1 J.2a-N254 Permits.pdf

RECORD OF ENVIRONMENTAL CONSIDERATION

Project Name: Permit 24P027 N254 Reliability of HVAC and UPS Systems at Agency Telecom Gateway

1. Sponsoring Entity: Roman Reyes – JCE

2. Description and location of proposed action:

This project involves the removal and replacement of rooftop HVAC units on Building N254. The specific Scope of Work includes the following:

The Base Bid includes the removal and replacement of roof top HVAC units, as well as related controls and ductwork. Additionally, it includes the installation of structural support members for roof top units and ductwork.

Bid Option 1 includes the installation of structural support members for uninterruptible power supply (UPS) systems and battery cabinets. Also, it includes the removal and replacement of UPS and batteries, as well as the removal and reinstallation of existing battery cabinets.

Bid Option 2 includes the installation of an exterior staircase.

Bid Option 3 includes the removal and replacement of existing battery cabinets with new battery cabinets.

Activities associated with Permit 24P027 N254 Reliability of HVAC and UPS Systems at Agency Telecom Gateway will comply with all terms and conditions stipulated in the environmental checklist and project-specific health, safety, and environmental requirements, permit requirements, applicable safety and environmental standards and procedures, and all applicable federal, state, and local regulations. As such, the proposed action is not expected to result in any individually or cumulatively significant effects on public health, safety, or the environment.

3. Anticipated date and/or duration of proposed action: 10/1/2025 – 9/30/2026

4. It has been determined that the above action (CHOOSE ONE):

Is exempt from NEPA requirements under the provisions of (cite superseding law):

Is adequately covered in an existing environmental document (cite document):

Fits within a class of actions eligible for categorical exclusion (CatEx), as listed in 14 CFR

(CHOOSE ONE):

§1216.304 (d)(1), Administrative Activities:

i. Personnel actions, organizational changes, and procurement of routine goods and services.

ii. Issuing procedural rules, manuals, directives, and requirements.

iii. Program budget proposals, disbursements, and transfer or reprogramming of funds.

iv. Preparing documents, including design and feasibility studies, analytical supply and demand studies, reports and recommendations, master and strategic plans, and other advisory documents.

v. Information-gathering exercises, such as inventories, audits, and studies.

vi. Preparing and disseminating information, including document mailings, publications, classroom materials, conferences, speaking engagements, Web sites, and other educational/informational activities.

vii. Software development, data analysis, and/or testing, including computer modeling.

viii. Interpretations, amendments, and modifications to contracts, grants, or other awards.

ix. Field studies, including water sampling, monitoring wells, cultural resources surveys, biological surveys, geologic surveys, modeling or simulations, routine data collection and analysis, and/or temporary equipment.

§1216.304 (d)(2), Operations and Management Activities:

i. Routine maintenance, minor construction or rehabilitation, minor demolition, minor modification, minor repair, and continuing or altered operations at, or of, existing NASA or NASA-funded or -approved facilities and equipment, such as buildings, roads, grounds, utilities, communication systems, and ground support systems (e.g., space tracking and data systems). This includes routine operations such as security, safety, and environmental services.

ii. Installing or removing equipment, including component parts, at existing Government or private facilities.

iii. Contributing equipment, software, technical advice, exchange of data, and consulting with other agencies and public and private entities, where such assistance does not control a receiving entity's program, project, or activity.

iv. NASA ceremonies, commemorative events, and memorial services.

v. Routine packaging, labeling, storage, transportation, and disposal of materials and wastes, in accordance with applicable Federal, State, Tribal, or local laws or requirements.

• Examples include, but are not limited to: hazardous, non-hazardous, and other regulated materials and wastes.

vi. Habitat and species management activities conducted within the boundaries of NASA controlled properties in accordance with applicable Federal, State, or local requirements (REC required).

• Examples include but are not limited to restoration of unique or critical habitat; thinning or brush control to improve growth of natural habitat, reduce invasive species, or to reduce fire hazard; prescribed burning to reduce natural fuel build-up, reduce invasive species, or improve native plant vigor; planting appropriate vegetation, which does not include noxious weeds or invasive plants; or wildlife management activities.

vii. Small-scale, short-term cleanup actions under the Resource Conservation and Recovery Act or other authorities, to reduce risk to human health or the environment from the release or imminent and substantial threat of release of a hazardous substance other than high-level radioactive waste and spent nuclear fuel, including treatment (such as incineration, encapsulation, physical or chemical separation, and compaction), recovery, storage, or disposal of wastes at existing facilities currently handling the type of waste involved in the action.

viii. Replacement of existing energy sources with alternative or renewable energy sources that comply with existing permit conditions.

ix. Routine maintenance, repair, and operation of vessels (including unmanned autonomous surface vessels), aircraft (including unmanned aircraft systems), overland/surface transportation vehicles, and other transportation systems as applicable.

• Examples include but are not limited to: transportation or relocation of NASA equipment and hardware by barge, aircraft or surface transportation system (e.g., tractor trailer or railroad); retrieval of spent solid rocket boosters by vessel;

repair or overhaul of vessel, aircraft or surface transportation systems that do not result in a change in the environmental impacts of their normal operation.

§1216.304 (d)(3) Research, Development, and Science Activities:

i. Research, development, and testing in compliance with all applicable Federal, federally recognized Indian tribe, State, and/or local law or requirements and Executive orders. This includes the research, development, and testing of scientific instruments proposed for use on spacecraft, aircraft (including unmanned aircraft systems), sounding rockets, balloons, laboratories, watercraft, or other outdoor activities.

ii. Use of small quantities of radioactive materials used for instrument detectors, calibration, and other purposes. Materials must be licensed, as required, and properly contained and shielded. Materials may be associated with the proposed use on spacecraft, aircraft (including unmanned aircraft systems), sounding rockets, balloons, laboratories, watercraft, or other outdoor activities.

iii. Use of lasers for research and development, scientific instruments and measurements, and distance and ranging, where such use meets all applicable Federal, State, Tribal, or local laws or requirements, and Executive Orders.

This includes lasers associated with spacecraft, aircraft (including unmanned aircraft systems), sounding rockets, balloons, laboratories, watercraft, or other outdoor activities.

iv. Use of non-space nuclear system payloads on various platforms (e.g., launch vehicle, sounding rocket, scientific balloon, and aircraft) (REC required).

v. Return of samples from solar system bodies (e.g., asteroids, comets, planets, dwarf planets, and planetary moons) to Earth when categorized as an Unrestricted Earth Return. NASA defines this activity as collecting extraterrestrial materials from solar system bodies, deemed by scientific opinion to have no indigenous life forms, and returning those samples to Earth (REC required).

§1216.304 (d)(4) Real and Personal Property Activities:

i. Acquisition, transfer, or disposal of any personal property, or personal property rights or interests.

ii. Granting or accepting easements, leases, licenses, rights-of-entry, and permits to use NASA property, or any non-NASA property, for activities that would be categorically excluded in accordance with this section. (REC required).

iii. Transfer or disposal of real property, property rights, or interests if a resulting change in use is a use that would be categorically excluded under this section (REC required).

iv. Transferring real property administrative control to another Federal agency, including the return of public domain lands to the Department of the Interior (DOI) or other Federal agencies, and reporting of property as excess and surplus to the General Services Administration (GSA) for disposal, when the agency receiving administrative control (or GSA, following receipt of a report of excess) shall complete any necessary NEPA review prior to any change in land use (REC required).

v. Acquisition of real property (including facilities) where the land use will not change substantially (REC required).

vi. Change in the facility status of real property assets (e.g., active or inactive).

vii. Reductions, realignments, or relocation of personnel into existing federally owned or commercially leased space that does not involve a substantial change affecting the supporting infrastructure (e.g., no increase in vehicular traffic beyond the capacity of the supporting road network to accommodate such an increase).

§1216.304 (d)(5) Aircraft and Airfield Activities:

i. Periodic aircraft (including unmanned aircraft systems) flight activities, including training and research and development, which are routine and comply with applicable Federal, State, Tribal, or local laws or requirements, and Executive Orders.

ii. Relocation of similar aircraft (including unmanned aircraft systems) not resulting in a substantial increase in total flying hours, number of aircraft operations, operational parameters (e.g., noise), or permanent personnel or logistics support requirements at the receiving installation (REC required).

Does not involve special circumstances that preclude the use of a CatEx, such as:

1) A reasonable likelihood of having (individually or cumulatively) significant impacts on public health, safety, or the environment.

2) A potential to impose uncertain or unique environmental risks.

3) A significantly greater scope or size than is normal for this category of action.

4) A reasonable likelihood of violating Federal, federally recognized

5) Indian tribe, State, and/or local law or requirements imposed for the protection of the environment.

6) A reasonable likelihood of having environmentally controversial impacts on the quality of the environment.

7) A potential to adversely affect environmentally sensitive resources, such as, but not limited to, federally listed threatened or endangered species, their designated critical habitat, wilderness areas, floodplains, wetlands, aquifer recharge areas, coastal zones, wild and scenic rivers, and significant fish or wildlife habitat, unless the impact has been resolved through another environmental review process; the Clean Water Act (CWA), the Coastal Zone Management Act (CZMA).

8) A potential to adversely affect known national natural landmarks, or cultural or historic resources, including, but not limited to, property listed on or eligible for the National Register of Historic Places, unless the impact has been resolved through another environmental review process; e.g., the National Historic Preservation Act (NHPA).

Does not involve an action normally requiring an EA, such as:

1) Altering the ongoing operations at a NASA Center where the significance of the environmental effect(s) is unknown..

2) Construction or modifications of facilities that represent a major change to an existing master plan and could result in a change in the environmental effect(s).

3) Actions that are expected to result in major changes to established land use.

4) Launching a spacecraft containing a space nuclear system. Space nuclear systems include radioisotope power systems, such as radioisotope thermoelectric generators and radioisotope heater units, and fission systems used for surface power and spacecraft propulsion.

Does not involve an action normally requiring an EIS, such as:

1) Development and operation of new NASA-developed launch vehicles or space transportation systems.

2) Management, including recovery, transport, and curation, of sample returns to Earth from solar system bodies (such as asteroids, comets, planets, dwarf planets, and planetary moons) that would receive a Restricted Earth Return categorization.

NASA requires such a mission to include additional measures to ensure any potential indigenous life form would be contained so it could not adversely impact humans or Earth’s environment.

3) Substantial construction projects expected to result in significant effect(s) on the quality of the human and natural environment, when such construction and its effects are not within the scope of an existing master plan.

Has not been segmented to meet the definition of a CatEx (e.g. the project is not related to other actions with individually or cumulatively significant impacts).

Does not conflict with the U.S. EPA’s June 9, 1989 Record of Decision for the Middlefield-Ellis-Whisman area (the “MEW ROD”), or the modified MEW RODs of September 1990 and April 1996.

Does not conflict with U.S. Navy remediation, monitoring wells, or treatment systems (e.g. landfill caps).

5. Follow-up Actions

Asbestos samples Lead samples Air Quality Permit Industrial Waste Water Permit Hazardous Waste Generation Permit Hazardous Materials Storage Permit Well (Excavation) Permit Storm Water Permit Stream Alteration Permit CWA Section 401/404 Permit Floodplain (E.O. 11988) Coordination

Coastal Zone Management Act Coordination FESA/ESA Consultation Section 106 Consultation Noise Monitoring/Assessment Tribal Government Consultation (EO 13132) Environmental Health/Safety Effects on children

(EO 13045) Coordination Environmental Justice (EO 12898) Coordination International (EO 12114) Coordination Sustainability (EO 13514) Coordination Other:

I have reviewed the information contained herein and have verified that it is accurate and complete.

NEPA Program Manager:

Signature:

Date:

Andres Estrada

Digitally signed by Andres Estrada Date: 2024.07.01 09:03:57 -07'00'

Environmental Permit Requirements for:

Permit 24P027 N254 Reliability of HVAC and UPS Systems at Agency Telecom Gateway

Permit Requirements In addition to the requirements included in the environmental checklist and project-specific health, safety, and environmental requirements, the following provisions are permit conditions.

General Project Requirements

GR-1 Pre-activity Meeting – An Environmental Management Division (EMD) representative must attend a pre-construction meeting/tailgate meeting to go over environmental requirements. Please contact Ryan Hutchison at 650-235-0366, Gabrielle Feldman at 650-416- 4936, or Andres Estrada at 650-224-8532.

Air Quality

AQ-1 Adhesives or Sealants – Adhesives and sealants need to comply with the VOC standards per BAAQMD Regulation 8 Rule 51. Note, section 100 provides exemptions from VOC standards (e.g. container size, consumer products) o Copies of safety data sheets shall be made readily available to NASA’s Environmental Management Division (Tito Martinez at 650-499-7186 or Lauren Wibe at 650-495-5519) Additional information is available online at http://www.baaqmd.gov/rules-and-compliance/current-rules.

o Records documenting use (amount, dates, purpose, etc.) must be sent to NASA’s Environmental Management Division (Tito Martinez at 650-499-7186 or Lauren Wibe at 650-495-5519). Refer to section 500 of BAAQMD Regulation 8 Rule 51 for monitoring and recordkeeping requirements.

AQ-2 Asbestos – If the amount of regulated Asbestos-Containing Material (RACM) removed or renovated will be greater than 100 linear feet, 100 square feet, and 35 cubic feet or if there will be any dry removal of RACM, the BAAQMD must be notified (see BAAQMD Regulation 11, Rule 2 Section 113).

o Copies of notifications submitted to BAAQMD (if required) must be sent to NASA’s Health and Safety Division. Additional information is available online at http://www.baaqmd.gov/rules-and-compliance/current-rules.

AQ-3 Architectural Coatings – Architectural coatings used must comply with the VOC Standards specified in BAAQMD Reg. 8 Rule 3.

o Copies of safety data sheets must be sent to NASA’s Environmental Management Division (Tito Martinez at 650-499-7186 or Lauren Wibe at 650-495-5519). Additional information is available online at http://www.baaqmd.gov/rules-and-compliance/current-rules.

AQ-7 Lead Paint – Lead paint removal must be conducted per BAAQMD Regulation 11 Hazardous Pollutants Rule 1 Lead. A person shall not discharge any emission of lead, or compound of lead calculated as lead, from any emission point in excess of 6.75 kg (15 lbs.) per day.

o Additional information is available online at http://www.baaqmd.gov/rules-and-compliance/current-rules.

AQ-9 Refrigerant Management – Maintenance, service, repair, reclamation, and/or disposal of appliances containing class I or class II refrigerants (or non-exempt substitute refrigerants) must be conducted by technicians certified through an approved technician certification program pursuant to Title 40 of the Code of Federal Regulations, Part 82, §82.161. Records containing applicable information specified in Sections 95388 and 95389 of the Refrigerant Management Program Regulation must be submitted to NASA’s Environmental Management Division (Tito Martinez at 650-499-7186 or Lauren Wibe at 650-495-5519).

Hazardous Materials

HM-1 Plan Review Permit – A County of Santa Clara Plan Review Permit must be obtained prior to connecting, installing, constructing, substantially modifying, or replacing a hazardous materials storage or handling facility, tank system, or piping system. You must contact David Dumas at 650-604-7946 or Timothy Pun at 650-582-8856.

o Additional information is available online at: Plan Submittal Requirements for Hazardous Materials Systems (sccgov.org) o Note: Project proponents are instructed not to submit any application or supporting documents to the County of Santa Clara. All Hazardous Materials Permit Applications must be submitted to the Environmental Management Division’s Hazardous Materials Management Program.

HM-2 Secondary Containment – All pipes and tanks containing hazardous materials (oils) and liquid hazardous materials (fuel, solvents, cleaners, and adhesives) must use secondary containment. Secondary containment for a single container must be 110% of the primary containers volume. For multiple containers, secondary containment must be 150% of the largest container’s volume or 10% of the aggregate volumes of all containers, whichever is greater.

Hazardous Waste

HW-1 Oil-based Paints – Paint out brushes to the extent feasible and clean with thinner or solvent in a proper, sealable, compatible container. All excess paint shall be removed from the site by the painting contractor for re-use or recycling. Contact Ron Littleton at 650-447-4892 at or Timothy Pun at 650-582-8856 for more information.

HW-2 Cleaning and Disposal of Demolished Materials – Clean contaminated pieces of equipment (such as oil-bearing systems, transformers, piping systems, fume hoods, etc.), prior to disposal. Dispose or recycle the content inside equipment and the equipment pieces based on regulatory requirements, practicality, and economical consideration. Contact Ron Littleton at 650-447-4892 at or Timothy Pun at 650-582-8856 for more information.

HW-3 Asbestos and Lead Management – Asbestos/lead removal work cannot begin until the following project specific documents have been submitted and approved by Benjamin Heck from Health and Safety (QH) at 650-604-4787:

o An abatement work plan that describes what is being removed, how it will be removed, and any engineering controls that will be used. A designated Environmental Management Division representative must sign the waste manifest for all waste leaving the center, whether it’s given to NASA or taken away by the subcontractor.

o Training certificates, copies of physicals, respirator fit testing records.

o Copies of the project’s Hazardous Waste Transporter Registration, Hazardous Materials

Certificate of Registration, DOSH certificate, and contractor’s license must be submitted prior to commencement of abatement.

o All asbestos/lead waste must be kept in transparent, seal-tight bags that are labeled as asbestos/lead waste. For asbestos specifically, all waste must be wetted.

o Please contact John Shepardson at 650-604-3787 or Timothy Pun at 650-582-8856 for more information.

HW-5 Contractor Hazardous Waste Disposal – Project must comply with all Federal, state, and local regulations including the Santa Clara Hazardous Materials Storage Ordinance. Project is responsible for organizing the analysis and disposal of the waste, as well as the associated costs.

Contact designated Environmental Management Division personnel to obtain manifest signature or for any questions (Contact Ron Littleton at 650-447-4892 at or Timothy Pun at 650-582- 8856).

Industrial Wastewater and Drinking Water

IW-1 Water-based Paints – Paint out brushes (from water-based paints only) to the extent possible, and rinse into a drain that goes to the sanitary sewer. Never pour paint down a storm drain.

IW-2 Water Use and Discharge – Any water used during construction including rinsate, water drained from equipment, or hydrostatic testing must be sampled and submitted for approval by the Publicly Owned Treatment Works (POTW) at least 14 days before being discharged into the sanitary sewer. Please contact the Environmental Management Division by calling Brian Kawashima at 650-604- 0296, or Jeanne Sabin at 650-582-7321 to initiate the process.

Soils

SO-1 Excavated Soils – Excavated soils and all soil cuttings and/or drilling mud slurry in projects smaller than 1 acre shall be placed on and covered by plastic. Larger projects must consult with Environmental Management Division personnel (Garrett Turner 650-279-6443) to determine protocols for proper containment of soil and mud slurry during operations.

SO-2 Excavated Soil Disposal – All excavated soils need to be tested for contaminants prior to disposal. Contact Garrett Turner at 650-279-6443 for testing information. The Environmental Management Division shall determine the suitability for soil reuse and appropriate disposal of all excavated soils.

SO-3 Offsite Soil Testing – All offsite soils proposed as fill material shall be tested for the following chemicals.

o Total Petroleum Hydrocarbons:

Benzene Toluene Ethylbenzens Xylenes 8015M Volatile Organic compounds 8260B/624 PCBs (including Aroclor 1268) 8082A Pesticides 8081A Metals 6010/6020/7000 o All test results must be reviewed and approved by the Environmental Management Division (Brian Reddig at 650-604-1315 or Garrett Turner at 650-279-6443) prior to transporting material onsite.

SPCC

SP-1 Spill Log – A spill log must be maintained onsite of all projects. All spills (regardless of the size of the spill) must be recorded and reported to the EMD. Please contact Marcy Christlieb at 650-604-5360 or Garrett Turner at 650-279-6443.

Storm Water

Please follow NASA’s BMPs (attached):

o SW-1 Minimum Best Management Practices (BMPs) – NASA’s Minimum storm water

BMPs for all activities, employees, contractors, and visitors are required. This includes employee training programs, erosion and sediment control, good housekeeping, material handling and waste management, preventative maintenance, quality assurance and record keeping, spill and leak prevention and response.

o SW-2 Building Repair, Remodeling, and Construction BMPs – NASA’s BMPs for Building Repair, Remodeling, and Construction are required.

o SW-3 Small scale Construction, Demolition, and Excavations BMPs – NASA’s BMPs for Construction, Demolition, and Excavation projects are required for all operations that disturb less than one acre of land.

SW-4 Reseeding – Bare dirt and vegetated areas that are disturbed during construction must be reseeded with Environmental Management Division approved native mix. Please contact Marcy Christlieb at 650-604-5360, or Jeanne Sabin at 650-582-7321 for approval.

SW-5 Material Shavings – Material shavings (wood, metal, etc.) from cutting or drilling activities must be treated as hazardous waste and swept up and properly disposed of. Metal scrap bins must remain covered to protect against dispersal from rain and wind. Contact Timothy Pun at 650-582-8856 for additional information.

SW-6 Storm Drains – Protect all storm drains, including rooftop downspouts, around the project area with sandbags or fiber berms. Sandbags and fiber berms must be maintained throughout the duration of a project. Please contact Marcy Christlieb at 650-604-5360, or Jeanne Sabin at 650-582-7321 for additional information.

SW-7 Cover Stockpiles and trenched soil – Stockpiles of equipment, trenched soil, and construction materials must be covered with plastic sheeting for the duration of the project to protect against the contamination of rainwater runoff.

SW-8 Paint and Concrete Disposal – Excess paint, paint chips, or concrete shall not be washed off onto the ground. Contact Timothy Pun at 650-582-8856, or Jeanne Sabin at 650-582-7321 for additional information.

SW-9 Disposal of Mechanical Parts with Oil or other Residues – Demolished mechanical parts and unused equipment with residual oil or other material must be placed on pallets lined with a protective plastic liner and covered with plastic sheeting.

SW-10 Report Spills or Discharges – All spills or discharges on soil or into the storm drain system must be reported to the Environmental Management Division. Please contact Marcy Christlieb at 650-604-5360, or Jeanne Sabin at 650-582-7321 to report such spills or discharges.

SW-11 Water Discharge – Only uncontaminated precipitation can be discharged onto the ground, into the storm drains, within vegetation, or into down spouts. Other water must be containerized and properly disposed of. For additional guidelines for proper disposal, please contact Marcy Christlieb at 650-604-5360, or Jeanne Sabin at 650-582-7321.

SW-13 Project Closeout EMP – Prior to the closeout of this project all waste and materials must be removed from site and returned to original condition or approved condition per the project

Record of Environmental Considerations (REC). Closeout approval from EMD is contingent on receiving notification from the project including pictures of all outdoor work/staging areas submitted to Marcy Christlieb at 650-604-5360 or Jeanne Sabin at 650-582-7321.

SW-14 SWPPP Training EMP – Provide a sign in sheet verifying SWPPP training within first two weeks of project. After the initial training, each construction project is required to provide sign in sheets quarterly and with annual updates. Contact the Environmental Management Division (Marcy Christlieb at 650-604-5360 or Jeanne Sabin at 650-582-7321) for the latest version of the training program and to submit sign in sheets.

NASA AMES RESEARCH CENTER

BEST MANAGEMENT PRACTICES

NASA ARC SWPPP Minimum BMPs 9 07/10/2018

EMPLOYEE TRAINING PROGRAM

DESCRIPTION

This BMP includes training of all personnel who are responsible for:

Implementing activities identified in the SWPPP;

Conducting inspections, sampling and visual observations; and, Managing storm water.

Training should address topics such as:

Good housekeeping;

Material handling procedures;

Preventive maintenance;

Spill response; and, Actions necessary to implement all Best Management Practices identified in the SWPPP.

The SWPPP identifies periodic dates for this training, which is regularly offered to ARC employees, contractors, and resident agencies. Records are maintained of all training sessions held. Employee training, like equipment maintenance, is a method by which to implement Best Management Practices. This highlights the importance of training and of integrating the elements of employee training from the individual source control measures into a comprehensive training program.

TARGETED CONSTITUENTS

Sediments Nutrients Floatable Materials Oxygen Demanding Substances Heavy Metals Toxic Materials Oil and Grease

APPLICABILITY

This Best Management Practice is applicable to all industrial activities at ARC.

REQUIREMENTS

1. Ensure that all team members implementing the various compliance activities of this General Permit are properly trained to implement the requirements of this General Permit, including but not limited to:

BMP implementation, BMP effectiveness evaluations, Visual observations, and Monitoring activities.

2. In the event that ARC enters Level 1 status, as described by the IGP, appropriate team members shall be trained by a Qualified Industrial Stormwater Practitioner (QISP);

3. Prepare or acquire appropriate training manuals or training materials;

Environmental Compliance/Safety Trainers are employed under the Safety, Health and Medical Services Office, Code QH, and EMD.

The Storm Water Pollution Prevention training materials were prepared by a QISP.

4. Identify which personnel need to be trained, their responsibilities, and the type of training they shall receive;

A list of facilities at ARC that have a potential to contribute to storm water contamination is presented in the SWPPP. Employees performing work in these locations will be required to attend the Storm Water Pollution Prevention training class on an annual basis, either in-person or online.

5. Provide a training schedule:

NASA ARC SWPPP Minimum BMPs 10 07/10/2018

Regularly scheduled safety and environmental courses are available to all civil servants at ARC and to contract employees on a space-available basis.

An instructor-led Storm Water Pollution Prevention class is provided at ARC 4 times each year and is presented by a QISP.

In addition to the instructor-led class, the Storm Water Pollution Prevention class is currently offered online through SATERN, and is available 24 hours a day.

Daily tailgate meetings should integrate storm water quality management with existing training programs.

6. Maintain documentation of all completed training classes and the personnel that received training in the

SWPPP.

Training records are maintained by Code QH and are retained on site for a period of at least 5 years.

7. Promote employee ownership of problems and the solutions.

8. Integrate employee feedback into training and BMP implementation.

NASA ARC SWPPP Minimum BMPs 11 07/10/2018

EROSION AND SEDIMENT CONTROLS

DESCRIPTION

This BMP includes a description of all sediment and erosion control activities. This may include the planting and maintenance of vegetation, diversion of run-on and run-off, placement of sandbags, silt screens or other sediment control devices, etc. Any site where soils are exposed to water and wind can have soil erosion and sedimentation problems. Erosion is a natural process in which soil and rock materials are loosened and removed. Sedimentation occurs when soil particles are suspended in surface run-off or wind and are deposited in streams and other water bodies.

Human activities can accelerate erosion by removing vegetation, compacting or disturbing the soil, changing natural drainage patterns and by covering the ground with impermeable surfaces (pavement, concrete, and buildings). When the land surface is developed or “hardened” in this manner, storm water cannot seep into or “infiltrate” the ground, resulting in larger amounts of water moving more quickly across the site, which can carry more sediment and other pollutants to creeks and streams. Because the vegetation primarily consists of marshlands and grasslands, soil erosion prevention is not required in many areas of ARC;

however, erosion prevention measures are considered during any construction and/or grounds maintenance activities.

TARGETED CONSTITUENTS

Sediment Heavy Metals Toxic Materials

APPLICABILITY

This BMP is a minimum requirement and applicable to all building, construction, and landscaping activities at ARC. Projects that disturb ground surfaces equal to or greater than one acre must submit an NOI with the SWRCB and prepare a project-specific SWPPP that meets the requirements of NPDES General Permit No.

CAS000002: State Water Resources Control Board General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities.

REQUIREMENTS

1. For each erodible surface facility location identified in the SWPPP:

Implement effective wind erosion controls:

o Retain as much vegetation (plants) on-site as possible.

o Minimize the time that soil is exposed;

o Water exposed areas to control dust;

o Cover stockpiles to protect from wind erosion.

Provide effective stabilization for inactive areas, finished slopes, and other erodible areas prior to a forecasted storm event;

o Stabilize the disturbed soils as soon as possible by planting vegetation or hydroseeding o Place filtering media (e.g. straw bales, rocks, silt fences, etc.) around the base of each stockpile or at the storm drain inlet to remove materials from rainwater run-off; and, o Remove sediment from storm water run-off before it leaves the site.

Maintain effective perimeter controls and stabilize all site entrances and exits to sufficiently control discharges of erodible materials from discharging or being tracked off the site;

Divert run-on and storm water generated from within the facility away from all erodible material:

o Slow down the run-off flowing across site (regrading, silt fences, planting).

o Prevent run-off from flowing across disturbed areas (divert the flow to vegetated areas).

o Provide drainage ways for the increased run-off (use grassy swales rather than concrete drains);

If sediment basins are implemented, ensure compliance with the design storm standards in Section X.H.6 of the IGP. Identify areas which, due topography, activities or other factors, have a high

NASA ARC SWPPP Minimum BMPs 12 07/10/2018 potential for significant soil erosion, and identify structural, vegetative, and / or stabilization measures used to limit erosion.

NASA ARC SWPPP Minimum BMPs 13 07/10/2018

GOOD HOUSEKEEPING

DESCRIPTION

Good housekeeping practices are designed to maintain a clean and orderly work environment. Often the most effective first step towards preventing pollution in storm water from industrial sites simply involves using good common sense to improve the facility’s basic housekeeping methods. Poor housekeeping can result in more waste being generated than necessary and an increased potential for storm water contamination. A clean and orderly work area reduces the possibility of accidental spills caused by mishandling of chemicals and equipment, thereby reducing safety hazards. Well-maintained material and chemical storage areas should minimize discharges of materials/pollutants that could contaminate storm water. Simple procedures can be used to promote good housekeeping, including improved operation and maintenance of industrial machinery and processes, material storage practices, material inventory controls, routine and regular clean-up schedules, maintaining well-organized work areas, and educational programs. It is the policy of ARC that facility managers as well as line supervisors are responsible for ensuring that personnel are educated in proper environmental hazards management, including storm water pollution prevention.

TARGETED CONSTITUENTS

Sediments Nutrients Floatable Materials Oxygen Demanding Substances Heavy Metals Toxic Materials Oil and Grease

APPLICABILITY

This BMP is applicable to all industrial activities at ARC.

REQUIREMENTS

1. Observe all outdoor areas associated with industrial activity; including:

Storm water discharge locations;

Drainage areas;

Conveyance systems;

Waste handling/disposal areas; and, Perimeter areas impacted by off-facility materials or storm water run-on to determine housekeeping needs.

2. Any identified debris, waste, spills, tracked materials, or leaked materials shall be cleaned and disposed of properly;

3. Minimize or prevent material tracking;

4. Minimize dust generated from industrial materials or activities;

5. Ensure that all facility areas impacted by rinse/wash waters are cleaned as soon as possible;

6. Cover all stored industrial materials that can be readily mobilized by contact with storm water;

7. Contain all stored non-solid industrial materials or wastes (e.g., particulates, powders, shredded paper, etc.) that can be transported or dispersed by the wind or contact with storm water:

Wind and rain can transport stockpiled materials into the storm drain system. To eliminate this hazard, cover materials of particular concern such as hazardous materials, dirt, and sand piles that must remain outdoors;

8. Prevent disposal of any rinse/wash waters or industrial materials into the storm water conveyance system;

9. Minimize storm water discharges from non-industrial areas (e.g., storm water flows from employee parking area) that contact industrial areas of the facility; and,

10. Minimize authorized Non Storm Water Discharges (NSWDs) from non-industrial areas (e.g., potable water, fire hydrant testing, etc.) that contact industrial areas of the facility.

11. Conduct formal monthly observations of all buildings and surrounding areas to ensure.

NASA ARC SWPPP Minimum BMPs 14 07/10/2018

Outside areas are cleaned and organized;

Drips, leaks, or evidence of such, from equipment or pipes are contained;

There is adequate space in work areas to minimize spill potential;

Wastes are removed regularly;

Walkways and passageways are easily accessible;

Walkways and passageways are free of materials that could be spilled;

Evidence of dust from painting, sanding, or other industrial activities are cleaned up and properly disposed of; and Cleanup procedures for spilled materials are accessible and utilized.

12. An inspection log will be maintained in order to feed other environmental reporting requirements at

ARC.

A formal annual inspection of industrial areas at ARC shall be conducted in accordance with the Quality Assurance and Recordkeeping BMP as required by the IGP.

13. Conduct annual inventory of chemical substances, including hazardous materials and pollutants that are present on-site. This inventory shall meet the requirements of the OSHA-required inventory of chemicals and toxic substances.

14. Maintain a current file of all Safety Data Sheets (SDSs) for chemicals and toxic substances.

15. Label chemical containers in accordance with OSHA, EPA, DOT, and other applicable federal, state, and local requirements.

16. Maintain dry and clean floors and ground surfaces by using brooms, shovels, vacuum cleaners, and cleaning machines.

17. Regularly pickup and dispose of garbage, debris and waste material.

18. Make sure equipment is working properly.

19. Routinely inspect for leaks or conditions that could lead to discharges of chemicals or contact of storm water with raw materials, intermediate materials, waste materials, or products.

20. Ensure that all employees understand spill cleanup procedures in accordance with the Employee

Training Program BMP and the IGP.

21. Inform on-site contractors of NASA ARC policies. Include appropriate provisions in their contract to make certain proper housekeeping and disposal practices are implemented.

22. Discuss BMP implementation during daily tailgates/briefings.

23. Improper storage can result in the release of materials and chemicals that can cause storm water run-off pollution. Proper storage techniques include:

Maintain an up-to-date inventory of all materials (hazardous and non-hazardous). This inventory helps to keep material costs down caused by overstocking, enables the tracking of materials stored and handled on-site, and identifies which materials and activities pose the most risk to the environment.

Clearly mark on the inventory each hazardous material that requires special handling, storage, use, and disposal considerations.

Keep the work site clean and orderly by removing debris in a timely fashion and sweeping the area regularly.

Adhere to the Material Handling and Waste Management BMP.

24. Make sure that nearby storm drains are well-marked to minimize the chance of inadvertent disposal of liquids.

25. Do not dump waste paints or other waste liquids down the storm drain. Nothing but clean rain water may enter the storm drainage system.

26. Washing concrete trucks over the storm drain is prohibited.

27. Cleaning equipment or tools over catch basins is prohibited.

NASA ARC SWPPP Minimum BMPs 15 07/10/2018

MATERIAL HANDLING AND WASTE MANAGEMENT

DESCRIPTION

This BMP includes the procedures or processes to prevent or minimize handling of industrial materials or wastes that can be readily mobilized by contact with storm water during a storm event.

Accidental releases of materials from underground liquid storage tanks, aboveground storage tanks, drums, containers, and dumpsters, or from improper handling, storage, or disposal of waste/recyclable materials present the potential for contaminated storm waters with many different pollutants. Materials spilled, leaked, or released from storage containers and dumpsters may accumulate in soils or on the surfaces. The materials may then be carried away by storm water run-off.

This BMP addresses the loading, unloading, and storage of industrial materials, hazardous wastes, and recyclable materials. Loading or unloading of materials occurs in two ways: relocation of solids or liquids in containers, or direct liquid transfer. Materials leaked, spilled, or lost during loading/unloading may collect in the soil or on other surfaces and be carried away by run-off or when the area is cleaned. Rainfall may wash pollutants from machinery used to unload or move materials.

Material transfers take place throughout ARC, including NASA Ames Supply Support Facility at N-255, the Naval Air Reserve Hazardous Materials Warehouse at Moffett Federal Airfield Facility 45 and the California Air National Guard Facilities 681 and 682.

Hazardous materials are stored outdoors at ARC in secondary contained and roofed chemical storage facilities or lockers. Standard Operating Procedures (SOPs) for each of the materials prohibit contact with storm water run-off in the event of an accident or spill.

Hazardous waste is collected from various satellite and 90-day accumulation areas throughout ARC. The waste is then stored at ARC Facility N-265 and Moffett Federal Airfield Facility 950 for processing before being shipped off-site to an approved Treatment, Storage, and Disposal, Facility (TSDF). The containment structure of the accumulation areas prohibits materials from contacting storm water runoff. Rainwater captured within the containment structures is pumped to portable holding tanks and the water is characterized. The water is either discharged to the sanitary sewer system or managed as a hazardous waste, as determined from the characterization.

TARGETED CONSTITUENTS

Floatable Materials Heavy Metals Oil and Grease Oxygen Demanding Substances Toxic Materials

APPLICABILITY

This BMP is applicable to all industrial activities at ARC, including any area where liquid materials are stored outside. It should be noted that the storage of reactive, ignitable, or flammable liquids must comply with the California Health and Safety Code, the Santa Clara County Hazardous Materials Storage Ordinance, and the Local Fire code.

REQUIREMENTS

1. Prevent or minimize handling of industrial materials or wastes that can be readily mobilized by contact with storm water during a storm event;

Prevent or reduce the discharge of pollutants to storm water from outdoor loading/unloading of materials through implementation of the following:

NASA ARC SWPPP Minimum BMPs 16 07/10/2018 o When materials are received, they shall remain in the travel path only for a time reasonably necessary to transport the materials but no longer than 24 hours;

o Use a written operations plan that describes procedures for loading and/or unloading;

o Have an emergency spill cleanup plan readily available;

o Employees trained in spill containment and cleanup should be present during material loading/unloading;

o Establish spill kits for quick deployment of cleanup materials. Locate spill kits next to or near each loading/unloading area and regularly train employees in their use;

o Park delivery vehicles so that spills or leaks can be contained; and o Cover the loading/unloading docks to reduce exposure of materials to rain.

Using engineering safe guards and thus reducing accidental releases of pollutants can prevent operator errors. Examples of engineering safeguards include:

o Overflow protection devices on tank systems to warn the operator to automatically shut down transfer pumps when the tank reaches full capacity;

o Protective guards (bollards) around tanks and aboveground piping to prevent vehicle or forklift damage; and o Clearly tagging or labeling all values to reduce human error Proper use of pesticides and fertilizers will reduce the risk of loss to storm water:

o Pesticide applicators must be licensed with the California Department of Pesticide Regulation and county agricultural commissioners;

o No person shall pollute water supplies or waterways while loading, mixing or applying pesticides on ARC property;

o No person shall transport, handle, store, load, apply or dispose of any pesticide, container or apparatus in such a manner as to pollute water supplies or waterways, or cause damage or injury to land, humans, plants or animals;

o Pesticides / fertilizers should not be applied during the wet season as they may be carried from the site by the next storm;

o Avoid over-watering not only to conserve water but to avoid the discharge of water which may have become contaminated with nutrients and pesticides;

o Store pesticides and application equipment in a responsible manner; and o Properly dispose of the used containers.

Storm water from parking lots may contain undesirable concentrations of oil, grease, suspended particulates, and metals such as copper, lead, cadmium, and zinc, as well as the petroleum byproducts of engine combustion. Deposition of air particulates, generated by the facility or by adjacent industries, may contribute significant amounts of pollutants. Therefore, the following maintenance operations shall occur:

o Sweeping of main streets shall be conducted monthly and sweeping of parking lots shall be conducted quarterly. Sweeping should be conducted with a vacuum sweeper, rather than a mechanical brush sweeping device which is not as effective at removing the fine particulates;

o Cleaning of catch basins and building laterals shall be conducted annually;

o Maintain painted stencils that mark storm drain inlets “No Dumping! Flows to Bay.” This stencil will minimize inadvertent dumping of liquid wastes; and o Debris will be disposed of off-center at an approved landfill site.

The NASA ARC Site Contingency Plan is the guideline for emergency response to incidents involving hazardous materials/hazardous waste and/or hazardous waste constituents. The emergency coordination and notification for incidents involving hazardous waste and/or hazardous materials shall be in accordance with federal, state, and local statutory and regulatory requirements. Contact the ARC EMD at 650-604-1406.

2. Cover industrial waste disposal containers and industrial material storage containers that contain industrial materials when not in use;

3. Contain all stored non-solid industrial materials or wastes (e.g., particulates, powders, shredded paper, etc.) that can be transported or dispersed by the wind or contact with storm water;

Provide secondary containment for liquids;

NASA ARC SWPPP Minimum BMPs 17 07/10/2018

Cover industrial materials and/or waste containers that hold industrial materials when not in use.

Protect from rainfall, run-off, and wind dispersal by implementing controls such as:

o Store materials indoors or in a chemical storage locker;

o Cover the storage area with a roof; and o Minimize storm water run-on by enclosing the area or providing a berm.

Storage of oil and hazardous materials, wastes, and recyclables must meet specific federal, state, and local standards including:

o Spill Prevention Control and Countermeasure (SPCC) Plan;

o Secondary containment, integrity and leak detection monitoring; and o Emergency preparedness plans.

Hazardous materials shall be properly stored:

o Hazardous materials should be placed in a designated area;

o The designated storage area should be covered with a roof;

o Designated areas should be paved, free of cracks and gaps and liquid tight in order to contain leaks and spills;

o Liquid materials should be secondarily contained to hold 10 percent of the volume of all the containers or 110 percent of the volume of the largest container, whichever is greater;

o Drums stored in an area where unauthorized persons may gain access must be secured to prevent accidental spillage, pilferage or any unauthorized use; and o Employees trained in emergency spill cleanup procedures should be present when dangerous waste, liquid chemicals or other wastes are loaded or unloaded.

Hazardous and Universal waste materials and recyclables must be segregated according to hazard class, stored in secondary containment to prevent accidental release, labeled according to the container’s contents and the material’s hazard and accurately inventoried for reporting to the EMD and to federal, state and local regulatory agencies.

4. Divert run-on and storm water generated from within the facility away from all stockpiled materials;

5. Clean all spills of industrial materials or wastes that occur during handling in accordance with the spill response procedures identified in the IGP:

Hazard…