ATTACHMENT D - CATEX.pdf

H_115 Life Extension

June 2023

RECORD OF CATEGORICAL EXCLUSION

SUBJECT OF THE PROPOSED ACTION:

DESCRIPTION OF THE PROPOSED ACTION:

This project is to design 3 phases of hangar lean-to (15,000sf each) renovations which comprises of gutting and renovating the existing facility to improve operations and to comply with current codes and standards for a life extension. The first phase consists of renovations to the Center

Lean-To, B1407, and freight elevator, the second phase consists of renovations to the Waterside

Lean-To and B1482 (Line Shack), and the third phase consists of renovations to the Roadside

Lean-To and H115A (Boiler House). The site is less than 0.1 acres, with flat terrain and is previously developed. Available utilities include water, sanitary sewer, electrical, gas, and communications. Stormwater runoff flows away from the building on the north, east, south and west side. Improvements to the Lean-Tos include water distribution, fire protection and sanitary sewer.

As described in the letter to the State Historic Preservation Office (SHPO), the plan is to demolish B1668 in order to make room for a temporary structure to house staff and their function during rehabilitation of Hangar 115 along with other projects. The funding for this project is separate from the Hl15 project and is being reviewed separately.

SUMMARY OF ADDITIONAL ENVIRONMENTAL REQUIREMENTS:

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

Historic Preservation

We have completed the consultation process with the State Historic Preservation Office

(SHPO). On the 13th of June, the SHPO concurred with us the project will have a no adverse effect on historic properties.

Soil Disturbance - Stormwater

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

Must provide the Stormwater Program Manager a map with dimensions of the new surface to track for Chesapeake Bay TMDL.

June 2023

Water - Stormwater

Ensure the proposed project design routes the water discharge to the stormwater system

(either over land through an existing rain garden, pond, etc. or through existing piping). If the project intends to use existing stormwater features, the project will have to prove, using the original design calculations and as-built plans, that the feature is designed to handle the additional stormwater before the project can use the existing feature. Contact the

Stormwater Program Manager with any questions.

Water – Drinking Water

If the total length of any connection from the end of a new main to the existing main exceeds 18 feet, a successful bacteriological test must be performed prior to any public water consumption. A bacteriological sample must be collected every 1,200 feet of the new water main, plus one set from the end of the line and at least one set from each branch. All samples must be obtained by a state of Maryland certified sampler and be analyzed by a state of Maryland certified laboratory. All results shall be forwarded to the

Environmental Office, attention Potable Water Program Manager. All analyses must be in accordance with Standard Methods for the Examination of Water and Wastewater. Any disinfection procedures will be in accordance to procedures delineated in the AWWA standard “Disinfecting Water Mains” (ANSI/AWWA C651-05). Contact the Drinking

Water Program Manager with any questions.

Solid Waste and Recycling

Contact the Installation Environmental Program Director 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.

Air Quality and Emissions

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.

Fuel-burning units having burners rated at least 1 MM Btu/hr 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, June 2023 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. 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 MM Btu/hr): standard permitting fee

$400; standard turnaround time 3 months.

Provide the Air Quality Program Manager a description of all air emission sources (e.g., fuel-burning heaters/boilers) 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:

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 26.11.06.03(D).* http://www.dla.mil/Aviation/Offers/Services/AviationEngineering/OzoneDepRsrv.aspx

June 2023

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.

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

o Removal/stripping of paint that would cause the debris to be a hazardous waste

(e.g., lead-based paints, chrome-containing primers) is not permitted outside.

o Chemical stripping using hazardous products (e.g., dichloromethane (DCM)) is not permitted outside.

o Spraying products that contain 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 product (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 removal or spraying activities from becoming airborne, per COMAR 26.11.06.03(C).* o Notify the Air Quality Program Manager at least 48 hours before outside removal or spraying 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.

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:

June 2023

*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.

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)

Primers, sealers, undercoats – 0.83 lb/gal (100 g/L)

Industrial maintenance coatings – 2.08 lbs/gal (250 g/L)

June 2023

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 Quality Program Manager with questions.

* “These reasonable precautions [for preventing residual paint dusts and sprayed 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)]

*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 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.

June 2023

Follow the above action items and incorporate as appropriate into all specifications (e.g., RFPs

SOWs) associated with this project. Additional informatin 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]

Radon

It has been determined that the buildings located on the installation have the potential for elevated radon levels in their lower level workspaces. IAW Navy radon monitoring policy, re-testing all testable nonresidential spaces in a building is required after each relevant renovation or repair* [OPNAV M-5090.1 Ch. 25-3.2.b(1)(c)]. Contact NAVFAC’s Radon

Program Installation POC Manager for further guidance.

SOWs) associated with this project. Additional information is provided below

*Relevant renovations/repairs include: 1) renovations that will alter ground level floor plans

(e.g., addition or removal of walls, doorways); 2) modification or replacement of HVAC system components (e.g., AHUs, fans, air intake/exhaust vents); 3) roof repairs, replacement or renovation; 4) weatherization or other modifications/repairs that may alter the building envelope. Refer to the 2017 NAVRAMP Guidebook for Naval Shore Installations for additional information. This document and other resources can be found at www.cnic.navy.mil/NASPRCRadon

Hazardous Materials

The Contractor will ensure proper handling, storage and proper disposal of all hazardous material (e.g., sealants/caulks, adhesives, asphalt, concrete, refrigerants, 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.

http://www.cnic.navy.mil/NASPRCRadon

June 2023

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

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 o OPNAVINST 5090.1

June 2023

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.

Polychlorinated Biphenyls (PCBs)

Wastes containing PCBs at concentrations greater than 49 ppm must be disposed of as a hazardous waste. Disposal may require submittal of a lab analysis. Contact the Regulated

Waste Program Manager to have samples taken or to obtain a lab analysis.

Lamp ballasts may contain PCBs, ballasts manufactured prior to 1979 are assumed to contain PCBs unless “No PCB” is clearly stated. PCB-containing lamp ballasts shall be managed as Universal Waste.

There are no apparent PCB wastes associated with this project, however, contact the Regulated

Waste Program Manager if PCBs are encountered.

Oil Control

Since this location is a former Oil Control site, if any fuel contaminated soil is encountered it will have to be handled properly according to MDE Oil Control Program requirements

(sampled, taken off base).

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. We have completed the consultation process with the State Historic

Preservation Office (SHPO). On the 13th of June, the SHPO concurred with us the project will have a no adverse effect on historic properties. 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.

June 2023

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 5090.1, 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 Teena Wettengel

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.