ATTACHMENT B B337 CATEX.pdf

Install Inbound F-24 & JP-5 Fuel Filtration System Page 1 of 7

March 2022

RECORD OF CATEGORICAL EXCLUSION

SUBJECT PROPOSED ACTION:

Install Inbound F-24 & JP-5 Fuel Filtration System

DESCRIPTION OF THE PROPOSED ACTION:

Install inbound fuel filter-separator for F-24(T-337) and JP-5(T-2787 & T-2788) pipelines.

Include an 1800 gpm capacity bulk air eliminator baffled tank, with large capacity (2") air eliminators, level switches, and 10" air-block valve and 120 volt power supply prior to the filter separator to each station. Install a packaged 600 gal product recovery tank, with pump and alarms, and Hi-level shut-off one for each service, located adjacent to filter separators. Construct two new containment curbs for receipt fuel filtration systems one for each fuel type.

Soil excavation will be no more than 550 cubic feet.

SUMMARY OF ADDITIONAL ENVIRONMENTAL REQUIREMENTS:

Soil Disturbance Historical and Archaeological Resources

• Carefully protect in-place and report immediately to the Contracting Officer historical and archaeological items or human skeletal remains discovered in the course of work. Upon discovery, notify the Contracting Officer or their representatives. Stop work in the immediate area of the discovery until directed by the Contracting Officer to resume work. If any artifacts or relics that are not obvious modern trash or debris, please call Craig Lukezic at 301-757-4774. Please take a digital image of the items along with a location map, and email them to craig.lukezic@navy.mil as soon as possible. The Government retains ownership and control over historical and archaeological resources.

Program Manger Comments: There are no intact archaeological deposits in the project area.

Soil Disturbance

• If the project does disturb over 5,000 square feet or 100 cubic yard the project will need to

Submit a combined Stormwater Management/Sediment and Erosion Control Plan and TMDL requirements in your Stormwater Management Plan to be approved by the Maryland Department of the Environment (MDE). Must incorporate LID (Low Impact Development) in compliance with EISA (Energy Independence and Security Act) Section 438 and the NAVFAC LID Policy in your Stormwater Management Plan. Please provide a copy of the final plan along with the MDE approval letter to the Stormwater Program Manager, Krystal Ayotte (301-757-4774).

Coastal Zone and Buffer Protection

• While project does not require a CZMA FCD due to size and nature of ground disturbance, the project proximity to tidal waters does result in a requirement for the project to have

Install Inbound F-24 & JP-5 Fuel Filtration System Page 2 of 7 sediment/erosion control BMPs in place around all areas of excavation before any digging commences and until the sites are stabilized after construction.

Tree Clearing

• No merchantable timber impacted by project based on current drawings / plans.

Solid Waste and Recycling

• The Contractor shall recycle the old carpet being removed from this project off base. The

Design Manager has provided the dimensions of carpet to be replaced. Contractor needs to provide landfill weight tickets to the government Engineering Technician for submission to the government Environmental Specialist within five days of removal from base for the rolloff dumpster being utilized.

Hazardous Materials

• The Contractor will ensure proper handling, storage and proper disposal of all hazardous material.

• 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 NAS PAX HazMat/EPCRA Program Manager, Danielle Hughes 301-757-9121 as soon as possible:

(1) SDS and product specs for all hazardous materials to be applied/used.

(2) General description of the intended use for each product.

(3) Total amount used (preferably weight).

(4) Span of dates the products are used.

(5) 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.

• NDWINST 5090.1 4 May 2018

• Ch. 23 and Ch. 26 of OPNAVINST 5090.1 3 Sep 2019

Hazardous Waste

• Ensure contractors working on projects remove all unused hazardous materials and waste generated by the project per all federal, state, local and Navy regulations.

• Contact the Regulated Waste Program Manager (Mario Maningas 301-757-4825) to determine if hazardous waste (flammable/corrosive/toxic) will be generated. Examples of waste include oil-contaminated rags, lead paint media/debris, solvent/thinner, fuel/oils/lubricants, stains, lamp ballasts, fluorescent and high-intensity bulbs, mercury switches, batteries, aerosol cans, and compressed gas cylinders.

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• All waste disposal documentation (manifests/shipping papers) require Regulated Waste

Program Manager signature or someone authorized by the Regulated Waste Program Manager prior to shipping off base.

• Ensure the hazardous 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

Air Quality and Emissions

• Take all reasonable precautions necessary to prevent particulate matter (i.e., dust) generated from the demolition, renovation, and construction activities from becoming airborne, per COMAR 26.11.06.03(D).*

• The project must comply with asphalt paving requirements described at COMAR

26.11.11.02. Contact the Air Quality Program Manager, Danielle Hughes at 301- 757- 9121 for assistance and additional information.

• 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, Danielle Hughes at 301- 757-9121 for assistance and additional information.

• Spray coating is best done inside of an approved facility, such as a paint booth or other enclosure. However, if alternative application methods (e.g., brush, roller) are not feasible and outdoor spraying cannot be avoided, the project must take the following actions:

o Spraying paint containing a solid Toxic Air Pollutant (TAP), per COMAR

26.11.16.07 (i.e., an ingredient/component that is part of the non-volatile portion of the paint (e.g., cadmium, zinc, chromates and other metal compounds)) outside of an approved enclosure with adequate filtration of overspray is strongly discouraged.

o Take all reasonable precautions necessary to prevent particulate matter (i.e., dusts, mists) generated from the unconfined, outdoor painting activities from becoming airborne, per COMAR 26.11.06.03(C).* o Notify the Air Quality Program Manager, Danielle Hughes at 301- 757-9121 at least 48 hours before outside spray painting is to be performed. The notification will ensure that a proper location has been selected and proper operating procedures are in place to minimize the release of particulates and other toxic materials into the air. The Air Quality Program Manager is also available to provide assistance and additional information.

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• 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, Danielle Hughes at 301- 757-9121 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:

*“These reasonable precautions [for preventing dusts from becoming airborne] shall include, but not be limited to, the following when appropriate as determined by the control officer:

1) Use of water or chemicals for control of dust in the demolition of existing buildings or structures, construction operations, the grading of roads, or the clearing of land.

2) Application of asphalt, oil, water, or suitable chemicals on dirt roads, materials stockpiles, and other surfaces which can create airborne dusts.

3) Installation and use of hoods, fans, and dust collectors to enclose and vent the handling of dusty materials. 4) Adequate containment methods shall be employed during sandblasting of buildings or other similar operations.

5) Covering, at all times when in motion, open-bodied vehicles transporting materials likely to create air pollution. Alternate means may be employed to achieve the same results as would covering the vehicles.

6) The paving of roadways and their maintenance in clean condition.

7) The prompt removal from paved streets of earth or other material which has been transported there by trucks or earth moving equipment or erosion by water.” [COMAR 26.11.06.03(D)]

*Example architectural coating VOC content limits (Note: These were lowered from previous limit, effective January 1, 2017):

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) Driveway Sealers – 0.42 lb/gal (50 g/L) Traffic Marking Coatings - 0.83 lb/gal (100 g/L)

For other coating categories and associated VOC content limitations, refer to COMAR 26.11.39.05 or contact the Air Program Manager, Danielle Hughes at 301- 757-9121 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)

For other adhesive/sealant categories and associated VOC content limitations, refer to COMAR

26.11.35.04 or contact the Air Program Manager, Danielle Hughes at 301- 757-9121 with questions.

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* “These reasonable precautions [for preventing paint mists from becoming airborne] shall include, when appropriate…, the installation and use of hoods, fans, and dust collectors to enclose, capture, and vent emissions.” [COMAR 26.11.03.06(C)]

Petroleum Systems

• Contact the Tank Program Manager, Brittany Babbington (301)757-4236, email brittany.a.babbington.civ@us.navy.mil and provide the following information:

-Tank size -Tank location -Type of fuel that will be stored

• Some petroleum tanks require an air permit to construct. All aboveground (AST) and underground (UST) storage tanks need to be added to the Oil Operations Permit from the Maryland Department of Environment (MDE). All USTs require notification to MDE prior to installation. In addition, project design must meet spill containment requirements in accordance with COMAR 26.10. Contact the Environmental Tank Program Manager, Brittany Babbington (301)757-4236, email brittany.a.babbington.civ@us.navy.mil for assistance and notification. The proposed project design shall be reviewed by the Environmental Tank Program Manager at each design phase.

• Must notify the Naval Air Station Fire Department and the Tank Program Manager, Brittany

Babbington (301)757-4236, email brittany.a.babbington.civ@us.navy.mil. The proposed project design shall be reviewed by the Tank Program Manager at each design phase.

• Must provide the Tank Program Manager, Brittany Babbington a description of the current heating source and the proposed work to be performed. The proposed project design shall be reviewed by the Tank Program Manager at each design phase.

Spill Contingency Planning

• Activities and operations aboard the NAS Patuxent River Complex that use or handle oil or hazardous substances shall:

o Maintain Site Specific Spill Contingency Plans to combat releases of hazardous substances or discharges of oil o Submit Site Specific Spill Contingency Plans to the NAS Public Works Environmental

Compliance Branch for review and approval o Provide appropriate containment and/or diversionary structures or equipment to prevent a discharge from entering soil or navigable waters o Ensure discharge prevention measures including procedures for routine handling of products (fueling of equipment, movement of oil and hazardous substances, etc) o Ensure appropriate discharge or drainage controls such as secondary containment around containers and other structures, equipment, and procedures for the control of a discharge mailto:brittany.a.babbington.civ@us.navy.mil mailto:brittany.a.babbington.civ@us.navy.mil mailto:brittany.a.babbington.civ@us.navy.mil

Install Inbound F-24 & JP-5 Fuel Filtration System Page 6 of 7 o Assure PW Environmental Branch its understanding of countermeasures for discharge discovery, response, and cleanup (both the facility’s capability and those that might be required of a contractor) o Provide PW Environmental Branch a written commitment of manpower, equipment, and materials required to expeditiously control and remove any quantity of oil discharged that may be harmful o Designate a person who is accountable for discharge prevention and who reports to facility management

• Activities and operations aboard the NAS Patuxent River Complex that use or handle oil shall train oil handling personnel in:

o the operation and maintenance of equipment to prevent discharges o discharge procedure protocols o applicable pollution control laws, rules, and regulations o general facility operations o the contents of the Installation Spill Prevention Control and Countermeasures Plan

• Activities and operations aboard the NAS Patuxent River Complex that stage (temporarily or permanently) shall provide an estimate of the potential number of mobile or portable containers, the types of oil, and anticipated storage capacities

Program Manager Comments:

Section 16, Question 1 of the Project Planning Checklist: Should be marked as “Yes” IAW project description/scope. (“Include a 1800 gpm capacity bulk air eliminator baffled tank”, “Install a packaged 600 gal product recovery tank”). Will each pipeline (F-24 and JP-5) require the 2 additional tanks?

Drainage of newly constructed secondary containment structures/berms will need to meet storm water discharge requirements. “Construct two new containment curbs for receipt fuel filtration systems one for each fuel type.”

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 structures in the vicinity are potentially eligible for the National Register of Historic Places (NRHP). According to various archeological surveys, no archeological sites are known to exist 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 controversial.

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

GENERAL CONFORMITY RULE DETERMINATION:

(1) In accordance with Section 176(c) of the Clean Air Act, the action is located in an attainment area (St. Mary’s County, MD) for NAAQS levels PM10, NO2, SO2, Carbon Monoxide, Ozone, and Pb, 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:

Subject proposed action can be categorically excluded from further National Environmental Policy Act (NEPA) processes per OPNAVINST 5090.1D, Reference (c), Chapter 10, Section

3.14 Table 10-6:

(35) Acquisition, installation, modernization, repair, or operation of utility (including, but not limited to, water, sewer, and electrical) and communication systems (including, but not limited to, data processing cable and similar electronic equipment) that use existing rights of way, easements, distribution systems, and facilities;

Action approved by:

NEPA Coordinator Anne Hodges

Requirements accepted by:

Project Lead Basa Wakjira

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 Design Manager must update the Planning Checklist and have the Categorical Exclusion reviewed for accuracy.