ENVIRONMENTAL REVIEW

U.S. Army Garrison-Fort Bliss, Directorate of Public Works, Environmental Division (DPW-ED)-NEPA Office Bldg. 624, USGA Fort Bliss, TX 79916

Office Number: 915-568-3782

A RECORD OF ENVIRONMENTAL CONSIDERATION (REC) WILL BE REQUIRED- NOT OFFICIAL NEPA DOCUMENT

Date Received: 8/18/2025 NEPA Log#:25-0704 Review Expires: N/A

• This review document, and its attachments, are only for the requested work as described in the narrative of the Work Order Request and/or supporting documents provided.

• The Project Manager (PM) responsible for the final design must address/resolve potential environmental issues prior to award/implementation of the project and concurrence is based on the proponent following the guidance in this document.

• This review identifies potential environmental issues which may be associated with the actions associated with this work and does not constitute an environmental technical review of subsequent project plans, specifications, and/or drawings.

• The DPW-Environmental Division's final review approval and concurrence is contingent on the project Work order request, Scope of

Work, any and all supporting documentation not changing, work must be completed within 365 days from the date of the review;

resubmit if project changes OR if not completed by the REVIEW EXPIRATION DATE

• This review is done in accordance with the National Environmental Policy Act of 1969 (NEPA) (42 United States [U.S.] Code Section

4321 et seq., and Department of Defense National Environmental Policy Act Implementing Procedures, 30 June 2025, and Army

Regulation 200-1.

Regular Work Order

Replace Roof TPO membrane at building 2417 due to multiple leaks. Multiple work-orders over the past month have been placed for both common areas and individual soldier’s rooms having leaks and water damage. Based on an assessment conducted by Pride it was recommended to request the TPO membrane to be replaced.

N/A

Proponent: please note that the DPW-ED concurrence is contingent upon the action meeting all, but not limited to, the conditions and/or criteria as detailed below. For questions, clarification, or additional guidance please contact the reviewer listed under each program.

Following the review of this Regular Work Order (WO) the Fort Bliss NEPA Office determined this action qualifies for Categorical

Exclusion (CATEX) in accordance with the National Environmental Policy Act of 1969 (NEPA) (42 United States [U.S.] Code Section

4321 et seq.) requires federal agencies to consider potential environmental impacts prior to undertaking a course of action. In accordance with NEPA, Department of Defense National Environmental Policy Act Implementing Procedures, 30 June 2025 and Army Regulation 200-

1, the Army has prepared CatEx (f)(1) for the routine repair of buildings, facilities, launch pads, structures, utility/communication systems, airfields, grounds, parking areas, targetry and other equipment, special hazards (e.g. ACM and/or LBP) are present and for which a Record of Environmental Consideration (REC) is required.

However, please consider the preliminary comments below when developing the supporting documents for this project. The following is not an official NEPA document. Should the project be considered for funding, coordination with the Fort Bliss NEPA Office is still necessary.

** asbestos-containing materials (ACM) and lead-based paint (LBP) for Building 2417**

SECTION BELOW PROVIDES THE ENVIRONMENTAL REVIEW. FOR DPW-ED SUBJECT MATTER EXPERT USE

PROGRAM: Cultural Resources-Archeology REVIEWER: Martha Yduarte CONCURRENCE: YES WITH NO COMMENTS

ATTACHMENT: NA FINALIZED DATE: 8/22/2025

No comment.

BLUF:

PROJECT TITLE AND BRIEF DESCRIPTION:

ANTICIPATED DATE AND/OR DURATION OF PROPOSED ACTION

DPW-ED ENVIRONMENTAL REVIEW NEPA LOG #25-0704

NOT AN OFFICIAL NEPA DOCUMENT

SCLMR#: NA WO#/Doc ID# #: MED 10211 5J Doc TYPE#: Regular Work Order Location/Building 2417

PROGRAM: Cultural Resources-Historic Preservation REVIEWER: Donald J. Sevigny CONCURRENCE: YES WITH NO COMMENTS

ATTACHMENT: NA FINALIZED DATE: 8/26/2025

NA

PROGRAM: Natural Resources REVIEWER: Gabriel Ramirez CONCURRENCE: YES- WITH COMMENTS

ATTACHMENT: NA FINALIZED DATE: 8/18/2025

Roof replacement, no natural resource issues.

PROGRAM: Drinking Water REVIEWER: Paola Soto-Montero CONCURRENCE: YES- WITH COMMENTS

ATTACHMENT: NA FINALIZED DATE: 8/25/2025

For activation, modification or deactivation of water systems, please coordinate with the water utility provider American States Utility Services, Inc. (ASUS) Fort Bliss Water Services Company (FBWS), which provides the operation and maintenance on the Installation.

Fire hydrants will not be utilized without getting the consent of FBWSC at 915-569-5358 or 915-564-1332 and the Fire Department at 915-

744-9896.

NON-POTABLE WATER REQUIREMENTS: Outlets for non-potable water, such as water for industrial or firefighting purposes, shall be posted or otherwise marked in a manner that will indicate clearly that the water is unsafe and is not to be used for drinking, washing of the person, cooking, washing of food, washing of cooking or eating utensils, washing of food preparation or processing premises, or personal service rooms, or for washing clothes.

CONTACT: Ms. Paola Soto-Montero at paola.i.soto-montero.civ@army.mil or at (915) 568-1051.

PROGRAM: Wastewater REVIEWER: Paola Soto-Montero CONCURRENCE: YES- WITH COMMENTS

Dispose of any project-related wastewater off Government property in accordance with 40 CFR 403, state, regional, and local laws, and regulations. Water discharges into the sewer system as a result of this project shall abide by the conditions and requirements of El Paso Water

(EPW) Rules 9 and 15. No foreign items, construction debris, chemicals, nor oils shall be introduced into the sanitary sewer collection system.

Asbestos from abatement activities is prohibited from being discharged to the sanitary sewer system without implementing best management practices to remove asbestos from wastewater.

The proponent shall ensure that the water filtration unit operational with proper 5-micron filter discharging to sanitary sewer, and that back-flow prevention devices installed at supply point.

CONTACT: Ms. Paola Soto-Montero at paola.i.soto-montero.civ@army.mil or at (915) 568-1051.

PROGRAM: Stormwater REVIEWER: Rebecca Navarrete CONCURRENCE: YES- WITH COMMENTS

Project intends to disturb less than an acre of land in accordance with description, therefore no additional documentation is required for the stormwater program. Proponent shall continue to ensure that no contaminants shall enter the stormwater system including sediment, oil and grease from vehicles, mud from tires, paint/stain, soaps/solvents, stucco, cement, sediment from disturbed soil.

Contact Rebecca Navarrette at rebecca.d.navarrette.civ@army.mil or (915)568-3472 to provide acreage or for guidance.

PROGRAM: D.E.R.A REVIEWER: Cynthia Hernandez CONCURRENCE: YES WITH NO COMMENTS

ATTACHMENT: NA FINALIZED DATE: 8/19/2025

SCLMR#: NA WO#/Doc ID# #: MED 10211 5J Doc TYPE#: Regular Work Order Location/Building 2417

PROGRAM: Solid Waste REVIEWER: Cynthia Hernandez CONCURRENCE: YES- WITH COMMENTS

ATTACHMENT: NA FINALIZED DATE: 8/19/2025

vii. Waste & Recyclables Management.

(a). Construction Waste Management. The DoD Strategic Sustainability Performance Plan (SSPP) (reference 1.q) requires that at least 60% of construction and demolition debris be diverted from the waste stream by FY2015. However, it is the Army’s intent to manage waste with the goal of Net Zero waste disposal in landfills. Therefore, projects that involve the removal of existing buildings or structures will evaluate the feasibility of deconstruction and salvage rather than conventional demolition and will implement deconstruction wherever markets or on-site reuse opportunities exist or are anticipated.

Any solid waste generated (non-hazardous or construction debris related) shall be disposed of and by the contractor, its subcontractor or the project proponent. All solid waste that cannot be recycled shall be disposed of at a permitted landfill or other authorized facility. Burning or burying (land disposal) is strictly prohibited by state laws, and any evidence of such will be addressed properly, and the contractor, its subcontractors and the proponent will be responsible for cleaning and removing all debris, trash and contaminated soils, water or other impacted materials, and replacing the materials, equipment or other infrastructure at the proponents, contractors and its subcontractors costs.

PROGRAM: Hazardous Materials REVIEWER: Samuel Del Toro CONCURRENCE: YES- WITH COMMENTS

ATTACHMENT: NA FINALIZED DATE: 8/26/2025

Prior to use of hazardous or regulated material, the Contractor shall provide the COR and DPW Environmental Division with a list of methods and materials for review and approval, pertaining to regulated/hazardous materials, storage, and disposal of waste generated.

PROGRAM: Lead & Asbestos Program REVIEWER: Donald J. Sevigny CONCURRENCE: YES- WITH REQUIREMENTS

ATTACHMENT: Asbestos Lead Survey_Bldg-2417_20080703 FINALIZED DATE: 8/26/2025

LEAD AND ASBESTOS PRESENT

PROPONENT SHALL FOLLOW THESE REQUIREMENTS:

1. GENERAL COMMENTS:

a. DPW-ED has a valid survey for asbestos-containing materials (ACM) and lead-based paint (LBP) for Building 2417, attached.

b. Review the attached surveys for all ACM and LBP to verify if they will be impacted by this project. If the project scope includes disturbing ACM and/or LBP, work must be conducted by a licensed abatement company.

c. If additional materials need to be disturbed that have not been tested in these surveys, they must be tested for ACM and LBP before any work is to be undertaken. Contact DPW-ED for additional testing.

d. Failure to manage present hazardous materials may expose workers, building occupants, and their families to toxic substances, which include carcinogens.

2. Since ACM and/or LBP is present and will be disturbed, the Proponent shall reference the requirements listed below in the project’s Scope of Work:

a. ASBESTOS CONTAINING MATERIALS (ACM): Shall be removed by licensed and trained individuals (Texas Administrative

Code Title 25, Part 1, [25 TAC] §296.41 - §296.62) in accordance with 25 TAC §296.211 - §296.213. If the project disturbs 10 square feet or less of ACM for each small project or task, the proponent shall follow 25 TAC §296.233: Alternative Asbestos Practices and

Procedures for Small Projects and Repetitive Tasks in a Public Building. A registered asbestos abatement worker may perform a small project or repetitive task that disturbs ACM. Written notification must be provided, as required in 25 TAC §296.251. The clearance-level assessment must be conducted as required on 25 TAC §296.213.

b. LEAD-BASED PAINT (LBP): Lead abatement is defined as the complete removal of the hazardous substance from the building substrate. For work which only involves stabilizing and encapsulating LBP such as peeling paint, drilling into painted walls, or other similar work, the Contractor shall provide the Contracting Officer’s Representative (COR), government representative, and DPW-ED the start date of the work and the information of the licensed lead contractor. The Contractor can obtain additional guidance from

SCLMR#: NA WO#/Doc ID# #: MED 10211 5J Doc TYPE#: Regular Work Order Location/Building 2417

DPW-ED on lead-related work to include engineering controls, personnel safety and work practices. According to methodology and requirements specified by 25 TAC §295.201 - §295.220. Handling lead-based paint activities, as defined in 25 TAC §295.202 shall only be conducted according to the procedures and standards contained in 25 TAC §295.212 relating to Standards for Conducting

Lead-Based Paint Activities. However, the standards contained in 25 TAC §295.212 do not apply when treating paint-lead hazards less than: (1) two square feet of deteriorated LBP per room or equivalent; (2) 20 square feet of deteriorated LBP on the exterior building, or (3) 10% of the total surface area of deteriorated LBP on an interior or exterior type of component with a small surface area.

c. NOTIFICATIONS: A proper notification shall be submitted to the State of Jurisdiction (25 TAC 296.251) no less than 10 working days prior to commencement of abatement activity and a copy shall be provided to the COR, government representative, and DPW-

ED. If the amounts of ACM are less than the notification thresholds, the customer shall notify DPW-ED of the start date of the small-scale abatement and provide a plan containing the licensed abatement company information, abatement methodologies, and the anticipated amounts of materials to be removed.

d. FEES & WASTE MANIFEST: The Contractor shall also provide DPW-ED with a copy of the waste manifest and clearance report, i.e., air sampling, if applicable. The Contractor will also be responsible for all State Asbestos Abatement/Demolition Notification fees. The appropriate DPW-ED personnel appointed by the Fort Bliss Garrison Commander is responsible for signing the waste manifest. The return address of the manifest must be DPW-ED.

e. RIGHT-TO-KNOW: Prior to conducting any activities that could disturb building materials, it is recommended to have the government representative reviews the attached survey to ensure the current site conditions are reflected by the report and additional materials have not been installed. The Contractor should receive a copy of these findings from the government representative so they can provide their workforce with the necessary OSHA Right-to-Know communication and to determine if special handling is required by either their company policy or OSHA compliance personnel (OSHA 1910.1001).

f. FOR NEW BUILDING MATERIALS: The Project Engineer, Architect or authorized persons shall submit to the point of contact listed below or alternate government program manager a letter verifying and certifying that all building materials used in the construction, renovation or remodeling contain no toxic substances, i.e. asbestos, lead, or other regulated toxic substances.

g. SUSPECT MATERIALS/INCIDENTAL ENCOUNTER: Should any suspect ACM be encountered/disturbed as part of the renovation project these materials will need to be sampled prior renovations or suspect material could be presumed to be ACM and managed accordingly. Upon discovery, the Contractor shall inform the COR, government representative, and DPW-ED.

h. ASBESTOS & LEAD WASTE: It is the responsibility of the Contractor to coordinate with DPW‐ED to ensure the ACM and/or LBP waste generated by this project is properly disposed of in accordance with all applicable federal, state, and local regulations. Disposal costs shall be charged to the project or related contract as applicable. DPW‐ED shall receive a copy of the waste profile issued by the disposal facility. Waste manifests must use the Fort Bliss Environmental Protection Agency Identification Number, and only DPW‐

ED personnel appointed in writing by the Garrison Commander are authorized to sign the manifests on behalf of Fort Bliss. The original manifests signed by the disposal facilities shall be provided to DPW‐ED.

Generator’s address for waste manifest:

Fort Bliss DPW-Environmental Division

624 Taylor Road

Fort Bliss, TX 79916

(915) 568-3782

3. Point of contact is D.J. Sevigny at (915) 568-3782 or donald.j.sevigny.civ@army.mil. Alternate point of contact is Troy Ainsworth, Historian, 915-568-1249 or troy.m.ainsworth.civ@army.mil.

PROGRAM: Hazardous Waste REVIEWER: Michelle Brennan CONCURRENCE: YES- WITH COMMENTS

ATTACHMENT: NA FINALIZED DATE: 8/20/2025

Upgrades, construction or repair activities will generate asbestos and/or lead waste, disposal shall be coordinated with DPW-ED. Disposal costs shall be charged to the project or related contract as applicable. A copy of the waste profile issued by the disposal facility should be provided to DPW-ED. Waste manifests must use the Fort Bliss Environmental Protection Agency Identification Number, and only DPW-ED personnel appointed in writing by the Garrison Commander are authorized to sign the manifests on behalf of Fort Bliss. The original manifests

SCLMR#: NA WO#/Doc ID# #: MED 10211 5J Doc TYPE#: Regular Work Order Location/Building 2417 signed by the disposal facilities shall be provided to DPW-ED.

PROGRAM: AST/UST REVIEWER: Isaac Trejo CONCURRENCE: YES WITH NO COMMENTS

ATTACHMENT: NA FINALIZED DATE: 8/21/2025

PROGRAM: SPCC REVIEWER: Isaac Trejo CONCURRENCE: YES WITH NO COMMENTS

ATTACHMENT: NA FINALIZED DATE: 8/21/2025

PROGRAM: Air REVIEWER: Victor Garcia CONCURRENCE: YES

ATTACHMENT: NA FINALIZED DATE: 8/20/2025

Potential impacts on the quality of the environment have been considered and are documented within the attached environmental checklist. It has been concluded that this action is not segmented, and no extraordinary circumstances exist that would preclude the use of the applicable categorical exclusion identified in paragraph below.

This document does not relieve the proponent from compliance with other applicable federal, state and local environmental laws and regulations.

On the basis of this evaluation the following is appropriate:

☐ In accordance with National Environmental Policy Act of 1969 (NEPA) (42 United States [U.S.] Code Section 4321 et seq., and Department of Defense National Environmental Policy Act Implementing Procedures, 30 June 2025 and Army Regulation

200-1, the proposed action qualifies for a CATEGORICAL EXCLUSION (CX) that does not require a Record of Environmental

Consideration (REC).

(Skip to the “Approved By” section for NEPA Program Manager signature to compete the document.)

REASONING FOR USING CX:

Ꭓ A Record of Environmental Consideration (REC) is required.

REASONING FOR USING REC: It has been determined that the action qualifies for Categorical Exclusion (CATEX) in accordance with the National Environmental Policy Act of 1969 (NEPA) (42 United States [U.S.] Code Section 4321 et seq.) requires federal agencies to consider potential environmental impacts prior to undertaking a course of action. In accordance with NEPA, Department of Defense National

Environmental Policy Act Implementing Procedures, 30 June 2025 and Army Regulation 200-1, the Army has prepared CatEx (f)(1) for the

Routine repair of buildings, facilities, launch pads, structures, utility/communication systems, airfields, grounds, parking areas, targetry and other equipment, special hazards (e.g. ACM and/or LBP) are present and for which a Record of Environmental Consideration is required.

All screening criteria have been satisfied; therefore, no further action is required.

NEPA DETERMINATION: