Attachment 15 - Completed AF Form 813 Construct Expeditionary South Fence.pdf

30 June 2022

MEMORANDUM FOR 325 CES/CEIEC

FROM: 325 FW/JA

SUBJECT: Legal Review – AF IMT 813 – Construct Expeditionary South Fence, Tyndall

AFB

1. You requested a legal review and sufficiency determination of the proposed categorical exclusion (CATEX) from further environmental analysis for this proposed action. I have reviewed the Request for Impact Analysis (AF IMT 813) titled “Construct Expeditionary South Fence” and find it legally sufficient.

2. Background. The proposed action will involve the construction of an anti-terrorism security fence South of Highway 98 along Cleveland Loop as an extension of Expeditionary Road, which will need to be approximately 760 linear feet to ensure the required stretch is fenced.

a. Site work will be performed including clearing and grubbing to allow for the construction of the fence.

(1). If a clear zone is used to meet Unified Facilities Criteria (UFC), the interior of the installation will be cleared approximately 7 feet from the fence. All vegetation and trees greater than 8 vertical inches will be removed within the clear zone.

(2). The fence will be 7 feet tall with 3-strand barbed wire on outriggers, per UFC 4- 022-03. A 3/8 inch aircraft cable run through the fence line is needed to deter vehicle ramming.

The fence poles will have 3-feet concrete footers in the ground.

b. The no-action alternative would result in maintaining the status quo. If the Status Quo is maintained, the installation will be at substantial risk of unauthorized personal entering Expeditionary Road from the West side of Cleveland Loop.

c. The proposed action is described as meeting CATEX A2.3.11, “Actions similar to other actions which have been determined to have an insignificant impact in a similar setting as established in an EA resulting in a FONSI.” The Environmental Assessment for Hurricane Recovery and Installation Development at Tyndall Air Force Base, April 2020, (hereafter “Recovery EA”) is the approved environmental document cited for use of this CATEX. This construction project is in the same general area, similar in nature and minor in scope as compared to projects evaluated in the EA. 325 CES/CEIE has conducted an evaluation of the EA to ensure the document is still valid in accordance with 32 CFR 989.20 (c), including on-

DEPARTMENT OF THE AIR FORCE

325TH FIGHTER WING (ACC)

TYNDALL AIR FORCE BASE FLORIDA

site survey, finding the methodology and analytical approach previously used is appropriate for the proposed action; the direct and indirect impacts of the proposed action are not significantly different from those identified in the existing document; the proposed action would not change the previous analysis of cumulative impacts; public involvement in the referenced analysis provides appropriate coverage for the proposed action; and there has been no significant change in circumstances or significant new information relevant to the proposed action.

3. Discussion. An AF IMT 813 Review Checklist is attached summarizing my review findings.

a. The Recovery EA resulting in a FONSI evaluated the proposed demolition, construction and renovation of numerous facilities throughout the installation that were severely damaged by Hurricane Michael in 2018. That proposed action included evaluation of 28 individual projects spanning six planning areas throughout the installation, as well as three additional projects that covered more than one planning area (Multi-Area projects). The action included demolition, redesign and construction of hundreds of thousands of square feet of new roadways, buildings and utilities necessary to their use in various base locations. Mitigation measures identified by the FONSI include: “Wherever possible as determined by final design, elevate all facilities above the base flood elevation, apply construction period erosion and sedimentation controls, and use pervious surfaces for stormwater retention and treatment.” The FONSI also identifies the need to obtain needed permits to include stormwater permits, while the EPF’s analysis of water resources for this AF 813 contains specific requirements to obtain the necessary permits and use of BMPs consistent with the Recovery EA & FONSI. The purpose of implementing the installation development projects at Tyndall AFB was to recover mission capabilities at Tyndall AFB impacted by Hurricane Michael, and rebuild Tyndall AFB to a fully operational base, thereby providing new facilities and infrastructure, as well as executing repair, demolition and functionality improvements necessary to support the mission of the 325 FW and tenant units. That EA resulted in a finding of no significant impact.

b. The project site is within the boundaries of Environmental Restoration Program (ERP) Site SR-170, which is undergoing a contamination study. Metals (lead, antimony, arsenic) and polycyclic aromatic hydrocarbons (PAHs) contaminated soils and groundwater have been identified as potential contaminants at SR-170. Construction projects within ERP site boundaries shall be conducted within the attached guidelines. If fill soil is needed, it must be certified clean IAW Non-ERP Soil Guidelines Section #3.

c. I find that the proposed action is sufficiently similar in nature and location to support application of A2.3.11 to this proposed action, taking into consideration the EPF’s updated environmental survey, tribal and historic consultation and analysis of the site finding no new information providing contrary indications or negative impacts, and assuming safeguards for environmental protection described in the proposed action are followed.

c. 32 C.F.R. 989 requires both air quality NEPA and General Conformity Rule assessments within the EIAP process. While 32 C.F.R. 989 Appendix B provides a list of CATEX actions that exclude further environmental analysis in an EA or an EIS, 32 C.F.R. 989.13(e) states that “application of a CATEX to an action does not eliminate the need to meet air conformity requirements”. Therefore, even if a proposed action has been excluded from further EIAP analysis based on a CATEX, further air quality analysis is required if a proposed action is located where General Conformity applies. Here, air conformity modeling resulted in a determination that a Conformity Determination is not required for this action. See Air Quality EIAP Guide Volume I, Table 5-2, List of General Conformity Exemptions; EIAP Guide p. 49;

40 CFR 93.153; Recovery EA, p. 4-2.

4. Recommendation. Proceed with the proposed action. The Request for Environmental Impact Analysis application of the cited categorical exclusion is legally sufficient. If you have any questions or concerns please contact me at 283-3238.

GERALD D. LAVER

Attorney-Advisor

Attachment:

AF IMT 813 Review Checklist, 28 June 2022

AF IMT 813 Review Checklist Construct Expeditionary South Fence

Mr. Gerald Laver, 28 June 2022 This checklist provides an overview for conducting a legal review of an AF IMT 813, Request For Environmental Impact Analysis (Form 813). The Air Force uses Form 813 to document the need for environmental analysis under the National Environmental Policy Act (NEPA), 42 U.S.C. Sec. 4321-4370f, or for certain Categorical Exclusions (CATEX) determinations for proposed actions. Generally, the AF IMT 813 is the starting point that initiates the AF Environmental Impact Analysis Process (EIAP). An attorney reviews the AF IMT 813 to ensure the proposed project meets the requirements of NEPA and the EIAP. If after completing the checklist, any one of blocks 1-19 are not checked or marked N/A, the AF Form 813 will be legally insufficient.

The AF EIAP regulation can be found at 32 CFR Part 989. AFI 32-7061, The Environmental Impact Analysis Process which adopts 32 CFR Part 989, is the controlling instruction for AF EIAP. CATEX determinations and descriptions identified by number are found in 32 CFR Pt 989 Appendix B.

If you have questions not addressed by the checklist, or you are uncertain about the sufficiency of the analysis in any portion of the AF Form 813, please contact your MAJCOM-ELO (Maj Milott). If you are coordinating with the Environmental Law Field Support Center Planning and Sustainment Branch, they may be contacted at 210-395-8998, DSN 969-8998 or by email at afloa.jaceps@us.af.mil.

Check if Met

Comments

SECTION I - PROPONENT INFORMATION

1. Blocks 1-3, Blocks 6-6b have been completed

Blocks comprised of self-explanatory administrative data.

X

2. Block 4 - Proponent has included a purpose and need statement in block or in an attachment.

3. Purpose statement clearly describes what the proponent intends to accomplish with the action.

4. Need statement clearly identifies why the proposed action is necessary.

Examples could include mission requirements or legal/regulatory changes, etc.

5. Block 5- Description of Proposed Action and Alternatives Proposed Action (DOPAA)

Block includes description of what action the proponent wants to take.

6. Description of proposed action is sufficiently detailed to ensure it meets the purpose and need as articulated in Block 4.

Block 5 may contain reasonable alternatives to the proposed action along with the no action alternative. Those items will be addressed at a later point in the checklist.

SECTION II – PRELIMINARY ENVIRONMENTAL SURVEY

7. One of the columns under each Block 7-16

Checked.

8. Blocks 7-16 Assessment makes sense based upon the type of action

Use common sense, for instance, if the proposed action requires filling some portion of a wetland and block 12 no effect is checked there are likely questions that you need to ask the environmental planner.

The project site is within the boundaries of Environmental Restoration Program (ERP) Site SR170 which is undergoing a contamination study.

Metals (lead, antimony, arsenic) and polycyclic aromatic hydrocarbons (PAHs) contaminated soils and groundwater have been identified as potential contaminants at SR-170. Construction projects within ERP site boundaries must be conducted within the guidelines provided. If fill soil is needed, it must be certified clean IAW Non-ERP Soil Guidelines Section #3.

9. Action assessed to have unknown environmental impacts If NO then mark as N/A.

If the action has any unknown effects, the decision maker cannot determine that unknown effects are not significant. A CATEX cannot be applied at this time and an Environmental Assessment (EA) or Environmental Impact Statement (EIS) should be considered.

N/A

10. Action assessed to have potential adverse effects in blocks 7-16.

If NO, then mark as N/A.

If an action has any potential adverse effect it will probably result in an Environmental Assessment (EA) or an Environmental Impact Statement (EIS) and will not qualify for a categorical exclusion

(CATEX)

If uncertain contact ELO or Planning and Sustainment Branch of ELFSC.

SECTION III – ENVIRONMENTAL ANALYSIS DETERMINATION

11. Block 17 indicates a CATEX is applicable.

If NO Mark Checklist Items 11-15 N/A and skip to

12. CATEX applied has been identified by number

CATEX descriptions identified by number are found in 32 CFR Pt 989 Appendix B

CATEX A2.3.11, “Action similar to other actions which have been determined to have an insignificant impact in a similar setting as established in an EA resulting in a FONSI.” The Environmental Assessment for Hurricane Recovery and Installation Development at Tyndall Air Force Base, April 2020, is the approved environmental document cited for CATEX.

13. CATEX applied is consistent with the description of the proposed action.

If NO, determine if another CATEX in Appendix B might apply. If one does discuss with environmental planner and have form accomplished again.

If uncertain about the proper application of a particular CATEX contact ELO or Planning and Sustainment Branch of ELFSC.

Proposed action is in the same general area and similar to proposed actions evaluated in the EA resulting in a FONSI.

14. Review 32 CFR 989, Appendix B, A2.2. Categories of Actions with “unique circumstances” described in subparagraphs have not been implicated.

If categories have been implicated, application of a CATEX may be legally insufficient and additional analysis may be required.

If uncertain whether A2.2 has been implicated or whether it precludes the application of a CATEX, contact ELO or Planning and Sustainment Branch of

ELFSC

Certain CATEX’s will require review of additional documents, you must be certain to review all necessary documentation that supports analysis. Two common instances are listed below. Review CATEX to determine if other documentation also needs review.

A2.3.7 requires proposal to have been originally evaluated in accordance with applicable regulations.

A2.3.11 requires proposal to be sufficiently similar to other project with EA/FONSI or EIS (an EBS is insufficient).

15. Use of CATEX is consistent with Preliminary

Environmental Survey

Checklist Item #9 MUST be marked N/A

Checklist Item #10 MUST be marked N/A OR you have consulted your environmental planner and/or ELO and are satisfied that the application of a CATEX is consistent with 32 CFR 989.13(b)

32 CFR 989.13 provides guidance regarding the applicability of a CATEX. Per 989.13(b) categories of actions that ordinarily do not require an EA or EIS include: “Minimal adverse environmental impacts.”

If adverse impacts are indicated further environmental study is then ordinarily done, however, if the action fits within CATEX and the adverse impacts are consistent with 32 CFR 989.13(b)(1) document may be considered legally sufficient.

16. Block 17 - indicates further environmental analysis required.

If NO mark as N/A then move to Checklist Item #17.

17. Block 17 – not completed

If Either box on Block 17 has been checked mark as N/A.

There may be instances where the AF Form 813 is being used to record the fact that environmental issues were considered but that neither a CATEX nor further study was required. In this instance you should see some further information in Block 18 of the form. If you encounter this situation, contact your ELO or the ELFSC Planning and Sustainment Branch to discuss prior to determining legal sufficiency.

18 Block 18 offers valid explanation how AF Form 813 is being used to create a record of environmental consideration when an action is not subject to a CATEX and does not require further environmental analysis.

An example of a situation where this would apply is where an action that does not fit into a CATEX and there will clearly be NO environmental impacts arising from the action but a record is required

Circumstances where this would occur are likely to be rare, please contact ELO or Planning and Sustainment Branch of ELFSC to discuss.

19. Block 18 includes a statement indicating that conformity requirements pursuant to Section 176(c) of the Clean Air Act have been addressed. See 32

CFR 989.30

Action will occur within an attainment area, making the action exempt from General Conformity (GC). See Air Quality EIAP Guide Volume I, Table 5- 2, List of GC Exemptions; EIAP Guide p. 49; 40 CFR 93.153.

Possible examples of an appropriate statement could be:

“The proposed action will occur in an area that is in attainment for all criteria pollutants and no conformity determination under the Clean Air Act is required”; or

“The proposed action will occur in an area that is in nonattainment for [insert criteria pollutant]; however emissions from the action will be de minimus so no conformity determination under the Clean Air Act is required.”

Note: If Block 17 indicates that further environmental analysis must be completed, conformity requirements will be addressed in the EA/EIS and this checklist Item may be checked.

If you have questions contact your ELO or the Planning and Sustainment Branch of ELFSC to discuss.

ACAM Modeling was performed, based on the results the air quality in the area would not be significantly impacted by the proposed project; therefore a conformity determination is not required.

If GC is otherwise required, conformity exemption based on CATEX A2.3.11 is available if the prior FONSI action evaluated air quality and identified air quality impact as not significant using the 2014 (or newer) version of ACAM, and the new proposed action’s scope, activity, and size are equal to or less than the prior FONSI action. Air conformity modeling was conducted for this project as part of the referenced EA, based upon which a Conformity Determination is not required for this action.

The Final Environmental Assessment for Hurricane Recovery and Installation Development at Tyndall Air Force Base, Florida meets these criteria, see vol. 1, pp. 4-1 to 4-5. Scope, activity and size of this action is less than that studied by referenced action which found for the actions studied that “Proposed Actions, all attainment criteria pollutants are below the significance indicators presented in Tables 4.1-1a through 4.1-1g.

Therefore, the potential air quality impact from all criteria pollutants is insignificant.”

20. Block 18: information in block does not impact the previously reviewed information.

If Block 18 does impact previous analysis, reconcile questions before determining legal sufficiency.

If you are uncertain about whether comments included in Block 18 call into question the other Checklist Items previously reviewed, contact ELO or Planning and Sustainment Branch at ELFSC for assistance.

21. Return to Block 5 on Form 813

Block 5 Includes reasonable alternatives to the Proposed Action (ONLY REQUIRED IF

FURTHER ENVIRONMENTAL ANALYIS

REQUIRED)

AF must analyze reasonable alternatives for all EA’s and EIS’s. See 32 CFR 989.8(a). The Block 5 DOPAA will serve as the basis for the DOPAA in an EA/EIS if needed and should identify reasonable alternatives.

Sometimes proponent will include reasonable alternatives for projects subject to valid CATEX.

This is acceptable but not required.

22. Block 5 identifies that No action alternative is included in DOPAA.

Unless otherwise excused by law the no action alternative must be analyzed. See 32 CFR 989.8(a).

(ONLY REQUIRED IF FURTHER

ENVIRONMENTAL ANALYSIS REQUIRED)

Sometimes proponent will include no action alternative for projects subject to valid CATEX.

This is acceptable but not required.

If the Status Quo is maintained, the installation will be at substantial risk of unauthorized personal entering Expeditionary Road from the West side of Cleveland Loop.

AF FORM 813, 19990901 (EF-V1) Page 1 of 2THIS FORM CONSOLIDATES AF FORMS 813 AND 814.

PREVIOUS EDITIONS OF BOTH FORMS ARE OBSOLETE.

REQUEST FOR ENVIRONMENTAL IMPACT ANALYSIS

SECTION I - PROPONENT INFORMATION

INSTRUCTIONS: Section I to be completed by Proponent; Sections II and III to be completed by Environmental Planning Function.

Continue on separate sheets as necessary and reference appropriate item number(s).

1. TO (Environmental Planning Function)

325 CES/CEIEC

2. FROM (Proponent organization and functional address symbol)

325 CES/CENPD

2a. TELEPHONE NO.

(850) 283-2984

3. TITLE OF PROPOSED ACTION

Construct Expeditionary South Fence

4. PURPOSE AND NEED FOR ACTION (Identify decision to be made and need date)

The Purpose and Need For Action is attached. See Page 2.

5. DESCRIPTION OF PROPOSED ACTION AND ALTERNATIVES (DOPAA) (Provide sufficient details for evaluation of the total action)

The Description of Proposed Action and Alternatives is attached. See Page 2

6. PROPONENT APPROVAL (Name and Grade) Bryan Hurt, GS 0-9

6a. SIGNATURE 6b. DATE 02/28/2022

SECTION II - PRELIMINARY ENVIRONMENTAL SURVEY (Check appropriate box and describe potential environmental effects including cumulative effects) (+=positive effect; 0=no effect; - = adverse effect; U=unknown effect) + 0 - U

7. AIR INSTALLATION COMPATIBLE USE ZONE/LAND USE (Noise, accident potential, encroachment, etc.)

8. AIR QUALITY (Emissions, attainment status, state implementation plan, etc.)

9. WATER RESOURCES (Quality, quantity, source, etc.)

10. SAFETY AND OCCUPATIONAL HEALTH (Asbestos/radiation/chemical exposure, explosives safety quantity distance, bird/wildlife aircraft hazard, etc.)

11. HAZARDOUS MATERIALS/WASTE (Use/storage/generation, solid waste, etc.)

12. BIOLOGICAL RESOURCES (Wetlands/floodplains, threatened or endangered species, etc.)

13. CULTURAL RESOURCES (Native American burial sites, archaeological, historical, etc.)

14. GEOLOGY AND SOILS (Topography, minerals, geothermal, Installation Restoration Program, seismicity, etc.)

15. SOCIOECONOMIC (Employment/population projections, school and local fiscal impacts, etc.)

16. OTHER (Potential impacts not addressed above.)

SECTION III - ENVIRONMENTAL ANALYSIS DETERMINATION

17. PROPOSED ACTION QUALIFIES FOR CATEGORICAL EXCLUSION (CATEX) # ; ORA2.3.11

PROPOSED ACTION DOES NOT QUALIFY FOR A CATEX; FURTHER ENVIRONMENTAL ANALYSIS IS REQUIRED.

18. REMARKS

ACAM Modeling conducted and conformity determination is not required.

19. ENVIRONMENTAL PLANNING FUNCTION CERTIFICATION

(Name and Grade) Edwin Wallace, GS-12

19a. SIGNATURE 19b. DATE

HURT.BRYAN.E.1113058389

Digitally signed by

HURT.BRYAN.E.1113058389

Date: 2022.04.29 11:27:07 -05'00'

WALLACE.EDWIN.

BLAIR.1047698347

Digitally signed by

WALLACE.EDWIN.BLAIR.1047698

Date: 2022.06.10 07:40:32 -05'00'

Construct Expeditionary South Fence, AF Form 813 continuation sheet

4.0 Purpose and Need for Action:

The purpose of the proposed action is to construct a security fence south of Highway 98 along Cleveland Loop as an extension of Expeditionary Road.

The action is needed due to support and protect 325 Security Force Squadron (SFS) control point for commercial vehicles before entering the tertiary gate at Expeditionary Road, which will allow commercial vehicles access onto flight side of Tyndall AFB.

5.0 Description of the Proposed Action and Alternatives (DOPAA):

The proposed action will involve the construction of an anti-terrorism security fence South of Hwy. 98 along Cleveland Loop as an extension of Expeditionary Rd. The fence will need to be approximately 760 LF to ensure the required stretch is fenced. Site work will need to be performed including clearing and grubbing to allow for the construction of the fence. Clear approximately 7 FT from the fence on the interior of the installation if a clear zone is used to meet UFC criteria. All vegetation and trees greater than 8 vertical inches will be removed within the clear zone. The fence will be 7 ft. tall with 3-strand barbed wire on outriggers, per UFC 4- 022-03. A 3/8in aircraft cable run through the fence line is needed to deter vehicle ramming. The fence poles will have 3 FT concrete footers in ground.

No Action Alternative: Status Quo. If Status Quo is maintained, leaves substantial risk of unauthorized personal entering Expeditionary Rd. from the West side of Cleveland Loop.

5.1 Anticipated Environmental Issues:

None

5.2 Environmental Impacts:

AICUZ/ Noise:

The proposed actions would result in a localized and temporary increase in noise levels due to construction and demolition. This noise is not expected to be significant. The proposed action would not significantly contribute to the noise levels of the area.

Air Quality:

Tyndall AFB is in an attainment area for National Ambient Air Quality Standard. The FESOP permit for Tyndall AFB will not be violated by the implementation of the proposed project.

Temporary minor exhaust emissions would occur in the immediate vicinity of the construction.

Fugitive dust would be controlled at the sites using best management practices (BMPs), such as periodic watering of cleared areas and stockpiled materials and mulching or vegetative cover for the cleared areas. ACAM Modeling was performed and based off the results the air quality in the area would not be significantly impacted by the proposed project; therefore a conformity determination is not required.

Water Resources:

Best management practices for erosion control shall be implemented prior to construction activities and maintained at all times during construction to prevent siltation and turbid discharges. Install erosion control measures along the perimeter of all work areas to prevent the displacement of fill material outside the work area into waters of the United States. Immediately after completion of the final grading of the land surface, all slopes, land surfaces, and filled areas shall be stabilized using appropriate vegetation, degradable mats, barriers, or a combination of similar stabilizing materials to prevent erosion.

Methods could also include, but are not limited to the use of staked hay bales, staked filter cloth, sodding, seeding, and mulching; staged construction; and the installation of turbidity screens around the immediate project site. Identify and cover Stormwater structures using protection devices before performing any work. Devices must remain in place until all work is complete and the area has been cleaned and free of construction potential discharges. The erosion control measures shall remain in place and be maintained until all work is completed and the work areas are stabilized.

There shall be no work, storage, or stockpiling of tools, materials (i.e. lumber, pilings, debris) within wetlands, ditches, swales, or elsewhere within waters of the state unless authorized by permit. All stormwater conveyance structures shall remain in operable condition and shall not be allowed to deteriorate or otherwise contribute to a water quality violation. Construction activities shall be conducted in a manner that does not cause or contribute to violations of state water quality standards.

An FDEP permit maybe required for the installation, maintenance, repair, and removal of underground utility lines, cable, conduit, or pipeline transmitting electricity, communication signals, potable water, raw water, reclaimed water, domestic wastewater, propane gas or natural gas. 62-330.453 within the Florida Administrative Code dictates that a General Permit is needed for Installation, Maintenance, Repair, and Removal of Utility Lines that cross a regulated surface of the state. In this case the ditches/swales maybe considered a regulated surface water.

All electric, gas, water, sewer, and other services lines should be shut off, capped, or otherwise properly controlled, at or outside the building before demolition work is started. In each case, any utility company that is involved should be notified in advance, and its approval or services, if necessary, shall be obtained. Coordinate with the 325 CES/CEIC, GCEC, and Bioenvironmental regarding flushing and water quality sampling prior to and after performing any work.

If it is necessary to maintain any power, water, sewer, or other utilities during demolition, such lines shall be temporarily relocated as necessary and/or protected. The location of all power sources should also be determined, as they can prove especially hazardous during any machine demolition. All workers should be informed of the location of any existing or relocated utility service. Coordinate with the 325 CES/CEIC, GCEC, and Bioenvironmental regarding flushing and water quality sampling prior to and after performing any work.

All material used as fill shall be clean sand/fill dirt/shell material and shall not be contaminated with vegetation, garbage, trash, tires, hazardous waste, or other materials that are not suitable for construction.

A Construction Generic Permit (CGP)/Notice of Intent (NOI) will not be required from the FDEP. Any act or process of developing or improving land, including demolition and renovation activity, which involves the disturbance of soils not limited to, clearing, grading, and excavation that reaches an acre of total disturbed area would require the CGP. This permit is different than an ERP. This permit does include dewatering. If dewatering is needed, please coordinate with the 325 CES/CEIEC, additional permits maybe required.

UFC 3-201-01 – Civil Engineering provides planning, design, construction, sustainment, restoration, and modernization criteria, and applies to the Military Departments, the Defense Agencies, and the DoD Field Activities in accordance with USD (AT&L) Memorandum dated 29 May 2002. This UFC will be used for all DoD projects and work for other customers where appropriate.

Section 3-3.2 – Erosion and Sediment Control states “Design erosion and sediment controls that minimize the discharge of pollutants from earth disturbing activities in conformance with the applicable requirements of the regulatory agency with jurisdiction over the Installation regarding erosion and sediment control. Where requirements do not exist, provide an erosion and sediment control plan in accordance with the requirements of Environmental Protection Agency’s (EPA’s) Construction General Permit.”

This project will require a Stormwater Pollution Prevention Plan (SWPPP) in accordance with the Florida Department of Environmental Protection (FDEP)/EPA standards. Please provide a SWPPP for review. The FDEP has generated a template to be used (https://floridadep.gov/sites/default/files/ConstructionSWPPP.pdf). Work specific Best Management Practices (BMP’s) shall be implemented prior to construction activities and maintained at all times during construction to prevent siltation and turbid discharges. Identify and cover Stormwater structures using protection devices before performing any work. The BMP’s are to be installed along the perimeter of all work areas to prevent the displacement of fill material outside the work area into surface waters, stormwater inlets, etc. Immediately after completion of the final grading of the land surface, all slopes, land surfaces, and filled areas shall be stabilized using approved sod, seeding, degradable mats, staked hay bales, staked filter cloth, barriers, turbidity screens, or a combination of similar stabilizing materials to prevent erosion.

The erosion control measures shall remain in place and be maintained until all authorized work is completed and the work areas are stabilized and verified by USAF personnel.

If jurisdictional waters of the state or United States are proposed for impact, permitting will be required through the FDEP and/or USACE. Additional coordination with the 325 CES will be required. Jurisdictional waters could include ditches, swales, wetlands, etc.

Soil Impact:

The project site is within the boundaries of Environmental Restoration Program (ERP) Sites SR170 and undergoing a contamination study. Metals (lead, antimony, arsenic) and polycyclic aromatic hydrocarbons (PAHs) contaminated soils and groundwater have been identified as potential contaminants at SR-170. Construction projects within ERP site boundaries shall be conducted within the attached guidelines.

If fill soil is needed, it must be certified clean IAW Non-ERP Soil Guidelines Section #3.

Cultural Resources Impact:

The Area Potential Effect was coordinated with the State Historical Preservation Office and a finding of no adverse effect was received. All work should cease and the Cultural Resources Manager should be contacted if archaeological deposits or human remains are encountered.

Contractor must be trained on inadvertent discoveries, training pamphlet will be provided.

Hazardous Materials:

A letter of review from 325 CES/CEIEC Must be accomplished prior to commencement of work.

The contractor shall submit TAFB Form 81 (Contractor Questionnaire) and TAFB Form 82 (Chemical Inventory) if applicable (within 10 duty days after the Notice to Proceed is issued), for review.

The Contractor should note that Tyndall AFB is required to report chemicals used such as (but not limited to) compressed gases, adhesives, aerosol cans, sealants, paints, lubricants, oils, cleaners, degreasers, pesticides, Fuels. Copies of manufacturer-specific Safety Data Sheets (SDS) must be attached to TAFB Form 82. These SDSs shall also be readily accessible at the location of each hazardous material. After submission, 325 CES/CEIE will notify the Project Manager and/or CONS of the reportable chemicals and of any special instructions. As directed by the CO, the Contractor is required to submit TAFB Form 83 (Reporting Entry Form) showing material usage monthly until completion of the task order. The CO must be notified of any changes from the original submittal (i.e. new chemical is added, size of container or unit of issue changes or if the manufacturer changes), changes must be submitted using TAFB form 82. An updated letter of review indicating changes will be sent from CEIEC to the Contracting Office before the material can be brought onto the installation. Prime contractors shall be responsible to ensure all sub-contractors comply with this section.

Hazardous Waste:

A Hazardous Waste Determination must be conducted/recorded and submitted to CEIEC for all wastes generated during the execution of this project IAW 40 CFR 262.11. A worksheet is attached to accomplish the requirement.

The personnel conducting Hazardous Waste Determinations and those individuals who may generate or manage Hazardous Waste must have annual Hazardous Waste Training that complies with 40 CFR 262.17(a)(7).

Any containerized waste must maintain compliance with EPA, DOT, and OSHA’s HAZCOM requirements.

Solid Waste:

Construction activities associated with the Proposed Action would result in a short-term increase in solid waste generated at Tyndall AFB. The contractor would be responsible for disposing of solid waste in accordance with all federal, state, and local laws.

Digging/Excavation:

Prior to any digging, an excavation permit will be required. An Air Force Form103, BCE Work Clearance Request, will be required. SWPPP must be submitted and approved before Environmental will sign.

5.3 List of required permits:

Permits may be required for the proposed action. Contractor is responsible to ensure all permits are submitted to the 325 Civil Engineer Squadron for review.

5.4 CATEX Statement:

The proposed project will not adversely impact Tyndall AFB environmental attributes; therefore, qualifies for Categorical Exclusions (CATEX) A2.3.11. Actions similar to other actions which have been determined to have an insignificant impact in a similar setting as established in an EIS or an EA resulting in a FONSI. The EPF must document application of this CATEX on AF Form 813, specifically identifying the previous Air Force approved environmental document which provides the basis for this determination.

The Environmental Assessment Hurricane Recovery and Installation Development, dated April 2020, is the Air Force approve document which form the basis for using this CATEX.

The construction project is in the same general area and the proposed actions are identical to those evaluated in the EA. 325 CES/CEIE has conducted an evaluation of subject EA to ensure the document is still valid in accordance with 32 CFR 989.20 (c). As part of the re-evaluation, CEIE personnel conducted an on-site survey and found that the affected environment and environmental consequences:

1. The methodology/analytical approach previously used is appropriate for the proposed action.

2. The direct and indirect impacts of the proposed action are not significantly different than those identified in the existing document.

3. The proposed action would not change the previous analysis of cumulative impacts.

4. Public involvement in the referenced analysis provides appropriate coverage for the proposed action.

5. There has been no significant change in circumstances or significant new information relevant to the proposed action.

PROJECT ENVIRONMENTAL REVIEW SHEET

Project Title: Construct Fence Expeditionary South Project Description:

1. Natural Resources

Reviewed By: ___e.wallace__________________ Does project affect BASH? YES ____ NO __X__ Does project affect wildlife management area? YES ____ NO _X___ Does project affect forestry management area? YES ____ NO __X__

2. Threatened and Endangered Species Reviewed By: ____e.wallace_________________ X__ Project has no potential for affecting threatened or endangered species or critical habitats.

__ Based on advice from USFWS _____, threatened or endangered species in the vicinity of the project will not be affected.

__ Consultation with USFWS underway in accordance with the Endangered Species Act.

__ Formal Consultation with the Regional Director, USFWS completed on ______.

__ Biological Assessment is required. Estimated completion date completion date is ______.

__ Biological opinion issued by USFWS on ______.

__ Informal consultation may be required if the impact to T & E’s is not likely to effect the species __ Formal consultation may be required if the impact may affect them, but not adversely __ Formal consultation will be required if it may affect them adversely Note: A Biological Evaluation will be required for Informal consultation and a Biological Assessment will be required for Formal consultations

3. Cultural Resources Cultural Resources Reviewed By: ____e.wallace_________________ __ Consultation required with State Historical Preservation Officer (SHPO) and Federally Recognized Tribes. Letters notifying parties dated ______.

__ Project area has not been surveyed for historic properties. Survey is required prior to project start.

__There are no cultural resources concerns with this project. The described actions of the project is exempted under the Programmatic Agreement.

__ Project area has been surveyed and no historic properties were identified.

__ Project area has been surveyed and identified historic properties but the project will have no adverse effect.

__ Project area identified historic properties will be adversely impacted. After consultation, project can proceed with specific mitigation guidelines.

__ Archeological Monitor is required. Please see attachment for monitoring guidance.

__ Mitigation measures can be found on attachment __ No MOA was developed and the formal comments of the Council are being sought or estimated date to execute the MOA is _______.

_X_ SHPO concurred that the project will have no adverse effect on historic properties dated 6/8/2022.

__ Tribes_______________ concurred that the project will have no adverse effect on historic properties dated ______.

_X_There are no cultural resources concerns with this project. However, if unexpected discoveries, such as Native American graves or lost historic cemeteries are encountered, guidelines set forth in Chapter 872, Florida Statute (Florida’s Unmarked Burial Law) must be followed. If human remains or archaeological materials are encountered during construction, work should cease immediately and the area secured. Contact the Tyndall AFB Cultural Resources office within 24 hours.

4. Water Programs Reviewed By: _____e.wallace________________

a. Jurisdictional Waters: State and/or Federal (Wetlands, ditches, swales, ponds, open water, etc.):

__ Is a permit required from either the Florida Department of Environmental Protection (FDEP) and/or U.S. Army Corps of Engineers (USACE)? Coordinate with NWFWMD and or FDEP __ Delineation survey is required. Estimated completion date______________ X__ Other: Project is not sited in a jurisdictional water

b. Flood Plain:

_X_ Project is not sited in a 100-year flood plain.

__ Requirements of EO 11990 in progress. Estimated completion date is ______ __ Project is sited in a 100-year flood plain. Requirements of EO 11990 completed on ______ __ Finding of "No Practicable Alternative signed ______

c. Water (Potable/Fire):

__ Construction permit required for extension of water system per 62.555, FAC.

__ No permit required because less than 2 in. diameter pipe and less than 100 if extension.

__ Backflow preventer(s) required. Must be field tested by licensed inspector upon installation.

__ Sprinkler system must have rain sensor device per FS 373.62.

__Well drilling/mod/abandonment must be conducted by a licensed contractor. Permit required per 4OC-

3, FAC.

X_ Other: No water required for this project.

__ Coordination with Bay County required for connection to Bay County Utility __Coordination with GCEC required for connection to GCEC Utility

d. Wastewater:

__ Construction permit required to connect to collection system per 62-600, FAC.

__ No permit required per 62-604.1 10 (single facility, gravity service connection, no pretreatment, compatible discharge) X__ Other: No wastewater required for this project.

e. Stormwater:

__ Stormwater permitting required?

a. Creates more than 4,000 ft2 impervious surface subject to vehicular traffic;

b. Creates more than 5,000 ft2 impervious surface; or

c. Project affects 5 acres or more (includes recreation areas, golf course, ball fields, etc.)

__ Site included in station stormwater master plan; permit required but may access existing stormwater treatment system. (Basin no. __________ pond no._________ ; approx ________________ s.f.)

__ Construction contractor must implement Stormwater Pollution Prevention Plan (SWPPP).

_X_ Project will require submittal of a SWPPP __ Upon completion site will be included in Base Stormwater Pollution Prevention Plan.

__ Other: No stormwater required for this project.

9. Potentially Regulated Substances

a. Asbestos:

__ Surveyed? (Y/N)_Date of survey: ____________ _N_ Asbestos present?

__ If asbestos is present, and renovation impacts asbestos, abatement will be required.

__ 10 day notification (FDEP Form 62-257.900(1) to FDEP is required prior to demo.

__ FDEP Form 62-257.900(1) approval date:___________ ID #:_____________

b. Lead Based Paint:

__ Surveyed? (Y/N)_Date of survey: ____________ _X_ LBP present? (No) __ If LBP is present, and renovation impacts LBP, abatement will be required.

c. Ozone Depicting Substances:

X__ Not present: _________ survey underway.

__ Present (describe mitigation, or state why mitigation is not necessary).

d. Polychlorinated biphenyls (PCBs):

_X_ Not present: _________ survey underway.

__ Present (describe mitigation, or state why mitigation is not necessary).

e. Other known hazardous or toxic substances and pollutants (e.g. contaminated soils, PFAS):

__ Not present: _________ survey underway.

X__ Present (guidelines attached).

10. Hazardous Materials _X_ Will chemicals (such as, but not limited to, compressed gases, adhesives, aerosol cans, sealants, paints, lubricants, solvents, oils, cleaners, degreasers and pesticides) be used?

__ Submit TAFB Form 81 (Contractor Questionnaire) and TAFB Form 82 (Chemical Inventory) 7-10 days upon issuance of the notice to proceed and prior commencement of work on site.

_X_ Submit copies of manufacturer-specific Safety Data Sheets

__ Submit TAFB Form 83 (Reporting Entry Form) monthly throughout the duration of the project or as indicated by CEIE.

_X_ Notify CEIE if anything changes from the original submittal (i.e. new chemical is added, size of container or unit of issue changes or if the manufacturer changes).

__ Will not use chemicals

11. Air Pollutants

Reviewed By: ______e.wallace_______________ __ Will not be generated by the operation or construction of this facility.

__ Will be generated by the operation or construction of this facility. Describe type and amount of substance expected to be generated, existing control systems, and the need for additional controls.

_X_ Conformity determination not required.

__ Conformity determination required.

__ Air construction permit required

12. Solid and Hazardous Wastes

Reviewed By: _________e.wallace______________ _X_ Facility will not be used for generating/managing solid and/or hazardous wastes.

__ Facility will be for generating/managing solid and/or hazardous waste.

__ Will the work being performed on the project generate any wastes?

__ Has a solid waste plan been submitted?

13. Storage Tanks

Reviewed By: _______e.wallace______________ _X_ No storage tanks are involved.

__ New storage tanks will be installed.

__ Existing tanks on the project will be removed. Ensure regulatory agency has been notified.

__ Contamination exists.

__ Contamination unknown.

__ Existing tanks on project will be retained.

14. Environmental Impact Analysis Process Reviewed By: ___e.wallace_________________ _X_ Categorical exclusion number _A2.3.11__ applies.

__ Environmental Assessment under preparation. Expected completion date is __________.

__ Finding of No Significant Environmental Impact signed on __________.

__ Draft Environmental Impact Statement (EIS) under preparation. Expected completion date is ____. __ Draft EIS filed on ___________.

__ Final EIS filed on ___________.

__ Record of Decision signed on __________.

__ Foreign nation or protected global resource exemption number ___________ applies.

__ Environmental study (or review underway) under preparation. Expected completion date is __ Environmental study (or review) completed on ___________.

__ Requirements of EO11990 in progress. Estimated completion date is ______________ __ Requirements of EO 11990 completed on ______________ __ Finding of "No Practicable Alternative signed ______________

15. Interagency and Intergovernmental Coordination for Environmental Planning Reviewed By: ______e.wallace_______________ X__ Coordination of proposed project with the state Single Point of Contact or other agencies is not required.

__ Coordination with the state Single Point of Contact is in progress. Expected date of completion is __ Proposed project was coordinated with the state Single Point of Contact or other agencies on _

16. Environmental Permits Reviewed By: ____ e.wallace_________________ X__ No permits are required unless dewatering is needed.

__ No permits required but regulatory agency notification required prior to construction (e.g.

underground storage tank removals).

__ Permits are required for this project.

17. Environmental Restoration Program (ERP)/Petroleum Contamination (PCA)

Reviewed By: ___ e.wallace__________________ __ Facility is not sited on or near an ERP/PCA site.

__ Facility is sited near an ERP/PCA site.

_X_ Facility is within the boundary of an IRP/PCA site. Guidelines attached .

__ The following activities must be coordinated with the IRP Manager:

excavation, sampling, and 40 hour H&S training.

__ The site is projected to be remediated and/or closed out on _________, prior to commencement of construction activities.

__ The nature of the site contamination does not preclude the type of construction activity proposed.

__ There is a Compliance Agreement associated with this site.

__ A Remedial Investigation/Feasibility Study was completed on _______ to accurately delineate the aerial extent of the contamination.

Comments

RON DESANTIS

Governor

CORD BYRD

Secretary of State

Division of Historical Resources

R.A. Gray Building • 500 South Bronough Street• Tallahassee, Florida 32399

850.245.6300 • 850.245.6436 (Fax) • FLHeritage.com

Mr. José J. Cintron June 8, 2022 Chief, Environmental Element 325th Civil Engineer Squadron 103 Mississippi Road (Building 36234) Tyndall Air Force Base, Florida 32403-5014

Re: DHR Project No.: 2020-4971-B

Proposed Installation of Expeditionary Road South Fence Tyndall Air Force Base, Bay County

Dear Mr. Cintron:

This office reviewed the referenced project for possible impact to historic properties listed, or eligible for listing, in the National Register of Historic Places. The review was conducted in accordance with Section 106 of the National Historic Preservation Act of 1966, as amended and 36 CFR Part 800: Protection of Historic Properties.

Based on the information provided and the conditions outlined in your letter concerning fortuitous finds or unexpected archaeological discoveries, it is the opinion of this office that the proposed undertakings will have no effect on historic properties.

If you have any questions concerning our comments, please contact Scott Edwards, Historic Preservationist, by electronic mail scott.edwards@dos.myflorida.com, or at 850.245.6333 or 800.847.7278.

Sincerely, Timothy A. Parsons, Ph.D.

Director, Division of Historical Resources and State Historic Preservation Officer

Environmental Restoration Program Guidelines

Work on ERP Site SR170 – Expeditionary Road South Fence Extension

11 May 2022

The project to install an anti-terrorism perimeter fence, approximately 760 LF, South of Highway 98, along Cleveland Loop, as an extension of Expeditionary Road is within the boundaries of Environmental Restoration Program (ERP) Sites SR170 and undergoing a contamination study. Metals (lead, antimony, arsenic) and polycyclic aromatic hydrocarbons (PAHs) contaminated soils and groundwater have been identified as potential contaminants at SR-170. There are no known PFOS/PFOA spill sites in the project area.

Construction projects within ERP site boundaries shall be conducted within the following guidelines. To the extent these guidelines conflict with provisions contained within the construction contract, Statement of Work, or approved work plans, those documents control.

1. It is the responsibility of the contractor to fulfill its obligation under 29 CFR 1910.120, Occupational Safety and Health Administration Standards (OSHA), Hazardous Waste Operations and Emergency Response (HAZWOPER), and address the health and safety of its employees associated with construction activities relative to this project.

2. Contaminated soil from excavation or construction activities may be temporarily moved within the IRP site, as long as it is subsequently redeposited in the same excavated area. Soils should be staged on visqueen and shall not leave that IRP site. Best management practices shall be utilized to prevent spreading contamination into previously uncontaminated or less contaminated areas within the IRP site. If soils are to be removed for disposal from the site, they shall be tested prior to disposal or reuse.

3. For disposal, waste soils must be tested utilizing the Toxic Characteristic Leaching Procedure (TCLP), analyzed for characteristic hazardous chemicals (40 CFR 260, Subpart C), and the results provided to Tyndall Restoration Program Manager (RPM) and the 325 Civil Engineer Squadron (CES) Hazardous Waste Program Manager (HWPM) prior to any transportation for proper disposal at an authorized disposal facility or may be conservatively handled as hazardous waste in accordance with appropriate hazardous waste laws and regulations if approved by Tyndall RPM and the 325 CES HWPM or required by the contract or statement of work.