Attachment_A3_Environmental_Guidelines.pdf

Avoid Verbal Orders TO: Tiffany Fairley/PX-C DATE: 02/13/2019 FROM: SI-E3/Environmental Management Branch SUBJECT: KSC Record of Environmental Consideration (REC) REC #: 10560

1. PROJECT INFORMATION

Project Title: Press Site- Natural Line of Sight Clearing

Project Lead: Tiffany Fairley, PX-C, 321-867-7986/321-747-8306 Project No.: PX-01_1/29/19

Project Description: Establish natural area lines-of-sight (LOS) from KSC Press Site to SLC 40, LC 41, SLC 39A and SLC 39B. A natural area LOS is established and maintained by mechanical roller chopping, selective mulching and hand removal of selected trees leaving the natural understory vegetation in place at a lower height that does not interfere with launch observations. These LOS would also require routine maintenance intervals using a combination of mechanical, hand labor, chemical treatments and prescibed fire to keep vegetattion height at the required elevation.

Implementing the Natural Areas LOS option would be considered a habitat management action maintaining existing habitats rather than converting areas to ruderal habitats resulting from traditional clearing and grubbing of all vegetation within the LOS and would result in an estimated $2.5 million in savings. Savings would be achieved by both means and methods cost reduction, and mitigation costs required for habitat loss that would be avoided with the natural area LOS.

Order of priority for clearing LOS would be : LC 41, LC 39A, SLC 40 and SLC 39B last. NASA Environmental, PX and FWS (Merritt Island National Wildlife Refuge) have met to discuss impacts and anticipated benefits and support from FWS including incorporation of prescribed burning within LOS areas as applicable for long term management.

EPB Reviewer: MAM Facility No.: NA / unimproved grounds

2. NEPA DETERMINATIONS

a. Categorical Exclusions per 14 CFR Part 1216.304(d) e. Centerwide EIS

b. Environmental Assessment (EA) Required f. AF Project on KSC/813

c. Environmental Impact Statement (EIS) Required g. NASA Project on CCAFS/813

d. Existing FONSI or ROD

3. ENVIRONMENTAL REQUIREMENTS

a. Non-Permit Requirements YES NO

b. Permit Requirements YES NO

2.a.1. CATEGORICAL EXCLUSION (CATEX): This project is categorically excluded (CATEX) from further NEPA review as defined in 14 CFR 1216.304(d)(2)(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, such as space tracking and data systems. For additional information, please contact Don Dankert of the NASA Environmental Management Branch (SI-E3, 321-861-1196).

3.a.1. SOLID WASTE MANAGEMENT UNITS (SWMU) AND POTENTIAL RELEASE LOCATIONS (PRL): The proposed line-of-sight clearing activities are within the footprint of several SWMUs or PRLs being investigated by the NASA Remediation Group (SI-E2). A SWMU or PRL designation means a site has had historical operations with the potential to impact the environment and is or has been under investigation. A Land Use Control Implementation Plan (LUCIP) has been prepared for some of the SWMU areas impacted y this project. These controls are necessary to prohibit residential exposure to soil and/or groundwater present at the site. All workers involved in subsurface/dewatering work must be notified (HAZCOM) of the potential for contamination present and it is recommended that an Industrial Hygienist be consulted for determination of required personal protective equipment (PPE). KEMCON/IMSS Industrial Hygiene (IH) can be contacted at 321-867-2400 or at KSC-DL-EnvHealth/(KSC-DL-EnvHealth@mail.nasa.gov).

FROM: SI-E3/Environmental Management Branch SUBJECT: KSC Record of Environmental Consideration (REC) REC #: 10560 The following sites are being investigated by the NASA Remediation Group of the Environmental Assurance Branch

(SI-E2):

PRL #224 Optical Tracking Station A,(RPM Dinh Vo, 867-5964) -- Undergoing Confirmation Sampling / no known contamination.

K7-0516 - SWMU #030 Component Cleaning Facility (RPM Anne Chrest, 867-2056) -- A LUCIP has been prepared for this SWMU. These controls are necessary to prohibit residential exposure to groundwater (volatile organics) present at the site. Numerous monitoring and air sparging wells within this location to be identified and avoided.

K7-0468 - SWMU #089 Converter/Compressor Building (RPM Ryan O'Meara, 861-7719) -- A LUCIP has been prepared for this SWMU. These controls are necessary to prohibit residential exposure to groundwater (volatile organics) present at the site. There are numerous monitoring and air sparging wells within this location to be identified and avoided.

SWMU #100 Area South of Facility K7-0516 (RPM Anne Chrest, 867-2056) -- A LUCIP has been prepared for this SWMU. These controls are necessary to prohibit residential exposure to groundwater (volatile organics) present at the site. There are numerous monitoring and air sparging wells within this location to be identified and avoided.

K7-0416B - SWMU #102 Propellant Storage Building Area (RPM Ryan O'Meara, 861-7719) -- A LUCIP has been prepared for this SWMU. These controls are necessary to prohibit residential exposure to groundwater (volatile organics) present at the site. There are numerous monitoring and air sparging wells within this location to be identified and avoided.

There may be active monitoring wells associated with remediation at these investigation areas. Prior to project commencement, existing wells should be located and identified and precautions taken so as not to cover or damage the wells, or place heavy equipment or vehicles on top of the well covers. If wells are disturbed or damaged, contact the appropriate RPM immediately.

The following areas have been deemed No Further Action (NFA) sites and therefore this project may proceed as proposed. There is no knowledge of any existing environmental contamination at these locations:

K7-0165 - SWMU #025 Hazardous Waste Facility - NFA

PRL #074 Non-Destructive Evaluation Laboratory - NFA

PRL #087A STP 09 - NFA

PRL #169 Ordinance Operations Building Area - NFA

PRL #174 Area 2 Repeater Buildings, Repeater Building #2 - NFA

PRL #176 Turn Basin - NFA

FROM: SI-E3/Environmental Management Branch SUBJECT: KSC Record of Environmental Consideration (REC) REC #: 10560 3.a.2. MANHOLE DEWATERING POTENTIAL RELEASE LOCATION (PRL): This project includes work within the boundary of PRL 204, Manhole Dewatering Operations. There is an institutional control being implemented on the soil within a 25 ft radius of manholes on KSC. The soil adjacent to telecommunications and electrical manholes is contaminated with barium, copper, lead and polynuclear aromatic hydrocarbons. The maximum concentrations found are barium at 410 mg/kg, copper at 440 mg/kg, lead at 4,900 mg/kg and B(a)P Equivalent at 35.4 mg/kg. If handling the soil (excavation or any other activity in which the soil is disturbed and handled by workers) within 25 ft of a manhole, contact your company's Safety and Health Office for recommendations on appropriate personal protective equipment (PPE). All soil being disturbed within 25 ft of the manhole being dewatered must remain within that 25 ft radius. If this is not possible the soil must be properly disposed. For more information, or if soil must be disturbed, please contact Mike Deliz (SI-E2, 867-6971) to discuss control/disposal options.

3.a.3. THREATENED AND ENDANGERED SPECIES: This project has the potential to affect protected and/or threatened and endangered species; which may include the Florida scrub jay, Eastern indigo snake, gopher tortoises, etc. Measures must be taken to minimize impacts to their habitat and avoid direct harm to these species. Coordination with supervisory wildlife management staff from the Merritt Island National Wildlife Refuge (MINWR) will be required to identify potential impacts prior to disturbances. Wildlife surveys may be necessary at the direction of MINWR depending on work location, season and type of land management activity proposed. Please contact Mike Legare, MINWR Refuge Biologist at 861-2309 to coordinate biological survey requirements. If it is determined that the proposed vegetation management within a specific location requires a biological survey, please contact Becky Bolt (IMSS-200, 867-7330) at least 14 days prior to beginning work to schedule a biological survey.

3.a.4. SCRUB COMPENSATION: Since the action is considered a land management activity that is consistent with MINWR scrub management activities conducted elsewhere on KSC/MINWR, it has been determined by both NASA EMB and MINWR land managers that the proposed actions to reduce vegetation height and removal of exotic/invasive vegetation with appropriate equipment and technique will improve existing Florida scrub-jay (FSJ) habitat. This action will not require mitigation in accordance with the Programmatic Biological Opinion for Kennedy Space Center Florida Scrub-Jay (FWS Log No. 04EF1000-2013-F-0194) and no additional Section 7 Consultation with USFWS is warranted.

Additionally, the KSC grounds contractor performing the land management actions must incrementally coordinate with MINWR land management personnel to ensure scrub habitat management objectives within the managed line-of-sight (LOS) areas will be met, including periodic use of prescribed fire by MINWR fire management personnel. Please contact James Brooks, NASA EMB for additional information at 867-9081, and Mike Legare, MINWR at 861-2369 for coordination of land management activities.

3.a.5. BRAZILIAN PEPPER REMOVAL: This project will include the removal and eradication of several acres of Brazilian pepper trees, an exotic invasive pest tree that displaces native vegetation. The removal activity will occur in both high density, near mono-culture stands of Brazilian pepper and within areas of lower density coverage where pepper trees are interspersed with native vegetation. The typical clearing/eradication methodology employed on KSC includes use of tracked hydraulic mulching machines to mulch trees to ground level, and once re-sprouting from roots systems occurs, follow-up application of EPA-listed herbicides per label direction. Generally most trees are killed after 2-3 re-sprouting and herbicide application events. Even after mature trees have been eradicated, a large and persistent seed bank will produce new trees that will eventually recolonize the initially treated area. Continued management of LOS clearings will be required to ensure Brazilian pepper and other invasive exotic plants are prevented from becoming established or recolonizing these areas. Therefore, as part of this action, the proponent has agreed to fund and direct the KSC grounds maintenance contractor to conduct periodic surveillance and control of Brazilian pepper and other potential invasive plant species such as cogon grass. Use of herbicides outside KSC operational areas must be

FROM: SI-E3/Environmental Management Branch SUBJECT: KSC Record of Environmental Consideration (REC) REC #: 10560 reviewed and approved by MINWR land managers in advance of application. Please contact Mike Legare, 861-2369 for additional information and coordination.

3.a.6. BALD EAGLE NEST: There is an established bald eagle nest located immediately south of the proposed LOS to LC-40. The bald eagle is federally listed under the Bald and Golden Eagle Protection Act. No work is to occur within the 660' radius of an eagle nest until the eaglets have fledged. Eagle nest locations and activity can change from year to year. Therefore, it is necessary that the project contractor consult with the NASA EMB regarding nest site locations prior to the initial vegetation removal and chopping, and before each follow-on maintenance activity that will occur under this action. Contact Becky Bolt (IMSS-200, 867-7330) for additional information and the latest locations of bald eagle nest sites on KSC.

3.a.7. WETLANDS: The proposed vegetation removal and management activities are not authorized to alter or adversely impact wetlands or surface waters. The project shall not include any excavation, fill or excessive disturbance (rutting and displacement) of hydric soils within wetlands. If vegetation height within wetlands exceeds the allowable height for the LOS, then appropriate management practices coordinated/approved through NASA EMB and MINWR staff may be used to reduce vegetation height without disturbing onsite soils. These practices may include selective hand clearing and use of a small, low-psi tracked mulching tractor if soil conditions allow. Wetland areas are to be identified prior to execution of land management activities to ensure operators are aware of the locations of wetlands to avoid impacts. Wetland land cover maps are available from the NASA and should be obtained and reviewed prior to work start. Please contact Lynne Phillips, SI-E3, 867-4817 for additional detail.

3.a.8. EROSION AND SEDIMENT CONTROL BEST MANAGEMENT PRACTICES (BMPs): Precautions must be made to eliminate or reduce to the greatest extent possible any discharge of sediments outside established project boundaries. This can be accomplished by initiating proactive erosion control BMPs. Installation and maintenance of appropriate erosion/sediment control devices (such as wattles, turbidity screens, silt fences, inlet protectors, floating turbidity booms, etc.) must be completed prior to initial land disturbance where the possibility of sediment discharge could impact surrounding stormwater conveyances and other surface waters. The BMPs must be maintained so they remain functional until such time that the newly exposed soils are stabilized with natural vegetation.

3.b.1. OPEN BURNING OF CONSTRUCTED BRUSH PILES: Combustible vegetative material may be burned within the confines of KSC after obtaining a Burn Permit issued by the KSC Fire Inspector. Burning may be limited or prohibited during periods of dry weather, or when sensitive flight hardware is housed in the vicinity of the burn site. Notify KSC Spaceport Integration (Bill Heidtman/861-9339 or Greg Gaddis/861-9556) 3 days ahead of planned burn for a review of impacts. After the site is prepared for burning, notify Michael Good (US Fish and Wildlife Service, 861-2812, michael_good@fws.gov) of the proposed open burning. Also contact the Florida State Division of Forestry Cocoa Field Office (690-6465) to notify them of the planned burning of land clearing debris and schedule an inspection to ensure the setbacks, piles, and equipment are set up properly. The Cocoa Office will send inspection paperwork to the Division of Forestry Orlando District Field Unit who will issue a valid burn control number. The project proponent must call the Orlando Unit (407-888-8767) every day before burning to receive a Burn Authorization Number. Call the KSC Duty Office at 861-5050 for a Burn Permit a minimum of 48 hours prior to the burn. The KSC Fire Inspector will schedule an onsite visit for the day you get the Burn Authorization Number.

No other environmental issues were identified based upon the information provided in the KSC Environmental Checklist.

This Record of Environmental Consideration (REC) does not relinquish the project lead from obtaining and complying

FROM: SI-E3/Environmental Management Branch SUBJECT: KSC Record of Environmental Consideration (REC) REC #: 10560 with any other internal NASA permits or directives necessary to ensure all organizations potentially impacted by this project are notified and concur with the proposed project.

Due to potential changes in regulations, permit requirements and environmental conditions, statements in this REC are valid for 6 months, and subject to review after this period. It is the responsibility of the project lead to submit current project information for a REC update prior to project commencement if REC is older than 6 months; and also to notify the Environmental Management Branch (SI-E3) if the scope of the project changes at any time after the REC is issued.

T. Fairley / PX-C cc:

L. Phillips / SI-E3 J. Brooks / SI-E3 M. Deliz / SI-E2 B. Bolt / IMSS-200 C. G. Willis / SCJones M. Legare / FWS - MINWR

4. Upon evaluation of the subject project, the above determinations have been made and identified. Contact the Environmental Management Branch (SI-E3) at 861-1196 for re-evaluation should there be any modifications to the scope of work.

02/13/2019 08:16

James Brooks Date