B448 Replace HVAC Unit - CATEX.pdf

B_448 Replace HVAC Unit

August 2019

RECORD OF CATEGORICAL EXCLUSION

SUBJECT PROPOSED ACTION:

DESCRIPTION OF THE PROPOSED ACTION:

Install a HVAC Unit in War Room (Vice Commander’s Office)

Install 2Ton Indoor unit in War Room (100A2), replace 2Ton Indoor unit in Vice Commanders Office (100A4).

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

• The Contractor shall recycle the old concrete pad being removed off base. The Design

Manager has provided the dimensions of concrete being removed.

• The old HVAC system being removed shall be recycled and shall be brought to the base

Recycling Center located in Bldg 604. Please contact William Stewart at 301-342-1509 to arrange for drop off.

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, Leslie Churilla 301-757-4930 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.

August 2019

• NDWINST 5090.1 4 May 2018

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.

• 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

• 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, Leslie Churilla 301-757-4930 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, Leslie Churilla 301-757-4930, 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 OPNAVINST 5090.1D, Chapter 22. The collection cylinders for the recovered http://www.dla.mil/Aviation/Offers/Services/AviationEngineering/OzoneDepRsrv.aspx

August 2019

R-22 may be supplied by the government*. Notify the Air Quality Program Manager, Leslie Churilla 301-757-4930 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 OPNAVINST 5090.1D, Chapter 22. Notify the Air Quality Program Manager, Leslie Churilla 301-757-4930 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).*

• 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, Leslie Churilla 301-757- 4930 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, Leslie Churilla 301-757-4930 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 [OPNAVINST 5090.1D, Chapter 22]. Equipment used to recover, recycle, or reclaim refrigerant must also meet EPA standards.

*Effective on January 1, 2018, 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.

August 2019

*“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. Adequate containment methods shall be employed during sandblasting of buildings or other similar operations. 4) 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…” [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) Concrete/masonry sealers - 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, Leslie Churilla at 301-757-4930 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, Leslie Churilla at 301-757-4930 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 Program Manager, Dave Morley at 301-757-4845 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.

August 2019

• 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, Leslie Churilla at 301-757-4930 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.

*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 tentatively determined that the buildings located on the installation have the potential for elevated radon levels in their lower level workspaces. IAW Navy radon policy, re-testing all testable nonresidential spaces in a building is required after each HVAC system modification or replacement [OPNAV M-5090.1D Ch. 25-3.2.b(1)(c)]*. Contact NAVFAC’s Radon Program Installation POC Manager for NAS PAX, Leslie Churilla at 301-757-4930 for further guidance.

• Program Manager Comments:

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

*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

NOTE: This requirement is being provided at this time (during the project’s planning) in order to identify all potential aspects that will need to be included in its scope. While the Radon Potential Category (RPC) for NAS PAX installations has not yet been finalized, it is likely that it will be designated as described in the narrative above and the follow-up testing will be required.

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

August 2019 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:

(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:

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

Action approved by:

NEPA Coordinator Anne Hodges

Requirements accepted by:

Project Lead Tracy Parson

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.