ATTACHMENT B-Final CATEX.pdf

B_416 Renovation

May 2024

RECORD OF CATEGORICAL EXCLUSION

SUBJECT OF THE PROPOSED ACTION:

DESCRIPTION OF THE PROPOSED ACTION:

The Project scope is to Renovate Interior of building 416 to meet unique security requirements.

The work includes but is not limited to, Interior Renovations, Electrical work, lighting renovations, Mechanical work, Fire Protection, Entry control, Interior Armory, interior 2nd floor Protected room, Exterior Fencing and Access control.

This proposed project will also include the addition of a whole building Backup Generator and associated equipment.

SUMMARY OF ADDITIONAL ENVIRONMENTAL REQUIREMENTS:

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

Soil Disturbance - Stormwater

Must provide the Stormwater Program Manager a map with dimensions of the new surface to track for Chesapeake Bay Total Maximum Daily Load (TMDL).

Project is still subject to proper Maryland Best Management Practices for sediment erosion control and stormwater management even though official Maryland Department of the Environment (MDE) notification is not required. Contact the Stormwater Program Manager if you have any questions.

Water - Wastewater

For new HVAC equipment, ideally pure condensate (pure water) from the unit should not drain to the sanitary sewer. If the condensate is not pure water, please see the Wastewater Program Manager to see if the new discharge meets permit requirements. If necessary within the design of the system to drain to sanitary sewer, it must be tied in through the interior of the building as requested by ASUS.

Water - Drinking Water

There was no mention a new water line. If a new potable water connection is being made within the renovation, a sample may be required to verify we are meeting safe drinking water standards.

May 2024

Endangered Species

Exterior work should only be conducted during 01 July - 14 December of any year due to adjacency of federally protected species/nest that will be present/occupied outside of the provided work window.

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 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

If applicable, provide the Air Quality Program Manager a description of the boiler(s)/heater(s), including manufacturer/model, rated heat input capacity (Btu/hr), and fuel type. Based on the boiler/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.

May 2024

Provide the Air Quality Program Manager a description of the generator(s), including manufacturer/model, rated output capacity of the engine (bhp), and fuel type. Based on the generator size and fuel type, the Air Quality Program Manager will assist the project in determining the specific permitting and other requirements for the equipment.

o Ensure that the generator has a non-resettable hour meter installed prior to startup of the generator.

o The generator must burn only natural gas, or diesel fuel containing no more than 15 ppm sulfur and having a cetane index of at least 40 (or maximum aromatic content of 35 vol%) (available from the fuel farm) [40 CFR 60.4207(b) and 40 CFR 80.510(b)].

o The generator must be installed and configured according to the manufacturer’s specifications. The generator’s engine must meet the appropriate emission standard for new non-road engines for the same model year and maximum engine power [for compression-ignition engines, see 40 CFR 60.4205 (Subpart IIII), and 40 CFR 89.112/.113; for spark-ignition engines, see 40 CFR 60.4233 (Subpart

JJJJ)].

If applicable, fuel-burning units having engines rated at least 500 bhp (373 kW) 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 Emergency backup power units having engines rated at least 2,328 bph (1500 kW) must obtain a Certificate of Public Convenience and Necessity (CPCN) Exemption from the Maryland Public Service Commission (PSC) prior to applying for the PTC.

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

*Standard permitting fee $500; standard turnaround time 3 months for generators smaller than 2,000 kW; 6 months for larger engines.

Provide the Air Quality Program Manager a description of all air emission sources 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).

Ensure the contractor provides a copy of each technician’s HVAC certification and the certification for each piece of equipment*. Contact the Air Quality Program Manager for assistance and additional information.

Per 40 CFR 82-97, refrigerant(s) must be recovered from each appliance prior to final disposal of the appliance. The refrigerants shall be evacuated to the levels specified in the regulation prior to opening/disposing of the appliance. Ensure the contractor provides a signed statement to the Air Quality Program Manager with the following information:

May 2024 o Former location of the appliance, as it was installed/operated;

o Date the refrigerant is recovered from each appliance prior to being disposed;

o Type and quantity of refrigerant recovered from each disposed appliance; and o Name and address of the certified technician who recovered the refrigerant;

o Name and address of the person to whom the recovered refrigerant is transferred for reclamation or disposal*; and o Date that the recovered refrigerant is transferred for reclamation/disposal*.

No R-22 refrigerant shall be transferred to the Contractor. All excess/residual R-22 shall be recycled by depositing in the Navy’s portion of the ODS Reserve in accordance with specified procedures (www.dla.mil/Aviation/Offers/Services/AviationEngineering/OzoneDepRsrv.aspx), and as required by OPNAV-M 5090.1, Chapter 22. The collection cylinders for the recovered R-22 may be supplied by the government*. Notify the Air Quality Program Manager ASAP so that collection cylinders may be acquired for the project.

Do not procure new equipment containing an Ozone Depleting Substance (ODS) (e.g., R-22 refrigerant), per OPNAV-M 5090.1, Chapter 22. Notify the Air Quality Program Manager of the refrigerant type and charge amount used in new HVAC equipment.

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 26.11.06.03D.*

If cutback or emulsified asphalt is used, the project must comply with asphalt paving requirements described at COMAR 26.11.11.02. Contact the Air Quality Program Manager 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 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:

May 2024

*Technicians must be certified per EPA requirements at 40 CFR 82 [OPNAV-M 5090.1, Chapter 22]. Equipment used to recover, recycle, or reclaim refrigerant must also meet EPA standards.

*Technicians who dispose of appliances containing more than 5 lbs of refrigerant, must keep detailed records on both the recovery of refrigerant from the appliance, and the refrigerants’ ultimate transfer for disposal/reclamation (per 40 CFR 82, as amended).

*Regarding the R-22 turn in, the REQUIREMENT is for the project to collect it into dedicated cylinders and ship to DLA in Richmond. There are no-cost OPTIONS for meeting this requirement that are available during execution:

1) to have DLA (via NAVFAC EV) supply the cylinders to the contractor to fill;

2) DLA will pay for shipment of the filled cylinders (either the DLA- or contractor-owned) back to Richmond (note: contractor-owned cylinders will not be returned);

and/or

3) NAVFAC EV (via NAVSUP HazMin Center) can offer transport of the filled cylinders from the worksite to the HazMin Center warehouse, where they will be stored and shipped to Richmond.

*“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...

3) Installation and use of hoods, fans, and dust collectors to enclose and vent the handling of dusty materials...

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 26.11.06.03D]

*Example architectural coating VOC content limits:

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)

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)

May 2024

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.

Asbestos and Lead

Structures or buildings that were constructed prior to 1988 have the potential to contain asbestos and/or lead based paint. If the proposed project involves any type of renovation, alteration, or demolition, asbestos or lead based paint abatement may be required. Contact the Asbestos Program Manager for further guidance.

If the work area is found to contain regulated asbestos-containing material (RACM)*, the project activities must comply with the requirements of 40 CFR 61, Subpart M (National Emissions Standard for Asbestos – Demolition and Renovation) and 29 CFR 1926.1101 (OSHA Asbestos in Construction), as well as Maryland Title 26 - Department of the Environment regulations (COMAR 26). The regulations require that each owner or operator of a demolition or renovation activity involving RACM remove all such material from a facility being demolished or renovated before any activity begins that would break up, dislodge, or similarly disturb the material or preclude access to the material for subsequent removal.

If there is a release of asbestos fibers, or if there is a potential for release of lead based paint dusts, contact the Air Quality Program Manager for assistance and additional information.

If abatement is required on a project, an abatement plan is required by a State of Maryland Licensed Project Designer. All asbestos- and lead paint-containing waste shipping manifests shall be signed by a designated and qualified government representative.

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:

*RACM includes “a) friable asbestos material; b) Category I nonfriable ACM that has become friable; c) Category I nonfriable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading; or d) Category II nonfriable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations…” [40 CFR 61.141]

Hazardous Materials

The Contractor will ensure proper handling, storage and proper disposal of all hazardous material (e.g., refrigerant, 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.

May 2024

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.

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.

Waste lamps and ballasts shall be handled as universal waste or hazardous waste dependent upon their condition. Lamps/bulbs including fluorescent, HID, neon, high-pressure sodium, CFL, metal halide, LED, or mercury vapor are considered universal waste when in undamaged condition and shall be managed accordingly. Broken lamps are hazardous waste and shall be managed accordingly.

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

May 2024 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.

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

Petroleum Systems

Contact the Tanks Program Manager and provide the following information:

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

Specifications for Generator Belly Tank Installations:

o The generator fuel tanks will need to follow all NFPA 30 and COMAR 26.10 requirements. Please send all tank specifications to the Fuel Tank Program Manager.

o Fuel tank: Extended double-walled sub-base tank. UL 142-approved heavy-gauge steel tank, with a rust-proof finish paint outer coating.

o ALL tank gauges, vents, and controls must be installed on the extended portion of the tank, outside the generator cabinet walls.

o Gauges:

Mechanical fuel level gauge installed on the primary tank - recommended style dependent on size of tank: clock (larger tank), dial or pop-up (smaller tank). Clock gauges can be ordered in gallons or in feet/inches. All fuel level gauges must be constructed of metal and glass – NO PLASTIC.

Mechanical leak detection gauge (pop-up style) installed on the secondary tank. Leak gauge cover must be constructed of metal and glass – NO

PLASTIC.

NOTE – Both the fuel level gauge and the leak gauge must be tested and calibrated annually.

o Overfill Prevention: Level gauge must be installed in the filler’s direct line of site to satisfy federal Overfill Prevention regulations. If the genset is to be installed in close proximity to surface water or stormwater inlets/culverts, recommend that the tank is installed with a high-level alarm that sounds at 90% full, OR an overfill prevention valve that shuts off flow at 95% full.

o Spill Protection: Install a (lockable) 5-gallon spill containment bucket onto the primary tank fill port, with a fill port cap. The fuel level gauge MUST still be visible when the spill bucket’s lid is open.

o Vents:

Normal (atmospheric) vent must be installed on the primary tank (only). If tank is to be filled with a cam-lock nozzle, then the normal vent line diameter must be at least as wide as the fill port.

May 2024

Emergency vents must be installed on both the primary and the secondary tanks. These vents must be properly sized based on the tank volume.

o Grounding: Tank must be grounded, either through a bond to the generator/cabinet and its ground, or separately through a grounding wire bonded to the tank, and bonded to a buried rod.

o Low fuel level sensor and alarm: Can be relayed to the generator panel alarm, or to the overfill prevention high-level alarm box (if installed).

o Other Standard Features:

Fill Port drop tube Basin drain (plugged) Black paint finish Baffles to separate cold engine supply fuel from hot return fuel (additional baffling as required for structural integrity) o Bollards: NFPA 30A Chapter 4.3.7.1 - Guard posts or other approved means shall be provided to protect tanks that are subject to vehicular damage. When guard posts are installed, the following designs shall be acceptable: (1) They shall be constructed of steel not less than 100mm (4 in.) in diameter and be filled with concrete; (2) They shall be spaced not more than 1.2 m (4 ft) on center; (3) They shall be set not less than 0.9 m (3 ft) deep in a concrete footing of not less than 380 mm (15 in.) in diameter; (4) They shall be located not less than 1.5 m (5 ft) from the tank.

Comply with all NFPA 30 and COMAR 26.10 regulations for generator fuel tank installations. Please send all tank specifications to the Tanks Program Manager.

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 (i.e. Spill Kits).

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.

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).

May 2024 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.

With the addition of an Emergency Power Generator the above applies. Additionally, the generator belly tank will require secondary containment (double-walled tank) and leak detection monitoring IAW 40CFR 112.8 & NFPA 30 22.11.4.9 (leak gauge). Protective bollards installed IAW NFPA 30 4.3.7.2: Guard posts or other approved means shall be provided to protect tanks that are subject to vehicular damage. When guard posts are installed, the following designs shall be acceptable: (1) They shall be constructed of steel not less than 100mm (4 in.) in diameter and be filled with concrete. (2) They shall be spaced not more than 1.2 m (4 ft) on center. (3) They shall be set not less than 0.9 m (3 ft) deep in a concrete footing of not less than 380 mm (15 in.) in diameter. Minimum distance requirement of the bollards away from the tank, not less than 1.5 m (5 ft) from the tank. The generator belly tank will need to be properly marked IAW NFPA 30 21.6.5.3 (tank contents, tank ID, size, NFPA hazard label, no smoking, combustible or flammable). The generator fuel tank must meet all NFPA Ch 30 and COMAR 26.10 requirements.

PRESENCE OF NORMAL CIRCUMSTANCES:

This proposed action will not affect public health or safety. Exterior work should only be conducted during 01 July - 14 December of any year due to adjacency of federally protected species/nest that will be present/occupied outside of the provided work window. 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 controversial. Finally, the proposed action does not establish a precedent nor threaten a violation of Federal, State, or local environmental law.

May 2024

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 5090.1, Reference (c), Section 10.3.14, Table 10-6:

(14) Alterations of and additions to existing buildings, facilities, and systems (e.g., structures, roads, runways, vessels, aircraft, or equipment) when the environmental effects will remain substantially the same and the use is consistent with applicable regulations

Action reviewed by:

NEPA Coordinator Betsy Isley

Requirements accepted by:

Project Lead Stan Goins

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.