ATTACHMENT A.2 - CATEX.pdf

B_2624 Replace Exhaust System

January 2024

RECORD OF CATEGORICAL EXCLUSION

SUBJECT OF THE PROPOSED ACTION:

DESCRIPTION OF THE PROPOSED ACTION:

Replace firing range ventilation system: gas-fired make-up air unit, exhaust unit, control DDC system, and two bathroom exhaust units.

SUMMARY OF ADDITIONAL ENVIRONMENTAL REQUIREMENTS:

These action items must be added to the specifications section of the contract or resolved before contract award.

Solid Waste and Recycling

Contact the Environmental Compliance Branch Head with the list of items and quantities that can be recycled. The Contractor must provide copies of all weight and landfill tickets to the Environmental Specialist within five days after removal from base.

Per the installation’s Stormwater Pollution Prevention Plan, ensure any on site dumpster doors remain closed when not in use (i.e., doors should only be open when actively disposing). Dumpster should not be filled past capacity to ensure doors can be physically shut. If the dumpster is being stored on a vegetated surface, such as a grass lawn, the area must be reseeded and stabilized after the project is completed.

Environmental General Awareness Training

All NASPRC personnel (including military, civilian, and contractors) are required to take the Environmental General Awareness Training.

ECATTS is an online environmental training site that can be accessed from any computer with access to the internet (you do not need a CAC). Instructions for taking the Environmental General Awareness Training in ECATTS:

o Go to https://environmentaltraining.ecatts.com o In the “NEW USERS-Register Here” box in the center of the page, enter "navfac" as the registration password and click on Create an Account.

o Complete only required fields in the registration form (help available at 866-730-

4253). You will be asked to select a UIC code (the NASPRC UIC code is 47608). Do not select any of the “training selection” options. Scroll to the bottom of the page, agree to the terms of use by selecting the appropriate box, and click “register”.

o Once you are properly logged into the system, you should see a page with the “EMS Training” heading at the top. Click on this heading and it will take you directly into

January 2024 the “Environmental General Awareness Training: Naval Air Station Patuxent River Complex (NASPRC)”.

o Read the training, complete the quiz, print the certificate and maintain it in your training records. You can request a roster from the EMS Manager by providing a list of names.

Air Quality and Emissions

Provide the Air Quality Program Manager a description of the make up air heater(s), including manufacturer/model, rated heat input capacity (Btu/hr), and fuel type. Based on the heater size and fuel type, the Air Quality Program Manager will assist the project in determining the specific permitting and other requirements for the equipment.

NOTE: Fuel-burning units having burners rated at least 1,000 MBH must obtain approval and a Permit to Construct (PTC)* from the Maryland Department of the Environment (MDE) prior to being delivered on site. With few exceptions, MDE considers even disconnected, but placed units to be installed; therefore, units that are delivered to the work site prior to the required PTC are at risk of violating the state’s permitting requirement.

o Contact the Air Quality Program Manager as soon as possible to coordinate the permitting effort and plan for delivering the unit.

*For most units (natural gas-burning less than 30,000 MBH): standard permitting fee $400;

standard turnaround time 3 months.

Provide the Air Quality Program Manager a description of all air emission sources (i.e, existing NG-burning MUA heater) that are removed from the project site, including the intended disposition of each (e.g., will be mothballed and placed into storage, or dismantled and disposed).

Do not apply an architectural coating with a VOC content in excess of the corresponding limit specified in COMAR 26.11.39.05*. Coatings of this nature include paints and other coatings that are applied to stationary structures, portable buildings at the site of installation, pavements, and curbs. Contact the Air Quality Program Manager for assistance and additional information.

Do not apply an adhesive/sealant with a VOC content in excess of the corresponding limit specified in COMAR 26.11.35.04. These include adhesives, sealants, adhesive primers, and sealant primers. This chapter contains additional requirements for adhesives, sealants, as well as associated surface prep and cleanup solvents. Contact the Air Quality Program Manager for assistance and additional information.

Program Manager Comments:

Follow the above action items and incorporate as appropriate into all specifications (e.g., RFPs SOWs) associated with this project. Additional information is provided below:

*Example architectural coating VOC content limits:

January 2024

Flat Coatings - 0.42 pound VOC per gallon coating (lb/gal) (50 grams per liter (g/L)) Non-Flat Coatings - 0.83 lb/gal (100 g/L) Non-Flat High-Gloss Coatings - 1.2 lbs/gal (150 g/L) Primers, sealers, undercoats - 0.83 lb/gal (100 g/L) Rust preventive coatings – 2.08 lbs/gal (250 g/L) Roof coatings – 2.08 lbs/gal (250 g/L)

For other coating categories and associated VOC content limitations, refer to COMAR

26.11.39.05 or contact the Air Quality Program Manager with questions.

*Example adhesive/sealant VOC content limits:

Cove Base Installation Adhesives – 1.25 pounds VOC per gallon product (lbs/gal) (150 grams per liter (g/L)) Multipurpose Construction Adhesives – 1.67 lbs/gal (200 g/L) Architectural Sealants – 2.08 lbs/gal (250 g/L) PVC adhesives – 4.25 lbs/gal (510 g/L) Nonmembrane roof adhesives/sealants – 2.5 lbs/gal (300 g/L) Single-ply roof membrane adhesives/primers – 2.08 lbs/gal (250 g/L) Single-ply roof membrane sealants – 3.75 lbs/gal (450 g/L)

For other adhesive/sealant categories and associated VOC content limitations, refer to COMAR 26.11.35.04 or contact the Air Quality Program Manager with questions.

Hazardous Materials

The Contractor will ensure proper handling, storage and proper disposal of all hazardous material (e.g., adhesives, sealants/caulks, coatings/paints, other products used by the project that require SDS)

The Contractor is responsible for ensuring that personnel are trained in the Hazardous Communication (HAZCOM) Standard prior to hazardous material usage.

The Contractor will maintain records throughout the course of the project of all manpower and material expenditures and will ensure accountability for material in the Contractors possession.

The use of hazardous materials in this project may be subject to the installation's regulatory reporting requirements under the Emergency Planning and Community Right-To-Know Act (EPCRA). The following information shall be submitted to the HazMat/EPCRA Program Manager as soon as possible:

o SDS and product specs for all hazardous materials to be applied/used.

o General description of the intended use for each product.

o Total amount used (preferably weight).

o Span of dates the products are used.

o Maximum amount of product that will be on site AT ONE TIME.

Ensure contractors working on new construction projects remove all unused hazardous materials and waste generated by the project.

January 2024

NDWINST 5090.1 4 May 2018 (Regional CHRIMP Instruction)

Ch. 23 and Ch. 26 of OPNAV-M 5090.1

Follow the above action items and incorporate as appropriate into all specifications (e.g., RFPs SOWs) associated with this project.

Hazardous Waste

Contractors are responsible for cost and removal of all regulated waste (Hazardous Waste, Universal Waste, Non-RCRA Regulated Waste) generated by the project in accordance with all federal, state, local, and Navy regulations.

Contact the Regulated Waste Program Manager to assist in waste stream determination.

Examples of commonly generated regulated waste include, but are not limited to:

oil/fuel/lubricant material and contaminated debris, lead contaminated debris, lead paint, solvent/paint/thinner/stain material and contaminated debris, fuels/oils/lubricants, mercury switches, batteries, aerosol cans, and compressed gas cylinders.

Ensure all regulated waste is properly stored, labeled/marked, and disposed in accordance with the following local, state, and federal regulations:

o Title 40, Code of Federal Regulations, Parts 260-279 o COMAR, Title 26.13 o OPNAVINST 5090.1

All waste disposal documentation (manifests/shipping papers) require the signature of the Regulated Waste Program Manager or someone authorized by the Regulated Waste Program Manager prior to shipping off base.

Please note that there is likely to be lead contaminants in the exhaust system of this building due to nature of it being a live range.

Follow the above guidance throughout the project for all waste generated and contact the Regulated Waste Program Manager for further guidance as needed.

PRESENCE OF NORMAL CIRCUMSTANCES:

This proposed action will not affect public health or safety. No wetlands or migratory bird populations will be affected by this action, and no listed threatened or endangered species are located in the vicinity. No historic structures will be affected by this project. According to our records, the undertaking will not affect archeological sites in this area. The proposed action does not have the potential for significant environmental effects on hazardous waste sites, according to the Federal Facilities Agreement. This action will not involve effects on the human environment that are highly uncertain, involve unique or unknown risks, or that are scientifically

January 2024 controversial. Finally, the proposed action does not establish a precedent nor threaten a violation of Federal, State, or local environmental law.

GENERAL CONFORMITY RULE DETERMINATION:

In accordance with Section 176(c) of the Clean Air Act, the action is located in an attainment area for NAAQS levels PM10, NO2, SO2, Carbon Monoxide, Ozone, and Pb (St. Mary’s County, MD), and is not subject to the conformity rule. This project will also meet the Northeastern Transport Region levels of 50 tons/year for Ozone.

CONCLUSION:

The subject proposed action can be categorically excluded from further National Environmental Policy Act (NEPA) processes per OPNAVINST 5090.1, Reference (c), Section 10.3.14, Table 10-6:

(8) Routine repair and maintenance of buildings, facilities, vessels, aircraft, ranges, and equipment associated with existing operations and activities (e.g., localized pest management activities, minor erosion control measures, painting, refitting, general building/structural repair, landscaping, grounds maintenance)

Action reviewed by:

NEPA Coordinator Betsy Isley

Requirements accepted by:

Project Lead Joel Rodriguez

This document does not relieve the proponent of compliance with applicable federal and state laws and regulations.

If the scope of work is modified, the Project Manager/Design Manager (or Construction Manager if Post Award) must update the Planning Checklist and have the Categorical Exclusion reviewed for accuracy.