A.02 J-0200000-13 Record of Environmental Consideration.pdf

Karla York Mew

REC: 21-0007

8. The Environmental Division (ENV) has reviewed the proposed project. The project must be completed as described above, or a new REC request form must be submitted if this project is modified or expanded in a manner that was not considered in this review or has not been initiated within one year. This REC is not an approval to begin the project, it only outlines the environmental and natural resource requirements as follows:

a. Many buildings on Fort Jackson have asbestos containing materials (ACM). Products, such as ceiling tiles, floor tiles, adhesives, cementitious wallboard, joint compound, skim coating, roofing materials, thermal system insulation, fire proofing, etc., are considered suspect ACM and have a high potential for disturbance when performing preventive maintenance activities. South

Carolina Department of Health and Environmental Control (SCDHEC) requires that, prior to any renovation or demolition activities, a current (within three years) building survey or scope specific analysis of suspect ACM be conducted. The most recent surveys are maintained by the

Environmental Management Branch within the Directorate of Public Works (DPW) and can be reviewed at any time.

In order to safely perform the duties that are required under this contact, any personnel with the potential to disturb ACM shall attend a U.S. Environmental Protection Agency (EPA) certified

Asbestos Operation and Maintenance (O&M) Workers Course and obtain SCDHEC licensing.

This training will allow the technician to perform activities when the amount of regulated ACM

(RACM) disturbed does not exceed that which may fit in a 6 mil polyethylene bag measuring no greater than 60 inches, or one asbestos glove bag. The Contractor has sole responsibility in identifying and assessing all potential asbestos disturbances for its employees prior to performing any maintenance or repair activities. The Contractor shall notify the Toxic Substance Program

Manager prior to disturbing any RACM. For additional information, contact Mark Merritt, Toxic

Substance Program Manager, at 803-751-3838 or mark.d.merritt6.civ@mail.mil.

Pre-Abatement Requirement: The Contractor shall provide the Contracting Officer

Representative (COR) an asbestos abatement plan for review by the Toxic Substance Program

Manager at least one week prior to starting any abatement work activities. The plan shall identify specific work practices that will be used to abate the ACM. In addition, the Contractor shall apply for an asbestos project license from the SCDHEC Air Quality Office. A copy of the approved project license shall be delivered or emailed to the COR or the Toxic Substance

Program Manager at Building 2563, Rm 106, or mark.d.merritt6.civ@mail.mil at least four days prior to starting any work activities.

Post-Abatement Requirements: The Contractor shall submit the following documentation to the COR within 45 days of completion of the abatement phase of the project:

- Copy of the Certificate of Liability Insurance coverage

- Copy of EPA training certificates and SCDHEC Licenses for each individual on the job site

- Copy of the Asbestos Waste Shipment Record and Landfill Disposal Weight Tickets

All new building materials installed during this contract (i.e., insulation, fire proofing products, acoustical ceiling tiles, floor coverings, joint compound, caulking, adhesives, etc.) must not contain any form of asbestos. Asbestos is still being manufactured and can be found in some mailto:mark.d.merritt6.civ@mail.mil mailto:mark.d.merritt6.civ@mail.mil products. When purchasing any materials, please check the manufacturer's safety data sheet for material content.

b. The Contractor shall reuse or recycle as much of the waste generated during this project as possible, to include electronic waste, scrap metal, cardboard, plastic bottles, and paper. If the contract allows, select recyclables may be taken to the Recycling Center, 5671 Lee Road. All reused materials, recyclables, and trash that are transported off-post must be reported to the COR upon completion of the project. The report must identify the amount, by weight, of waste reused, recycled, composted, or disposed, and the name of the receiving facility. The COR shall provide a copy of this report to ENV within 10 days of receipt. For additional information, contact

Sherri Robinson, Solid Waste Program Manager, at 803-751-6853 or sherri.e.robinson2.ctr@mail.mil.

c. The Contractor shall manage hazardous substances, including lamps (light bulbs), batteries, substances containing heavy metals, solvents/sealants, epoxy/compounds, paint and paint related materials, possible mercury containing equipment, lead based paint, and asbestos containing materials, refrigerants, and fuels and fluids needed for vehicles and equipment, in accordance with Federal, State, local, and military regulations. The Fort Jackson Hazardous Substance

Management Plan (HSMP) may be used for guidance. The Contractor is responsible for spill prevention, training, clean up, disposal, and reporting, and must comply with the Fort Jackson

Spill Response Plan (page 15 of the HSMP). The Contractor should notify the Fort Jackson Fire

Department (751-9111), if the spill is greater than 5 gallons or has the potential to reach a body of water or storm drain. The Contractor shall take any unused hazardous substances or other

Contractor supplied items regularly with them to avoid storage violations at all temporary job sites and at any permanent lay down yards, and upon completion of each project. Items should not be abandoned on Fort Jackson. For additional information or a copy of the HSMP, contact

Lisa McKnight, Hazardous Substance Program, at 803-751-5971/319-4618 or lisa.a.mcknight11.civ@mail.mil

The Contractor shall properly dispose of all contaminated debris and waste generated during each project in accordance with State environmental regulations. Hazardous waste manifests, non-hazardous waste manifests, Bills of Lading, Record of Recycling, and any other documentation requiring a generator’s signature must be signed by the primary or secondary Fort

Jackson Hazardous Substance Program Manager. The documentation must be provided to the

Hazardous Substance Program Manager at least one week prior to shipment. The Generator ID

Number, name, mailing address, and phone number are shown below:

SC3210020449

US ARMY GARRISON, FORT JACKSON

ENVIRONMENTAL DIVISION

2562 ESSAYONS WAY

FORT JACKSON SC 29207-5608

803-751-5971/803-319-4618

e. Inspection and cleaning of oil-water separators (OWS) and washracks must occur at least annually. Records of the inspection and waste disposal must be submitted to the Wastewater mailto:sherri.e.robinson2.ctr@mail.mil mailto:lisa.a.mcknight11.civ@mail.mil

Program Manager. For additional information, contact Mark Merritt, Wastewater Program

Manager, at 803-751-3838 or mark.d.merritt6.civ@mail.mil.

f. The project site is located within the cantonment area. The Contractor shall immediately notify

ENV and the Contracting Officer (KO)/COR of the project of any indication(s) of broken piping, compromised structure, etc. from all equipment covered under this contract including, but not limited to, underground storage tanks, aboveground storage tanks, OWSs, and washracks, which may be suspected or has resulted in the release of materials beyond the contained design of the equipment. The Contractor shall immediately notify ENV and the KO/COR of the project if any evidence of materials (visual, olfactory, staining, etc.) potentially impacted by petroleum, solvents, unknown chemicals, and/or landfill materials are discovered in soil, surface water, or groundwater. The Contractor shall immediately notify the Explosive Ordnance Disposal Unit

(803-751-5126/910-624-2739) if suspected munition debris or unexploded ordnance are discovered. The Contractor shall also notify the KO and ENV. For additional information and/or notification, contact Zachary Tice, Installation Restoration Program (IRP) Manager, at 803-751-

7332 or Zachary.A.Tice.ctr@mail.mil.

f. The Contractor shall ensure the addition and removal of any type of refrigerant is performed by a mechanic certified to EPA, Title VI standards. Refrigerant must be handled, stored, and disposed in accordance with Federal regulations. The use of Class I Ozone Depleting Substances

(ODS) is prohibited. If the unit (containing 50 pounds of ODS or more) is leaking, a leak rate calculation must be made and an initial leak check must be performed at the end of the service. A follow up leak check must be performed within 10 days of the repair. The following information must be provided to the Air Program Manager (if applicable): (1) records that indicate the amount of refrigerant added or removed from an appliance; and (2) records documenting the date and type of service. If the refrigerant removed from the unit is R-22, the Contractor shall collect the R-22 in an approved, properly labeled container and turn it in to ENV. Information pertaining to the newly installed unit(s) must be submitted to the Air Program Manager. This information shall include (but is not limited to): unit location, installation date, manufacturer, model, serial number, fuel source (if applicable), and manufacturers suggested maintenance schedule.

If the proposed project includes the addition of an air emissions source(s) and/or the modification of an existing source(s) which results in an increase of air emissions, a construction permit or a construction permit exemption must be obtained from the SCDHEC, Bureau of Air Quality

(BAQ). The construction permit or permit exemption must be received from BAQ prior to the initiation of this project. The permitting process may take as many as 180 days to complete.

Please coordinate with the Air Program Manager on the permitting process.

The Contractor must meet the requirements of Federal regulations 40 CFR Part 60 IIII, JJJJ or 40

CFR Part 63 ZZZZ when performing preventive maintenance on stationary generators. All maintenance documentation for the generators must be provided to Christy Pollock. For additional information, contact Christy Pollock, Air Program Manager, at 803-751-6629 or

Christina.b.pollock.civ@mail.mil.

g. The Contractor shall perform tightness testing and leak detector function checks on underground storage tank (UST) systems in accordance with State and Federal regulations within mailto:mark.d.merritt6.civ@mail.mil mailto:Zachary.A.Tice.ctr@mail.mil mailto:Christina.b.pollock.civ@mail.mil

1 year of the last test. Copies of the final report for all UST testing must be submitted to ENV.

For additional information, contact Christy Pollock, Spill Prevention, Control, and

Countermeasure (SPCC) Program Manager, at 803-751-6629 or christina.b.pollock.civ@mail.mil.

9. SUBMITTALS DUE TO THE DPW ENVIRONMENTAL DIVISION:

TOXICS:

Pre-Abatement (at least 1 week prior to the start of the project)

- Asbestos Abatement Plan

Pre-Abatement (4 days prior to the start of the project)

- SCDHEC approved Asbestos Abatement Project License

Post-Abatement (Within 45 days of completion)

- Copy of the Certificate of Liability Insurance coverage documentation

- Copy of EPA training certificates and SCDHEC Licenses for individuals on the job site.

- Copy of the Asbestos Waste Shipment Record and Landfill Disposal Weight Tickets

RECYCLING, REUSE, AND DISPOSAL (if taken off-post):

Upon completion of the project:

- Documentation identifying the amount, by weight, of waste reused, recycled, composted, or disposed, and the name of the receiving facility.

NON-HAZARDOUS/HAZARDOUS WASTE (HW)/UNIVERSAL WASTE (UW):

At least one week prior to shipment:

- Manifest, for both HW and non-HW

- Other shipping document (such as Bill of Lading or a Record of Recycling) for waste batteries or lamps (light bulbs)

- Laboratory analysis if applicable/necessary

- Waste Profile Form and all supporting documents to include Safety Data Sheet

- Land Disposal Restriction Form (must accompany HW manifest)

WASTEWATER:

- Records of the OWS/washrack inspections and waste disposal.

IRP:

Immediate Notification:

- Any evidence of a materials potentially impacted by petroleum, solvents, munitions, unknown chemicals, metals, and/or landfill materials.

- Any indication(s) of broken piping, compromised structure, etc. from all equipment covered under this contract.

AIR QUALITY:

Within one week of completion:

- Information on newly installed unit(s), including: location, install date, manufacturer, model, serial number, fuel source, and maintenance schedule.

- Generator maintenance documentation.

mailto:christina.b.pollock.civ@mail.mil mailto:christina.b.pollock.civ@mail.mil

- Reclaimed R-22 that can no longer be used must be turned in to ENV.

- Leak check calculations and recheck records on equipment containing 50 pounds or greater of ODS.

SPCC:

Within one week of completion:

- Copies of the final reports for all UST testing

10. NEPA Review

The proposed project has not been segmented, and no extraordinary circumstances exist, as defined in 32 CFR 651.29. The proposed project is categorically excluded under the provisions of CX g(1), 32 CFR Part 651, Appendix B: Routine repair and maintenance of buildings, airfields, grounds, equipment, and other facilities. Examples include, but are not limited to:

Removal and disposal of asbestos-containing material (for example, roof material and floor tile) or lead-based paint in accordance with applicable regulations; removal of dead, diseased, or damaged trees; and repair of roofs, doors, windows, or fixtures (REC required for removal and disposal of asbestos-containing material and lead-based paint or work on historic structures).

11. For additional information, contact Sarah Smith, ENV, at 803-751-4231 or sarah.e.smith347.civ@mail.mil.

11/9/2020

X Sarah E. Smith

Sarah E. Smith

Signed by: SMITH.SARAH.ELIZABETH.1374408891

National Environmental Policy Act Coordinator, Environmental Management Branch

11/5/2020

X Barbara S. Williams

Barbara S. Williams

Signed by: WILLIAMS.BARBARA.S.1229241784

Chief, Environmental Division mailto:sarah.e.smith347.civ@mail.mil

Directorate of Public Works, Environmental Division (ENV)

This is a re-procurement of these same services that are currently ongoing at Ft. Jackson.