to keep the SWWS without leaks. This task is performed by the BMC.

3.4 Storage of Chemicals, Toxic Organic Pollutants and Solvents

Handling and storage of hazardous materials are at Thule AB managed by the Hazardous Material Management Plan. Major storages are kept in Bldgs. 555, 580, 605, 629, 801, 1391, and 4002.

Handling and storage of hazardous waste at Thule AB is managed by the Hazardous Waste Management Plan (A068). Major storages are kept in Bldgs. 604, 935 and 937.

The potential of accidental spillage of chemicals that might contaminate the SWWS is where sumps and floor drains are leading directly to the SWWS. In all other cases, the chemicals have to be manually poured or pumped into the drains. Temporary drain covers are used to prevent accidental chemical spills from reaching the SWWS. The covers can be removed for floor cleaning and other activities requiring use of the drain.

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3.5 Floor Drains

As mentioned in section 3.2, the only direct drainages into the SWWS from floors outside the dormitories are in Bldgs. 107, 118, 236, 1411 and 4016. Special interest has to be made to these locations, as they are the only places where accidental release of chemicals can occur. Temporary drain covers are used to prevent accidental chemical spills from reaching the SWWS. The covers can be removed for floor cleaning and other activities requiring use of the drain.

Bldg. 118 – Hospital There are only floor drains from showers – for both staff and patients.

All decontamination incidents are handled by the Fire Department in an outdoor mobile emergency system. The system collects all decontamination water for hazardous waste characterization.

As a part of the Environmental Awareness Program at Thule AB (newcomer briefings), all personnel are informed to return expired medical supplies to the hospital or DLA Disposition Services.

All X-rays are performed with digital computer technology leaving no hazardous waste like mercury, silver, formaldehyde etc.

Bldg. 107 – Dundas Buffet Restaurant In the kitchen in Bldg. 107 several floor drains are installed. From the floor drains, water is directed to a grease trap, where grease and other low-density liquids with low solubility in water can be withheld. The water is subsequently discharged to the SWWS.

Bldg. 4016 – Power Plant, J-site Storage of petroleum, oil and lubricants (POL), and hazardous materials at the auxiliary power plant at J-site is located in a room with a sump drained directly to the SWWS. The waste is stored in four 55-gallon steel and plastic drums situated horizontally and with secondary containment to collect spillage of chemicals.

Bldg. 236 – TOW Club Water discharged to the SWWS through the floor drains in the kitchen is also led through a grease interceptor.

Bldg. 1411 – Water Treatment Facility Raw water is treated to become potable in Bldg. 1411. Various sources of wastewater – including reject water from the filtration process and wastewater from the electrolytic conversion of chloride to active chlorine (hypochlorite) – are collected in a floor drained and led to a sump. The wastewater is subsequently pumped into the SWWS. Limited amounts of hazardous chemical are stored here – including hydrochloric acid. Appropriate spill kits and containment is maintained.

3.6 Conclusion

The SWWS at Thule AB is situated above the ground. At the same time, it is totally segregated from the storm water drainage system. Hereby eliminating that outdoor spills of chemicals, oil and other contaminants run off into the SWWS – except for the possibility that it might enter through a leakage during the short period, where the storm drains are flooded and thereby partly submerging the SWWS.

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4 SLUG MANAGEMENT AND OPERATIONS

Based on the analyses in section 3, the following management and operation plan is established.

4.1 Discharge Practice and Non-routine Batch Discharges

The main risk of damaging the SWWS or the recipient comes from the different routine discharges and non-routine batch discharges.

Discharge practice for trucked and hauled waste According to the FGS, C4.3.2.1.7: “The discharge of trucked and hauled waste into the DWTS, except at locations specified by the DWTS operator is prohibited”.

Although there is no wastewater treatment plant on Thule AB (and therefore no DWTS operator), the only location approved for the discharge of trucked and hauled waste is Bldg. 984.

Discharge practice for trucked sanitary wastewater As mentioned in paragraph 3.2, an amount of the collected wastewater is not transported by the SWWS but by truck to Bldg. 984, where it is discharged into the SWWS by the grit system. The same procedure is used for materials collected from septic tanks.

There is no limitation on the amount of trucked wastewater and no record has to be made, as long as the discharge is measured as a part of the ongoing registration of wastewater.

Intentional non-routine batch discharge Intentional non-routine batch discharges to the SWWS not specifically approved by this plan (i.e.

from heating production IAW section 3.3) must be approved by VS Environmental Engineering.

Appendix 3 has a suggested format for the approval.

Spills In areas with a floor drain and storage of hazardous substances, the rules outlined in the Spill Prevention and Response Plan (A070) have to be observed. Temporary drain covers are used when chemicals may spill. The covers can be removed for floor cleaning and other activities requiring use of the drain.

In some areas, water from floor drains is pumped to the SWWS. In case a spill occur during pump operation, the pump must be stopped immediately and spill response initiated.

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4.2 Buildings, Containment Structures and Equipment

Planning of new building, containment structures and equipment When planning a new building, containment structures and equipment, it is essential to ensure no spill is directed to the SWWS. The measures are:

• To plan buildings for storage of pollutants in a way with no direct outlet to the SWWS.

• To locate showers, toilets and other drains in building areas, where no pollutants are stored.

• To establish secondary containment for pollutants stored in areas with floor drains.

• To secure floor drains by installing a pump system, that can be manually stopped in case of an accident.

To secure that a proper measure has been chosen, all projects have to be reviewed by VS Environmental Engineering.

Inspection and Maintenance of the SWWS Inspection and maintenance of the SWWS is performed by the VS Utilities Facilities Maintenance (VS/OMUFM) section of the BMC.

The maintenance of the SWWS is important as the segregation between the SWWS and the storm water drainage system is a major part of the safety measures against pollution of the SWWS with spilled materials.

Oil/water Separators The discharge of petroleum oil, non-biodegradable cutting oil, and products of mineral oil origin is prohibited. In places where oil is removed from objects with water and soap, e.g. where cars are washed, an oil/water separator system has been installed to withhold the oil and non-emulsifying soap is applied for the washing process.

VS/OMUFM is responsible for the BMC maintenance of the oil/water separators.

Maintenance of oil water separators involves draining them and cleaning them. The drained liquid is collected by a mud pump and left for evaporation on a weathering bed in order to avoid the discharge of a non-compliant slug. The weathering bed is located near the land farm area in the western part of the main base area. The bed consists of an earth dike with a liner to protect the surroundings from leaking. A project has been programmed to replace the current dike with an improved concrete structure.

If excessive amounts of oily solid and semi-solid sludge is present in the oil water separator it will be disposed of via the DLA Disposition Services.

Sand/Grease Traps The discharge of solid or viscous pollutants that might obstruct the SWWS is prohibited.

VS/OMUFM is responsible for the BMC maintenance of the sand/grease separators.

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Cross Connections Cross connections between the SWWS and the drinking water system is a problem related to drinking water and associated vulnerability assessments and sanitary surveys. It is not part of the scope of this plan.

4.3 Spill Emergency Response

If an unintentional discharge of a hazardous slug occurs, it is required to immediately notify the BMC Environmental Engineering section (ext. 2224/2698/3319/3650) or the alarm center if no contact can be made with BMC environmental personnel.

Detailed Emergency Response procedures are included in the Spill Prevention and Response Plan (A070). It should be noted that spills entering the SWWS are significant, because they can only be recovered with great difficulty and will generally end up in the host nation waters.

4.4 Employee Training

BMC personnel and non-BMC employees who handle hazardous substances or perform activities that could contribute to spill or batch discharges should be trained in appropriate Best Management Practices by the individual shop. Such training should emphasize pollution prevention, awareness of possible pollution sources and local measures to contain spillage in a way that makes it possible to contain the spillage, e.g. how to stop pumps that discharges water from floors into the SWWS.

VS Environmental Engineering training programs include:

• Hazardous Waste Handling

• Chemical Hazard Communication

• Spill Response Training

• Storm Water Awareness

Training is based on classroom attendees.

4.5 Sludge Disposal

A wastewater treatment plant is not been installed at Thule AB, therefore, no wastewater treatment sludge is produced.

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5 EFFLUENT MONITORING

The daily volume of direct effluent discharge from Bldg. 984 to North Star Bay is monitored by an open channel flow meter based on standardized Venturi flume principles. A new flow meter was installed in January 2022.

The daily volume of direct effluent discharge from Bldg. 4002 (12 SWS) to Wolsteinholme Fjord is monitored by an on-line flow meter based on inductive measure principles. The flow meter was installed in summer 2012.

IAW FGS, Table C4.T2, sampling of effluent is performed monthly at Bldg. 984 and 4002. Grab samples are collected manually.

IAW FGS, Paragraph C4.3.1.3 the monthly collected effluent samples are tested for conventional pollutants as pH, Total Suspended Solids (TSS) and Biochemical Oxygen Demand (BOD5).

IAW FGS, Paragraph C4.3.1.4 the records on date, time and exact place of sampling and testing, analyst, test results, procedures and daily volume are retained for at least 3 years.

The outlet at Bldg. 4016 produces less than 1000 gallons of wastewater per month and is therefore exempt from effluent monitoring IAW FGS, Table C4.T2.

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6 WATER POLLUTION COMPLAINTS

In general, USAF remains current with Greenland environmental activities and regulations IAW Performance Work Statement, paragraphs 3.18.20 and 3.18.20.1

All official environmental correspondence sent to organizations outside of the 21 SW is approved by 821 ABG/CC and 21 CES/CEIE prior to release. In addition, copies of all official incoming environmental correspondence are forwarded to 821 ABG/CC and 21 CES/CEIE within five days of receipt.

IAW FGS, Paragraph C4.3.1.5 and C4.3.2.2, water pollution complaints from individuals or host nation water pollution control authorities are investigated, involving the Environmental Executive Agent, as appropriate.

All correspondence and investigations are documented and records are retained for 10 years. So far, no complaints have been received.

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APPENDICES

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APPENDIX 1: DEFINITIONS AND TERMS

Thule AB

Thule Air Base

DWTS Domestic Wastewater Treatment System

Any DoD or host nation facility designed to treat wastewater before discharging to waters of the host nation and in which the majority of such wastewater is made of domestic sewage.

SWWS Sanitary Wastewater System; defined as the existing piping system for wastewater on Thule AB

Seasonal Contractor A company awarded a contract by the government for construction or repair projects. Usually projects performed during the summer season at Thule AB.

Tenant Units These are other organizations assigned to Thule Air Base, which occupy some base facilities.

Process Wastewater Any water originated from manufacturing processes – including water coming from military installations

New Sources A source built or substantially modified on or after 1 October 1994, that directly or indirectly discharges pollutants to the wastewater system

Substantial Modification Any modification to a facility the cost of which exceeds $1,000,000, regardless of the funding source

Waters of the Host Nation Surface waters including the territorial seas recognized under customary international law

Hazardous Substances

A substance that is defined as either hazardous materials or hazardous waste in accordance with Appendix 1 of the

FGS

EMS CFT

EMS Cross-Functional Team (CFT)

Facility Manager An individual appointed to a facility/building whose primary responsibility is to ensure the facility is kept in a good state of repair. This includes ice and snow removal in front of doorways, stairways, ramps etc. during the winter.

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APPENDIX 2: SANITARY WASTEWATER SYSTEM (SWWS)

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APPENDIX 3: NON-ROUTINE DISCHARGE OF WASTEWATER

NON-ROUTINE DISCHARGE OF WASTEWATER

Identification of discharge

Date of discharge:

Completion date:

Location:

Recipient:

Amount of discharge:

Point of contact:

Date Signature

Approval by VS Environmental Engineering

Justification:

Containment action(s):

Root cause analysis:

Corrective action(s):

Approver:

Date Signature