Attachment E_CATEX B_2184 Replace HVAC System.pdf

B_2184 Replace HVAC System

January 2024

RECORD OF CATEGORICAL EXCLUSION

SUBJECT OF THE PROPOSED ACTION:

DESCRIPTION OF THE PROPOSED ACTION:

To replace (2) 7.5 tons HVAC systems and duct system associated accessories. Install new duct system with VAV boxes, DDC system, VFD's and UV lights.

See the Site Plan for additional information.

SUMMARY OF ADDITIONAL ENVIRONMENTAL REQUIREMENTS:

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

Water - Wastewater

Please ensure drain/condensate lines with pure water are drained to storm and not sanitation sewer.

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.

January 2024 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

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 26.11.06.03D.*

January 2024

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:

*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...” [COMAR 26.11.06.03D]

*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)

January 2024

PVC adhesives – 4.25 lbs/gal (510 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., 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.

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

Program Manager Comments:

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

Petroleum Systems

Must notify the Naval Air Station Fire Department and the Tanks Program Manager. The project will be located within 100 feet of an AST, UST, or fuel line. Please use extreme caution when disconnecting and replacing the fuel lines. The proposed project design shall be reviewed by the Tanks Program Manager at each design phase.

Program Manager Comments:

There is an AST (PG-2184) and generator belly tanks (GES-P-2184-01 and GES-P-2184-02) located within 100 feet of B2184. Please be mindful of the location of these tanks during the entirety of the project.

January 2024

Spill Contingency Planning

Use caution while working around installed fuel tank and two emergency power generators located near HVAC systems.

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 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.

January 2024

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.