Attachment 4 - Environmental Requirements for Construction and Renovation Projects-v9-20200121.pdf

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Prefabricated Build Fort Wainwright M320 Range ROCA Tower
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This document is an environmental requirements specification for construction, demolition, and renovation projects at U.S. Army Garrison Fort Wainwright, Alaska. It establishes mandatory environmental compliance protocols that contractors must follow across all Fort Wainwright lands, including training areas and satellite sites. Contractors are liable for any enforcement actions, fines, and penalties resulting from non-compliance with applicable environmental requirements per AR 200-1. The document mandates contractor attendance at environmental briefs during preconstruction meetings, preparation of comprehensive Environmental Protection Plans addressing multiple environmental concerns, and coordination with the DPW Environmental Division. Key environmental requirements include restoration site compliance with excavation clearance requests for ground-disturbing activities exceeding six inches, adherence to land use controls and institutional controls outlined in Garrison Policy #38, and strict protocols for handling known or suspected contaminated soils using work plans approved by the Army, EPA, and Alaska Department of Environmental Conservation.

The specification requires contractors to implement storm water management using low impact development best management practices, prepare Storm Water Pollution Prevention Plans with notice submissions to ADEC for projects disturbing one acre or greater, manage excavation dewatering through approved plans and permits, obtain temporary water use permits from Alaska Department of Natural Resources, design wastewater systems approved by ADEC, comply with backflow prevention requirements, manage hazardous waste disposal as contractor responsibility, implement spill notification and response procedures through Fort Wainwright Directorate of Emergency Services, manage solid waste through recycling and certified landfill disposal, control fugitive dust emissions 24/7, comply with head bolt outlet requirements for parking areas, obtain air quality construction permits when required, manage fuel storage tanks per federal standards, obtain wetland permits from USACE when applicable, comply with fish habitat permit requirements from Alaska Department of Fish and Game, implement migratory bird protections, and manage cultural resources through inadvertent discovery protocols. The primary environmental contact is Tamara Scholten at (907) 361-9622, and the document includes twelve detailed appendices addressing specific technical requirements for dust control, refueling operations, spill reporting, soil handling, storm water management, and cultural resource protection.

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IMFW-PWE

Version 8 October 2019

Environmental Requirements for Construction, Demolition, and Renovation Projects

A. The U.S. Army Garrison, Alaska, Fort Wainwright (USAG Alaska) is firmly committed to a policy of environmental stewardship for all lands and facilities under its control.

This policy is laid out in Garrison Policy Letter #37 Environmental Policy Statement, (Appendix A). In order for the USAG Alaska to effectively manage environmental resources that enhances mission performance, the planning, design, and execution of construction, demolition, and renovation projects must integrate environmental management processes from concept to final acceptance. The Directorate of Public Works (DPW) Environmental Division is available to assist with any questions regarding environmental requirements. Coordination with the Environmental Division shall occur through the appropriate Contracting Officers Representative (COR), DPW Engineering Project Manager, and/or DPW Engineering Quality Assurance Specialist.

B. The issues discussed herein are major concerns of the USAG Alaska DPW Environmental Division and shall be included in the planning, design, and implementation of projects on all lands managed by Fort Wainwright (FWA) including but not limited to Yukon Training Area (YTA), Tanana Flats Training Area (TFTA), Donnelly Training Area (DTA), Black Rapids Training Area (BRTA), Haines Terminal, Seward Recreation Area, and lands leased by Fort Wainwright. More specific guidance may be provided in the project scopes of work. The primary Environmental Division point of contact for construction, demolition, and renovation projects is Tamara Scholten (907) 361-9622.

C. Contractors shall attend an environmental brief to be included in the preconstruction meeting. Contractors shall provide at this time the anticipated use of hazardous materials, type(s) of waste or wastewater that may be generated during the project.

D. Part of each project is the preparation of an Environmental Protection Plan (EPP).

In addition to other requirements for the EPP (i.e. specifications) the plan shall specifically address how the contractor will comply with the issues listed herein.

Some areas identify a specific requirement for a plan (e.g. Erosion and Sediment Control Plan, Storm Water Pollution Prevention Plan, etc.). These may stand alone or be incorporated into an overall EPP. A copy of the plan(s) shall be provided to DPW Environmental Division for review and comment prior to the start of construction.

E. Per AR 200-1, Environmental Protection and Enhancement, 2-2. d., contractors shall be liable for any enforcement actions, fines, and/or penalties resulting from their failure to comply with applicable environmental requirements.

F. General Compliance Programs:

1. Restoration Sites:

a. All projects on the Installation, Training Areas, and satellite sites with ground disturbing activities of 6 inches or deeper must submit an Excavation Clearance Request (ECR or dig permit). All projects on or near a current or past restoration site will comply with Appendix B, Garrison Policy #38 Land Use Controls/Institutional Controls. Some sites contain monitoring wells, recording sensors and/or remediation systems. If the site contains any of these items, the contractor shall coordinate all staging and construction activities through the DPW Environmental Division. FWA Environmental Division, Resource Planning Branch, Restoration Program will determine the disposition of any such items on the site (i.e. removal, decommissioning, replacement, etc.).

b. Projects involving excavation of soils in areas of known or suspected contamination are required to adhere to a Work Plan, prepared by a qualified environmental professional in accordance with the Uniform Federal Policy for Quality Assurance Project Plans (UFP-QAPP), approved by Alaska Department of Environmental Conservation (ADEC) and Environmental Protection Agency (EPA), coordinated through the FWA Environmental Division prior to the start of work. Work Plans must be approved prior to Environmental Division approval of the ECR. Work Plans typically include field screening for petroleum products and/or other identified contaminants of concern and associated sampling and analysis. Regulatory review of the work plan can take up to 30 days for each submittal or re-submittal. Soils shall be managed in accordance with Appendix C, Handling/Management of Soil on Fort Wainwright

c. Projects involving excavation of soils that are not within known or suspected contamination, shall require submittal of a Simplified Field Screening Plan. The contractor shall screen for evidence of contamination based on presence of sheen, odor, staining, debris, or other evidence of contamination. If the contractor discovers evidence of contamination, work shall cease in the area of contamination and the contractor shall provide notifications as directed in the ECR. Work within the contaminated area shall not resume until clearance is given by the COR in consultation with DPW Environmental.

2. Storm Water:

a. Design: The incorporation of low impact development (LID) best management practices (BMP)s as a means to manage storm water is a requirement under the Army’s implementing guidance titled Army Storm Water Management Using Low Impact Development, 4, January 2013 with an effective starting date of FY15 for Military Construction Army, and all projects funded with other appropriations.

The storm water system shall also comply with the Fort Wainwright Storm Water Management Plan Nov 2016, and Alaska Pollutant Discharge Elimination System (APDES) permit. Storm water drainage wells (e.g., dry wells, bored wells, infiltration galleries, etc.) are regulated by the EPA and ADEC through the Underground Injection Controls (UIC) program as Class V underground injection wells and are generally prohibited on Fort Wainwright due to contamination risk.

Designs which propose to incorporate storm water drainage wells or infiltration trenches shall be submitted to FWA Environmental Division for approval.

b. Construction: The contractor is responsible for preparing and following a Storm Water Pollution Prevention Plan (SWPPP) as well as submitting the Notice of Intent (NOI) and Notice of Termination (NOT) to the ADEC when ground disturbance from projects is one acre or greater. A copy of the SWPPP and NOI should be submitted to the DPW Environmental Division. An example storm water pollution prevention plan checklist is included as Appendix D. For ground disturbing projects less than one acre, the contractor shall complete and submit an Erosion Control and Sedimentation Plan (Appendix E) for review and approval to the DPW Environmental Division at least 5 days prior to beginning work.

3. Excavation De-Watering: If excavation de-watering is anticipated, the contractor shall prepare a de-watering plan as a stand-alone plan or as part of the SWPPP. If de-watering is expected to exceed 5,000 gallons per day, the contractor shall apply for a permit to ADEC. The plan and permit shall conform to ADEC Wastewater General Permit No. 2009DB0003 (expires March 23, 2014 – administratively extended until replacement can be issued). Because some excavation de-watering activities may be located in a contaminated area, coordination with the DPW Environmental Division to ensure potential contamination is not migrating off-site is critical. A copy of the permit and plan shall be shared with the DPW Environmental Division at least 5 days prior to beginning work for dewatering in areas of no known sources of contamination. In areas of known sources of contamination de-watering activities shall be included in the Sampling and Analysis Plan submitted for regulatory approvals.

4. Temporary Water Use: If the contractor proposes to obtain water from any surface water source for construction purposes (e.g., dust control, soil compaction), the contractor shall obtain a temporary water use permit from Alaska Department of Natural Resources. The permit must be granted prior to water extraction. A copy of the permit shall be shared with the DPW Environmental Division at least 5 days prior to beginning work.

5. Wastewater: Use of a facility must be evaluated for need of such items as oil/water separators and applicability of floor drains in the wastewater system. The sanitary system design must be approved by ADEC. Oil/water separators shall not discharge to a septic system. An alternate means of containment (i.e., holding tank) shall be provided for facilities not served by a wastewater system. A copy of all correspondence with ADEC shall be provided to the DPW Environmental Division prior to the start of construction of a septic system.

6. Backflow Prevention: Design of the facility potable water system must comply with Ft. Wainwright’s cross-contamination plan and components complying with applicable plumbing codes and approved by ADEC, often before construction begins. A copy of all correspondence with ADEC shall be provided to the DPW Environmental Division. A Backflow Assembly Test/AG Inspection Report shall be completed by a certified Backflow Assembly Tester and submitted to the DPW Environmental Office by the Designer/Installer upon completion of the project for all backflow prevention devices installed or repaired. The contractor shall provide an electronic photograph of the device after installation along with a detailed one-line drawing of its installation.

7. Hazardous Waste/Material:

a. The disposal of hazardous waste generated under construction contracts

(construction/demolition debris, paints, soil from contractor spills, etc.) is the contractor’s responsibility. Any hazardous waste that is the responsibility of the Government should be identified in advance and proper abatement/disposal planned as part of the project. Sampling, abatement, containerization, manifesting, and handling are the responsibility of the contractor.

b. Propylene Glycol, as used in heating systems in facilities throughout the Post, is not regulated by the EPA; however, it is regulated by ADEC. When diversion of construction and demolition (C&D) debris for recycling/reuse is specified in a project, propylene glycol shall be considered in the contractor’s diversion plan.

Should diversion of propylene glycol for recycling/reuse not be practicable, its disposal shall be the responsibility of the contractor and shall comply with ADEC requirements. Ethylene glycol is a regulated hazardous substance and shall be recycled through the Hazardous Waste Consolidation Facility contractors. Make arrangements with them for transportation to Bldg 5007 for recycling on post.

c. All hazardous materials (e.g., paint, solvents, fuel, etc.) must be stored and used in such a manner as to prevent spills and releases. Any unused or partially used materials are the property of the contractor and shall be removed from the installation and disposed of at the contractor’s expense.

d. On-site refueling operations will conform to guidance in Appendix F.

e. Definitive instruction for the management of hazardous waste and material can be found in the USARAK Pamphlet 200-1, Hazardous Materials, Hazardous Waste and Used Oil Management Plan.

f. Contractors are required to create and submit a Waste Management Plan. The required sections can be found in Appendix L.

8. Spills:

g. All releases of hazardous substances and petroleum products shall be immediately reported to the Directorate of Emergency Services Dispatch by telephone 24-hours a day at (907) 353-7535. Additionally, the spiller must complete and submit a “Basic Spill Information Sheet”, located in Appendix G.

Reporting requirements to ADEC will be conducted by the DPW Environmental Division. Contractors, installation units/organizations are NOT to report spills directly to ADEC. To report a spill, follow the instructions found in Appendix G

Basic Spill Information Sheet. In the case that a spill is deemed dangerous to human health and the environment, call (907) 353-7535.

h. After hours phone number is (907) 482-7267.

i. Any release of a hazardous substance must be reported as soon as the person has knowledge of the discharge.

j. Any release of petroleum product to water must be reported as soon as the person has knowledge of the discharge.

k. Any release of petroleum product to land in excess of 55 gallons must be reported as soon as the person has knowledge of the discharge. Any release of petroleum product to land in excess of 10 gallons but less than 55 gallons must be reported within 48 hours after the person has knowledge of the discharge.

l. Any release of petroleum product in excess of 55 gallons to an impermeable secondary containment area must be reported within 48 hours after the person has knowledge of the discharge.

m. Clean up of the spill and associated clearance and confirmation sampling/testing is the responsibility of the contractor. Contractors shall provide to the DPW Environmental Division through the project’s KO/COR/PM all correspondence pertinent to the ultimate disposition of contaminated soil (e.g. field notes, lab results, Material Profile/Approval to Transport and Treat forms and certifications of treatment when treated by thermo-remediation, or shipment manifests when applicable). Procedures listed in Appendix C, Handling and Management of Contaminated Soils, will also apply.

9. Solid Waste:

a. Construction and demolition debris shall be recycled when possible.

b. All Solid Waste to include construction debris that is deemed waste or is not recycled must got to a certified landfill.

c. Unless otherwise specified in the Scope of Work, the Fort Wainwright landfill may not be used for the disposal of construction and demolition debris or municipal waste.

d. The Fort Wainwright Landfill will accept 10 cubic yards or less of friable asbestos per project only. Prior approval from the Manager of Landfill Operations is needed before any disposal can be coordinated.

e. Coordination for disposal of 10 cubic yards or less of friable asbestos per project only at the Fort Wainwright landfill shall be made with the DPW Operations and Maintenance Division, Manager of Landfill Operations.

f. Solid waste disposal to include all project waste and diversion are required to be reported the installation Solid Waste program manager monthly.

10. Air Quality Issues:

a. Dust Control: Fugitive emissions, primarily dust, shall be controlled on each construction site 24 hours per day, 7 days a week. This includes cleaning of soil tracked out onto roadways daily. Appendix H, Fort Wainwright Dust Control Specification, elaborates on this requirement.

b. Head Bolt Outlets: The Post is subject to Fairbanks North Star Borough air pollution ordinances. One such ordinance requires installation of head bolt outlets in any new or renovated parking lot in which patrons can be expected to park for at least two hours. This requirement applies to nearly every existing and proposed parking area on Post.

c. Air Quality Construction Permit (AQCP): DPW and the Air Quality program manager must evaluate each project to determine whether an AQCP is required prior to commencing construction. An AQCP is typically required for projects that involve the addition of new air emission sources (e.g., boilers, generators, fire pumps, painting & degreasing operations, fuel storage & loading) and for projects that involve the modification of existing air emission sources. The evaluation includes determining if the project conforms to the requirements and emission caps established by Fort Wainwright’s current Title V operating permit and assesses the need to obtain a permit modification. As early in the design process as practicable, the designer of record (DOR) shall submit pertinent data such as generator model, engine capacity and serial number, boiler burn rates, fuel type, and heat output.

d. General Conformity: Each project must be evaluated for impacts to the Fairbanks North Star Borough Carbon Monoxide Maintenance Area. This evaluation includes assessing both direct and indirect emissions. Direct emissions include emissions resulting from the installation of new air emission sources, including generators, incinerators, boilers, paint booths, fuel tanks and parts washers. Indirect emissions include those resulting from increased vehicle traffic, heat & power demand from the CHPP, cooling water and wastewater loads. An inventory of these sources will come from the designer and/or end user, and must be provided to the DPW Environmental Office as early into the design process as possible to facilitate this review and the need for a more detailed general conformity determination.

e. EPA-required Technology Standards: Designers will insure any new stationary air emission source (e.g. boiler, pumps, generators, painting operation, fueling station, fuel storage tanks, etc.) meets applicable technology standards: New Source Performance Standards (40 CFR Part 60) or National Emission Standards for Hazardous Air Pollutants (40 CFR Part 63).

f. Disposal of Air Conditioners and Refrigeration Equipment: Prior to final disposal, the refrigerant from stationary air conditioners and other cooling equipment must be recovered in accordance with the EPA's National Recycling and Emission Reduction Program, which prohibits the release of refrigerants and their substitutes to the atmosphere during service, repair, and disposal of equipment containing ozone depleting substances (ODS). The Fairbanks North Star

Borough landfill will not accept the equipment without a certificate of removal;

otherwise, the FNSB will charge an additional fee to remove the ODS and generate the required EPA documentation. Alternatively, the project manager may arrange for the Post Operations and Maintenance contractor to service/evacuate the equipment. This option is most consistent with Army policy, which directs installations to capture and reuse the refrigerant to recharge other compatible, ODS equipment on Post. Disposal of systems with greater than 5 lb capacity should utilize this option as additional EPA requirements might apply.

Note: The EPA prohibition applies to CFCs, HCFCs, their blends, and substitute refrigerants.

11. Fuel Storage Tanks:

a. Underground Storage Tanks (USTs): All USTs installed on Army property will conform to 40CFR280, 18AAC78 and applicable Army guidance. While the EPA and ADEC generally exempt heating oil tanks, the Army requires all USTs to be installed to the same standard. New steel USTs shall be double wall steel with cathodic protection (anodic, not impressed current), spill and overfill prevention, and interstitial leak detection. New reinforced plastic tanks shall be double wall but do not require cathodic protection. Fuel lines will be double wall Enviroflex, or equal. Other requirements will be identified based on specific use and installation requirements.

b. Aboveground Storage Tanks (ASTs): All ASTs installed on Army property will conform to 40CFR112, as well as applicable ADEC and Army guidance (to include the most current version of the Fort Wainwright Spill Prevention, Control and Countermeasures Plan). In general, all ASTs will be either double wall or vaulted tanks, with containment on ALL four sides. Tanks with double steel on one end will not be accepted. Single wall tanks with alternate secondary containment will generally not be approved, but will be considered on a case-by-case basis. All tanks will be tapped on the top only, and be provided with spill and overfill prevention and leak detection. Other requirements will be identified based on specific use and installation requirements. All new installed ASTs will conform to industry standards as defined by the American Petroleum Institute (API) 650 publication, Steel Tank Institute (STI) SP0001 and the National Fire Protection Association 30: Flammable and Combustible Liquids standards.

12. Natural Resources:

a. Wetlands: Prior to design and construction activities, DPW Environmental

Division, working with U.S. Army Corps of Engineers (USACE) Regulatory Office, will determine the existence of wetlands on or near the site. If wetland conditions exist and are expected to be impacted by the project, DPW will apply for a permit from USACE Regulatory Office. For Design-Build projects, conceptual design data are typically submitted with the application for initial permitting; however, as the design develops to a level which shows the project limits, depths of cut/dredge and fill, etc. as necessary to describe the work affecting the wetlands, the designer shall provide these data to DPW

Environmental Division for transmittal to USACE Regulatory Office for possible modification of the initial permit. A permit must be granted prior to the start of work. USACE Regulatory Office may request additional information.

b. Timber Policy: Once clearing limits for a particular site are established, the DPW

Environmental Division Forester will evaluate the site for salvageable timber.

Based on the estimate, timber may be purchased by the contractor, those funds being deposited into the DA Budget Clearing Account; or, salvageable timber may be cut and stacked on the site in an area accessible to the public. This policy and guidance is provided in Appendix I, Policy on Use of Timber at Fort Wainwright.

c. Fish Habitat: There are several rivers and streams within Ft. Wainwright, DTA, YTA, and TFTA. All design and construction activities affecting fish bearing waters shall be accomplished in accordance with Alaska Statutes AS 41.14.870

– AS 41.14.900 and an Alaska Department of Fish and Game (ADF&G) Habitat Permit must be obtained prior to starting work. A habitat permit is required from the ADF&G when crossing from any fish bearing stream. Contact the DPW Environmental Division prior to any stream/river crossing or work conducted below ordinary high water mark (e.g. generally within the stream/river’s banks).

d. Migratory Birds: All migratory birds are of concern, as stated in the Migratory

Bird Treaty Act; however, cliff swallows and mew gulls tend to be more visible.

Cliff swallows build mud nests on facilities and mew gulls build nests on vehicles and other equipment. Raptors also build nests on power poles. Once a nest has been established and eggs laid, it is against Federal law to disturb the nest or harass the birds in an attempt to get them to abandon the nest without a permit and consultation with the U.S. Fish and Wildlife Service. The contractor shall make every attempt to remove partially completed nests daily before eggs are laid from 1 May to 15 July if applicable at the job site. During land clearing activities, the equipment operator shall pay attention to avoid nests. If a nest is encountered, the contractor must contact the DPW Environmental Division. It is also recommended that vegetation clearing occur before 1 May or after 15 July to minimize impacts on ground and tree nesting birds. Contractors shall also comply with the Bald and Golden Eagle Protection Act and an eagle permit must be obtained prior to the start of work if the project will impact an eagle’s nest.

13. Cultural Resources:

1. Within the Ft. Wainwright cantonment area, potential impacts to the Ladd Field National Historic Landmark and the Ladd Air Force Base Cold War Historic District, shall be considered. These districts are shown in Appendix J, Ft. Wainwright Historic Properties. Cultural resources include (but are not limited to) archaeological sites, historic buildings or structures, and properties of traditional religious and cultural importance. All projects require review for potential conflicts with cultural resources under Section 106 of the National

Historic Preservation Act. Projects that will disturb the ground may require a survey by qualified staff prior to project. This survey is generally conducted by the DPW Environmental Division staff during initial project planning and review. However, if the project scope changes to include new areas of ground disturbance that was not identified in the original scope, a new survey of that area may be required before execution. The contractor shall also have a policy in place for notifications and actions by workers in the event of inadvertent discovery of cultural resources (old building systems, artifacts, human remains, etc....), as described in Appendix K, Inadvertent Discovery of Cultural Resources. The DPW Environmental Division cultural resources program is available to provide educational assistance to the contractor in identifying inadvertent discoveries on Fort Wainwright if needed.

G. A copy of the latest edition of "DPW Environmental Requirements for Construction

Projects "document can be obtained through the Government's Contracting Officer's Representative (COR) or by contacting Tamara Scholten, DPW Environmental Division, 361-9622 or tamara.a.scholten.civ@mail.mil.

APPENDIX A

DEPARTMENT OF THE ARMY

INSTALLATION MANAGEMENT COMMAND

HE QUARTERS, U.S. ARMY GARRISON FORT WAINWRIGHT

1046 MARKS ROAD #6000

FORT WAINWRIGHT, ALASKA 99703-6000

IMFW-PWE SEP 2 5 2017

MEMORANDUM FORS 'E DISTRIBUTION

SUBJECT: Environment 1 1 Policy Statement (Garrison Policy #37)

1. Reference, AR 200-1, Environmental Protection and Enhancement, 13 December 2007.

2. The US Army Garriso Fort Wainwright (USAG FWA) is firmly committed to a policy of environmental stewardship for all lands under its control in accordance with

AR 200-1.

3. The USAG FWA's po[l following:

a. Maintaining complli y of environmental stewardship is a commitment to the nee with applicable legal requirements.

b. Prevention of pollution through identifying, implementing, and promoting pollution prevention strategies.

c. Continual improvement through setting and reviewing environmental goals, objectives and targets.

4. This environmental p9licy will be reviewed annually by the Environmental Quality Control Committee (EQC ) to ensure that USAG FWA's commitments are consistent with the garrison's operati on s and sustainability goals.

5. This policy supersedee Garrison Policy #37, subject: Environmental Policy Statement, dated 4 Oct 1b.

SUBJECT: Environmental Policy Statement (Garrison Policy #37)

6. The point of contact fa( this memorandum is Directorate of Public Works, Environmental Division Clhief at 361-6220/9686.

. F HER

COL, AR

Commanding

DISTRIBUTION:

DIST A (FWA)

APPENDIXB

DEPARTMENT OF THE ARMY

INSTALLATION MANAGEMENT COMMAND

HEADQUARTERS, U.S. ARMY GARRISON FORT WAINWRIGHT

1046 MARKS ROAD #6000

FORT WAINWRIGHT, ALASKA 99703-6000

IMFW-PWE 'SEP 25 2017

MEMORANDUM FOR SEE DISTRIBUTION

SUBJECT: Land Use Controls/Institutional Controls (Garrison Policy #38)

1. References:

a. AR 600-20, Army Command Policy, 6 November 2014.

b. AR 200-1, Environmental Protection and Enhancement, 13 December 2007.

c. Memorandum: DUSO (ES/CL), Policy on Land Use Controls Associated with Environmental Restoration Activities, 17 January 2001.

d. Executive Order 12580, Implementation of Superfund, 23 January 1987, as amended by Executive Order 13308, 20 June 2003, Further Amendment to Executive Order 12580, as Amended, Superfund Implementation.

e. 40 CFR 300, National Oil and Hazardous Substances Pollution Contingency

Plan.

f. 42 USC 9601 et seq. Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as Amended by the Superfund Amendment and Reauthorization Act of 1986.

g. 10 USC 2710(b) Military Munitions Response Program, Inventory of UXO, DMM, and MC Defense Sites other than operational ranges.

h. US Army Garrison Fort Wainwright (USAG FWA) Federal Facility Agreement as amended under CERCLA Section 120, Administrative Docket Number: 1092-04-10-120 April 2007.

i. USAG FWA Land Use Controls/ Institutional Controls Standing Operating

Procedures (SOP).

j. USAG FWA Land Use Controls/ Institutional Controls Potential Source Area List w/ Status.

2. Purpose: To update and disseminate the Land Use Controls/ Institutional Controls (LUC/IC) Policy for USAG FWA.

3. Applicability:

a. This policy applies to all individuals, units, directorates, activities, organizations, partners and tenants which includes the U.S Army Corps of Engineers in its entirety, all Prime and Sub-Contractors, and Consultants; all personnel working for contractor owned, contractor operated facilities and operations; Government Owned, Contractor Operated facilities and operations; and personnel living, working, or conducting other authorized activities on USAG FWA controlled lands and are therefore responsible for complying with all established LUC/ICs identified in this document.

b. These LUC/ICs cover all contiguous and non-contiguous properties under the control of USAG FWA.

c. Specific land use restrictions cited in this policy, the USAG FWA Land Use Controls/Institutional Controls (LUC/IC) Standard Operating Procedures (SOP), the USAG FWA Land Use Controls/Institutional Controls Potential Source Area List w/ Status, as well as those established in the Comprehensive Environmental Response Compensation and Liability Act Record of Decisions, shall be incorporated into all lease agreements, Memoranda of Agreement, and contract documents, as necessary, to reduce the potential for exposure to environmental hazards.

d. In addition to these LUC/ICs, all units or personnel entering USAG FWA Ranges and Training Areas shall also comply with the directives of the Range Control Officer and the Range Control SOP.

e. Penalties for violating this policy include the full range of statutory and regulatory sanctions for military and civilian personnel according to the following citations:

(1) For military personnel, the Uniform Code of Military Justice (UCMJ) Article 92(1), violation of a lawful general regulation, and service-specific regulations.

(2) For civilian personnel, Army Regulation (AR) 690-700, Chapter 751; and the

Code of Federal Regulation, Title 5, Chapter 1, Part 752. Commanders should contact their servicing civilian personnel activity for·assistance concerning punitive actions for civilian personnel.

4. Procedures: The Directorate of Public Works (DPW) shall ensure that the following standard operating procedures are in place to comply with this policy:

a. All construction, maintenance, repairs, and authorized training activities conducted anywhere within active ranges and training areas that involve soil.disturbing activities impacting soils six inches or more below the ground surface in known contaminated areas, shall comply with LUC/ICs requirements in addition to Range Control directives and SOPs.

b. All soil disturbing activities impacting soils six inches or more below the ground surface anywhere on the installation must have a DPW approved DA Form 4283 (Work Order) or DPW approved Service Order, a signed and approved Excavation Clearance Request (ECR) from DPW Customer Service Desk and a completed and signed Project Checklist for Environmental Concerns. During this process, DPW Environmental personnel will identify applicable LUC/ICs, identify known or suspected contamination, and other pertinent information and requirements. This process shall be followed for the listed activities which include but are not limited to the following:

(1) Installation, maintenance, and removal offacilities, infrastructure, landscaping, and private fence/gates in North Haven Communities and Army Family Housing.

(2) Installation, maintenance, and repair of facilities, infrastructure or utilities by

DPW workers, service contractors, privatized utility or privatized housing partners, organizations, tenants, Soldiers, units and Family Housing residents.

(3) Military Construction Army (MCA) contracts for facilities, utilities, ranges or other infrastructure.

(4) Landscaping, erosion control, Storm Water Pollution Prevention mitigations or similar activities anywhere on the installation.

(5) Installation of investigative test pits, soil borings, remediation systems, dewatering wells, monitoring wells, or potable water wells for whatever reason.

Submission of the request for installation and justification for dewatering or potable water wells shall be coordinated through the DPW Environmental Office not less than 365 days prior to installation of the wells.

c. If any of the above listed activities occurs in an area of known or suspected contamination, the Work Order shall be accompanied by a US Army, EPA and ADEC approved Work Plan that is written and submitted by the proponent of the work that addresses the following:

(1) The nature of the contaminants of concern.

(2) How the construction workers will deal with the contaminated media.

(3) Protection of existing ground water monitoring wells.

(4) Decommissioning of existing ground water monitoring wells that must be removed to facilitate the construction of new facilities or infrastructure.

(5) Installation of new or replacement ground water monitoring wells

(6) Construction and maintenance requirements for long-term contaminated soil stockpiles.

(7) Final disposition of the exhumed contaminated material.

(8) How the remaining/residual contaminated media will be mitigated to prevent future accidental exposure to contaminants of concern.

d. The discovery of readily identified or potentially hazardous waste, buried waste containers, discarded military munitions, unexploded ordnance, munitions debris, "unusual debris" or other forms of contamination in surface soil, sub-surface soil, ground water, or indoor/outdoor air within the cantonment area shall comply with the following process:

(1) Immediately cease all work or training, move away from the area and notify the DPW Environmental Division at 361-9686 and await further guidance before proceeding with any other soil disturbing activity.

(2) If DPW cannot be reached, call the emergency responders (911 on Post) or

353-9170 if calling from a cell phone or Family Housing area.

(3) If these items are found within an active training area or range, immediately move away from the area and notify Range Control via radio or call 353-1244.

(4) Tenants or contractor's signature on an ECR acknowledges their understanding of Army Reporting Requirements regarding new contaminant finds.

Failure to report this contamination constitutes a violation of US Code and Army Regulations.

e. Newly identified contaminated areas that cannot be immediately remediated shall be added to the LUC/IC list within 90 calendar days of final investigation report on the area being received and approved.

f. DPW shall maintain all information and an electronic map of all Installation Restoration Program sites and Military Munitions Response Program Sites. The map shall be updated as soon as practicable but, within 90 calendar days of final investigation report on the area being received and approved by the Army, the EPA, and the ADEC.

g. Groundwater restrictions prohibit the drilling of water wells for potable water, fire suppression, irrigation or other purposes anywhere on the installation without written consent of the Garrison Commander or approved representative. Coordination for these activities must begin not less than 365 calendar days prior to the date required.

DPW Environmental will provide the necessary coordination with the EPA and ADEC.

h. DPW shall sample and analyze ground water monitoring wells up-gradient from the Installation Drinking Water Supply wells to ensure no contaminants of concern are migrating towards these wells from adjacent contaminated sites. DPW shall ensure that the analytical test methods used are capable of detecting the contaminants of concern at levels that are protective of human health.

i. Construction on known or potentially contaminated areas will not proceed until the site has been properly evaluated for its intended use as follows:

(1) If Family Housing is planned for an area, investigative results will compare soil and groundwater results against unrestricted use scenarios. Occupants will be protected against exposure to hazardous levels of contaminants.

(2) If new or upgraded infrastructure or unoccupied industrial facilities are planned, engineering controls will be incorporated into the design to ensure construction workers are not exposed to contaminant levels exceeding the OSHA PEL.

(3) If volatile organic compounds or other hazardous materials are left in the soil or ground water under occupied building foundations, facility designs shall incorporate protective measures to prevent vapor intrusion into the breathing zone of the facility and prevent exposure to hazardous levels of sub-slab contaminants by occupants during normal activities.

j. DPW shall monitor sub-slab soil gas for all buildings in the Tanana Trails Family

Housing area at each change of occupancy, but not less than every three years or until the US Army, EPA and ADEC agree the monitoring is no longer required.

k. DPW shall ensure the disposal of contaminated soil or groundwater approved for removal from the work site must be containerized and disposed of per IAW USARAK Pamphlet 200-1, Hazardous Materials and Regulated Waste Management.

I. Implementation details shall be updated in the USAG FWA Land Use

Controls/Institutional Controls Standard Operating Procedures.

5. Modification or Revocation: Future modifications or revocation of this policy shall be conducted in consultation with the US Environmental Protection Agency (Region 10) and the Alaska Department of Environmental Conservation (Military Contaminated Sites Program).

6. This policy supersedes Garrison Policy #38, subject: Land Use Controls/Institutional Controls, dated 01 Dec 15.

7. The Point of Contact for this policy Directorate of Public Works, Environmental Division Chief at 361-6220/9686.

SEAN N. FISHER

COL, AR

Commanding

DISTRIBUTION:

DIST A (FWA)

Appendix C, Handling / Management of Contaminated Soil

Page C-1

Revision 2019

APPENDIX C

HANDLING / MANAGEMENT OF SOIL ON FORT WAINWRIGHT

Appendix C only applies to soil management. If the project requires excavation below groundwater level, groundwater screening levels meeting ADEC Table C of 18 AAC 75 would be applied to all sampling and dewatering efforts. Pre-design project planning consultation with DPW Environmental Division is required.

Areas of known or suspected contamination:

1. During ground-disturbing activities within areas of known or suspected contamination, excavated soil shall be screened for potential contamination in accordance with the approved Work Plan. Should the contractor encounter soils having photoionization detector (PID) readings of 20ppm or greater (or lower if required by the Work Plan) or soil that exhibits signs of contamination such as debris, staining, or odor, the contractor shall promptly notify the government in accordance with the Excavation Clearance Request (ECR).

Work shall cease in the area of concern until cleared by the Contracting Officers Representative (COR) in coordination with DPW Environmental Division. No backfill of the area of concern shall be accomplished without clearance from the COR in coordination with DPW Environmental Division.

2. Upon clearance by the COR, excavation may proceed within the area of concern in accordance with the following procedures:

a. At any point prior to reaching design excavation limits, or if design limits are reached and PID readings at floor and walls of excavation are less than 20ppm, the associated screening locations and results shall be explicitly reflected in field notes and the contractor may backfill upon approval by COR in coordination with DPW Environmental Division.

b. If project design limits are reached and PID readings of 20ppm or greater remain at the walls/floor of the excavation or there is still evidence of contamination, the contractor shall notify the COR, who will coordinate with DPW Environmental. Confirmation samples shall be taken in accordance with approved work plan. No backfilling will occur without clearance from the COR in coordination with FTW Environmental Division.

It is not intended that the project remediate or clean up (i.e., “chase”) presumed contaminated soil beyond the project design limits.

3. Excavated soil shall be segregated as follows or in accordance with the approved Work Plan:

a. Less than 20ppm: Soil with PID readings less than 20ppm may be assumed clean and used on site or handled/transported in accordance with contract requirements for clean soil. There is no need for special handling.

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b. 20ppm to 99ppm: Soil with PID readings 20ppm to 99ppm is assumed contaminated and shall be placed in an ADEC-compliant short-term soil containment cell and tested by an approved lab (IAW 18 AAC 78 and 75).

c. 100ppm and above: Soil with PID readings 100ppm and greater is assumed contaminated and shall be placed in a separate ADEC-compliant short-term soil containment cell and tested by an approved lab (IAW 18 AAC 78 and 75).

4. Long -term contaminated soil cells shall be constructed in accordance with Table D of 18 AAC 75.370 and the attached check list near the construction site Soil storage cells are for presumed contaminated soil only; no construction debris (i.e. wood, concrete, reinforcement steel, asphalt, metal, etc.) shall be placed in containment cells. Contaminated soil generated by contractor-caused spills shall be stored separately within or near the construction site only. All potentially contaminated soils, regardless of source, shall be clearly identified in a weather proof manner with the following information: project information; contractor company name, with point of contact name and contact information; project’s COR name and contact information; PID range; date or dates of generation; project location, if there are more than one set of stockpiles for the project; and source and quantity if it associated with a contractor caused spill.

5. Sampling and Analysis:

a. Sampling and lab analysis is the responsibility of the contractor. Unless other contaminants are suspected, soil confirmation samples (walls & floor of excavation) shall be analyzed for the contaminants identified in the project documents and the approved Work plan and may include all or any combination of the following contaminant list: gasoline-range organics (GRO), diesel-range organics (DRO), residual-range organics (RRO), volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), pesticides, and Resource Conservation and Recovery Act (RCRA) metals plus Nickel and Vanadium. The number and locations of samples shall conform to those required by 18 AAC 78 and 75.

b. Presumed contaminated soil stockpiles shall likewise be sampled for GRO, DRO, RRO, VOCs, SVOCs, pesticides, herbicides, RCRA metals and Toxicity Characteristic Leaching Procedure (TCLP) extraction and analysis on same soils as RCRA metals if RCRA metals results are greater than twenty times the allowable TCLP limit.

c. Additional sampling and analyses to the extent required by the approved offsite treatment, storage or disposal (TSD) facility shall be the responsibility of the Contractor and shall be subject to approval by the Contracting Officer and DPW Environmental Division.

Page C-3

d. Data Quality Objectives for analytical methods to achieve limits of detection lower than the most stringent project screening levels.

e. Contaminated soil screening levels for known sources of contamination shall be EPA Residential Screening Levels (RSLs) (TR=1E-06 and THQ=0.1) for soils. In addition to EPA RSL, data shall be compared to the more stringent of one-tenth the current ADEC Method Two human health for the under 40 inch zone (soil) or migration to groundwater of Table B1, Method Two soil cleanup levels from 18 AAC 75. The screening level for GRO, DRO, and RRO for soils shall be the most stringent of under 40 inch inhalation/ingestion or migration to groundwater cleanup levels of Table B2, Method Two petroleum hydrocarbon cleanup levels from 18 AAC 75.

6. Upon Receipt of Laboratory Analysis:

a. Non-contaminated Soil in Cells: Soil that is confirmed by laboratory analysis not to be contaminated, or below ADEC Human Health levels, may be assumed clean and used on site or handled/transported in accordance with contract requirements for clean soil. The contractor is responsible for maintaining the storage cell, removing/dismantling the storage cell and restoring the site to its original condition (e.g., graded, re-seeded, etc.). If the soil cell has been constructed outside of the project boundary, the contractor is still responsible for transporting and disposing the soil in accordance with contract requirements for clean soil and dismantling/disposal of all storage cell materials.

b. Contaminated Soil in Long-Term Storage Cells: Soil that is confirmed contaminated above EPA or ADEC screening levels (see section 5.d.) will be disposed of in accordance with the Project requirements. The contractor is responsible to maintain the cell until the contaminated soil is removed from within the project boundary or from the location identified in the contract documents. Once the cell is removed, the contractor shall be responsible for restoring the site to its original condition or to design specifications and ensuring there was no soil contamination caused by the soil storage cell. If contaminated soil is treated within the State of Alaska, an ADEC Transport, Treatment, and Disposal Approval Form for Contaminated Media shall be submitted to DPW Environmental, after treatment all soils shall be returned to Fort Wainwright and be disposed of in accordance with the clean soil requirements of the contract. A certification of treatment shall be submitted to DPW Environmental Division.

c. Contaminated Soil Transported to Fort Wainwright Contaminated Soil Yard or left on Project Site for transfer to DPW Environmental: Transport of soil to the contaminated soil yard shall be coordinated with the DPW Environmental through the COR. A storage cell within the yard shall be assigned to the project. The contractor shall be responsible for preparing the storage cell by doing the following: ensuring it is free of vegetation, tamara.a.scholten Sticky Note Change to LODs low enough for comparison. Change to Bris language for screening.

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Page C-4 preparing a long-term soil storage cell in accordance with ADEC 18 AAC

75.370 Table D, labeling per section 4, and completing the storage stockpile checklist with FTW Environmental Division (attached to this document). Upon completion of the checklist the contractor is relieved of the requirement to maintain the storage cell.

d. Non-contaminated Soil in the Excavation: If laboratory analysis confirms no remaining contamination at the floor/walls of the excavation, or concentrations are below EPA and ADEC screening levels, the site may be backfilled upon coordination with and approval by FTW Environmental Division.

e. Contaminated Soil in the Excavation: If laboratory analysis confirms contamination at the floor/walls of the excavation remain at concentrations above ADEC cleanup levels, DPW Environmental Division, ADEC, and EPA will determine the course of action. The excavation shall not be backfilled without clearance from FTW Environmental Division.

f. Upon completion of the project, submit a closure report. The report shall be a narrative report including, but not limited to, the following: site conditions, ground water elevation, and cleanup criteria; excavation logs;

field screening readings; quantity of materials removed from each area of contamination; quantity of water/product removed during dewatering;

sampling locations (required datum WGS 1984) and sampling methods;

sample collection data such as time of collection and method of preservation; sample chain-of-custody forms; source of backfill; Copies of all chemical and physical test results meeting Staged Electronic Data Deliverable (SEDD) requirements; Copies of all manifests and land disposal restriction notifications (if applicable); Copies of all certifications of final disposal signed by the responsible disposal facility official (if applicable); Waste profile sheets (if applicable); Scale drawings showing limits of each excavation, limits of contamination, known underground utilities within 50 feet of excavation, sample locations, sample identification numbers, location of contaminated soil stockpiles; and color progress photographs to document location of the area of contamination, entrance/exit road, and any other notable site activities and conditions.

Areas not known to be contaminated:

7. During ground-disturbing activities within areas not known to be contaminated, excavated soil shall be screened for potential contamination in accordance with the approved Field Screen Plan. If contaminated soil is suspected or drums, unexploded ordnance, or unusual debris are found promptly notify the government in accordance with the Excavation Clearance Request (ECR). Work shall cease in the area of concern until cleared by the Contracting Officers Representative (COR) in coordination with DPW

Page C-5

Environmental Division. No backfill of the area of concern shall be accomplished without clearance from the COR in coordination with DPW Environmental Division.

8. DPW Environmental and the government COR will determine the best course of action; to either modify the contract such that the contractor prepares a Work Plan for regulatory approval and completes all activities in accordance with sections 2 through 6 (except 5e see section 9) or if the DPW Environmental Contractor shall guide excavation in accordance with their approved Work Plan and sections 2 through 6 (except 5e see Section 9).

9. Contaminated soil screening levels for NO known sources of contamination shall be EPA Residential Screening Levels (RSLs) (TR=1E-06 and THQ=0.1) for soils. In addition to EPA RSL, data shall be compared to one-tenth the current ADEC Method Two human health for the under 40 inch zone (soil) from 18 AAC 75.

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