Environmental_Special_Conditions 2018 (TE 4).pdf

USAG Fort Lee

Environmental Special Conditions

PROTECTING THE LAND WE DEFEND

Directorate of Public Works 825 19th Street, Building 6005

Fort Lee, VA 23801

Environmental Management Division Room 110

804-734-5014

This Standard Operating Procedure is subject to change at any time. It is the user's responsibility to ensure compliance with the most recent revision.

Technical Exhibit 4

USAG Fort Lee Directorate of Public Works Environmental Special Conditions 2018 i

This document is subject to change at any time. It is the user’s responsibility to be aware of updates and/or additions.

TABLE OF CONTENTS

Glossary of Abbreviations ...................................................................................................................... iii Foreword ............................................................................................................................................... vi Objective

Policies

Implementation

Training

Environmental Document Submittal Procedures

Environmental Protection Plans

Non-Compliance, Fines and Inspections

Environmental Program Areas

COMPLIANCE

Air Quality

Asbestos

Lead

Refrigerant

Hazardous Materials

Hazardous Waste

Solid Waste Management

Stormwater

CONSERVATION

Cultural Resources

Natural Resources

POLLUTION PREVENTION

Sustainability

Energy

Cross Connection Control and Backflow Prevention

Pest Management

RESTORATION

Site Safety

Monitoring Wells

Appendix A: Contract Language ii

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Appendix B: Off-Site Recycling Companies (page 1 of 2)

Appendix B: Off-Site Recycling Companies (page 2 of 2)

Appendix C: Utility Company Points of Contact (POC) (page 1 of 2)

Appendix C: Utility Company Points of Contact (POC) (page 2 of 2) iii

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Glossary of Abbreviations

AC&R Air Conditioning and Refrigerant

ACM Asbestos Containing Material

ARPA Archaeological Resources Protection Act

ASHRAE American Society of Heating, Refrigeration, and Air Conditioning Engineers

BMP Best Management Practice

BTEX Benzene, Toluene, Ethylbenzene and Xylenes

CAC Common Access Card

CO2 Carbon Dioxide

CFC Chlorofluorocarbons

CFL Compact Fluorescent Lamp

C&D Construction and Demolition

CFR Code of Federal Regulations

COR Contracting Officer’s Representative

CRM Cultural Resource Manager

CX Categorical Exclusion

DA Department of the Army

VDEQ Virginia Department of Environmental Quality

DA PAM Department of the Army Pamphlet

DoD Department of Defense

DPW-EMD Directorate of Public Works – Environmental Management Division

E&SC Erosion and Sediment Control

EA Environmental Assessment

EIS Environmental Impact Statement

EISA Energy Independence and Security Act

EMS Environmental Management System

EPA (US) Environmental Protection Agency

FAR Federal Acquisition Regulation iv

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GHG Greenhouse Gas

HAP Hazardous Air Pollutants

HAZMAT Hazardous Material

HAZWOPER Hazardous Waste Operations and Emergency Response

HMCC Hazardous Material Control Center

HVAC Heating Ventilation and Air Conditioning

IPMP Installation Pest Management Plan

IRP Installation Restoration Program

JP-8 Jet Propulsion-8

KO Contracting Officer

LEED Leadership in Energy and Environmental Design

LID Low Impact Development

MI-EMS Mission-Integration Environmental Management System

MS4 Municipal Separate Storm Sewer System

MSDS Material Safety Data Sheet

NEPA National Environmental Policy Act

NHPA National Historic Preservation Act

NOx Oxides of Nitrogen

O2 Oxygen

ODC Ozone Depleting Chemical

ODS Ozone Depleting Substance

OSHA Occupational Safety and Health Administration

PACM Presumed Asbestos Containing Material

PCB Polychlorinated Biphenyl

PM Project Manager

PPM parts per million

POC Point of Contact v

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RCRA Resource Conservation and Recovery Act

REC Record of Environmental Consideration

RMP Refrigerant Management Plan

RPA Resource Protection Area

SAS Satellite Area Site

SDS Safety Data Sheet

SHPO State Historic Preservation Officer

SOP Standard Operating Procedures

SMP Stormwater Management Plan

SWPPP Integrated Stormwater Pollution Prevention Plan

TCLP Toxic Characteristic Leaching Procedure

TSS Temporary Storage Site

UFC Unified Facilities Criteria

USACE US Army Corps of Engineers

USAG US Army Garrison

USGBC US Green Building Council

USTs Underground Storage Tanks

UXO Unexploded Ordnance

VAC Virginia Administrative Code

VDOT Virginia Department of Transportation

VOC Volatile Organic Compound(s) vi

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Foreword As stated in all United States Army Garrison (USAG) Fort Lee scopes of work/performance work statements and contracts, the Contractor shall comply with the most current version of this Environmental Special Conditions Package (hereinafter ESC) in the bidding and performance of contracts for work at USAG Fort Lee. The ESC is also available online.

This document was created by USAG Fort Lee’s Directorate of Public Works Environmental Management Division (DPW-EMD) to guide those engaging in construction projects and maintenance work within the boundaries of the installation. Federal lands are protected by many statutes, some of which are more restrictive and have requirements above and beyond those of the Commonwealth of Virginia or Prince George County.

The ESC is meant to identify requirements, in some cases which are unique to USAG Fort Lee, to be met in the performance of work and ensure full compliance with pertinent provisions of Federal, State (Virginia), and local regulations and procedures. The ESC is not intended to be fully inclusive of all regulations. It is the Contractor's responsibility to comply with all Federal, State, and local laws, regulations, or guidance. The Contractor shall also execute Environmental Best Management Practices (BMPs). Any fines and penalties that are the result of actions by the Contractor, its subcontractors, employees, other representatives or agents of the Contractor are the responsibility of the Contractor to pay. These fines/penalties will not be passed on to USAG Fort Lee.

Additionally, the Contractor, or its designated representative, shall act as an Environmental Officer on all work performed under an awarded contract. The Government’s Contracting Officer (KO), or designated representative, shall notify the contractor of any non-compliance with environmental requirements and any corrective action to be taken. Such notice, when delivered to the Contractor, or its representative on the work site or place of performance, shall be deemed sufficient for this purpose.

Anyone performing work at USAG Fort Lee is required to coordinate with the Government’s point of contact (POC) for a given project, usually the Project Manager (PM) or Contracting Officer’s Representative (COR), to ensure timely submittal of a complete and accurate Department of the Army (DA) Form 4283 (Facilities Engineering Work Request) or other project documentation to the DPW Business Operations and Integration Division (BOID) so that it may be properly tracked and routed through DPW’s project review management system.

Refer to the section on Environmental Document Submittal Procedures for more information.

http://www.lee.army.mil/dpw/emd/documents/Environmental_Special_Conditions.pdf http://www.lee.army.mil/dpw/emd/environmental.management.division.aspx http://www.lee.army.mil/dpw/emd/environmental.management.division.aspx http://www.apd.army.mil/pub/eforms/pdf/A4283.pdf

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Objective It is the duty of USAG Fort Lee’s environmental specialists to ensure that all projects that occur on USAG Fort Lee meet Federal, State, Local and Army requirements. This document contains fundamental provisions that pertain to common construction, renovation, repair and demolition activity which regularly occurs at USAG Fort Lee. Special projects may have additional requirements not mentioned in this SOP and as such, will require a more detailed review by environmental staff in order to ensure that all aspects of USAG Fort Lee’s environment is protected.

It is the Contractor’s responsibility to ensure that all of the requirements within this SOP are adequately addressed and that all requested submittals are received and approved by the DPW-EMD. There are a number of submittals noted within this document that are required to be delivered to DPW-EMD. Failure to adhere to these requirements will delay final payment to the Contractor, and possibly require the contractor to uninstall out of spec equipment or re-design and correct any components of the project that do not pass final inspections.

A reference to this SOP must be included in all Performance Work Statements, Scope of Works, and Contract Proposals for work at USAG Fort Lee. A project submittal will not be approved by the DPW-EMD without including such reference.

This document is reviewed and updated annually to reflect changes in regulations and policies.

Achieving compliance with laws and regulations is a team effort at USAG Fort Lee and close integrated collaboration between Contractors and environmental staff is key to protecting the environment in which our families work, live and play. In accordance with the National Environmental Policy Act (NEPA), it is imperative to “encourage productive and enjoyable https://ceq.doe.gov/ https://ceq.doe.gov/

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harmony between man and his environment; to promote efforts which will prevent or eliminate damage to the environment and biosphere, and stimulate the health and welfare of man; to enrich the understanding of the ecological systems and natural resources important to the Nation.”

NEPA is the underlying national charter for protecting the environment. It was enacted on January 1, 1970 and is referred to as the “Environmental Magna Carta.” Each Federal agency has its own implementing procedures which adapt the regulations to address agency specific missions and decision-making authority. The NEPA process begins when an agency proposes to take an action (this can include proposals to adopt rules and regulations, formal plans that direct future actions, programs and specific projects). Once a proposal is conceptualized and any reasonable alternatives have been developed, the agency must determine if the action has the potential to affect the quality of the human environment. This process results in one of three levels of NEPA analysis. Agencies may:

apply a Categorical Exclusion (CX);

prepare an Environmental Assessment (EA); or prepare an Environmental Impact Statement (EIS).

The majority of USAG Fort Lee actions do not require an EA or EIS and can be documented with a Record of Environmental Consideration (REC) using a CX, which are listed in 32 Code of Federal Regulations (CFR) Part 651 Appendix B. However, it is important to note that CX’s are sometimes not applicable because NEPA does not replace or supercede the requirements of certain other laws or regulations, such as the National Historic Preservation Act.

Ultimately, the level of NEPA analysis and documentation for each project is determined by the Chief of the DPW-EMD or designated representative, who utilizes processes outlined in NEPA to ensure that all requirements are being addressed. Part of this process includes using information from subject matter experts to determine the environmental effects of every project proposed to occur on USAG Fort Lee property.

Any modifications to USAG Fort Lee property or its environment must be executed in a manner that prevents pollution, protects the environment, conserves natural resources and avoids historic properties. All procedures must follow the requirements specified in this this SOP and be in joint effort with the DPW.

Policies Organizations, tenants, and military units shall review their policies, procedures, and regulations accordingly and revise them as necessary to ensure full compliance with the purposes and provisions of this SOP for actions requiring either federal dollars or federal property.

https://www.gpo.gov/fdsys/pkg/CFR-2012-title32-vol4/pdf/CFR-2012-title32-vol4-part651-appB.pdf

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Where contractor activities on federal property affect an agency’s environmental management aspects, USAG Fort Lee’s Mission-Integration Environmental Management System (MI-EMS) requirements shall be included in contracts to ensure proper implementation and execution of Environmental Management System (EMS) roles and responsibilities. Applicable policies and regulations are noted throughout, but not limited to those referenced in this document.

Approved language for all contracts executed for work performed at USAG Fort Lee is presented in Appendix A. All new and revised contracts are to be thoroughly reviewed by DPW-EMD specialists to ensure full compliance with environmental laws, regulations, policies, and mandates. This language is subject to change based on the various local, state, and federal laws.

Implementation All work performed within USAG Fort Lee boundaries shall be carried out in accordance with all applicable federal, state, and local laws, ordinances, regulations, Executive Orders, court orders, and other types of rules or rulings including USAG Fort Lee policies.

The following shall be submitted as guidance, not all inclusive, in accordance with USAG Fort Lee submittal procedures:

Copies & signatures of all licenses and permits (i.e. signed VDEQ permit authorization) Permit fees; copy of checks Calculations and methods identified Certified reviewed plans and P.E. stamp The Plan Reviewer’s Certification Map with verified constraint boundaries adjacent to or within the project limits Map with verified wetlands and the 100 Resource Protection Area (RPA) Buffer that exists adjacent to or within the project limits

Training USAG Fort Lee’s MI-EMS requires Environmental General Awareness Training (EGAT) fence line-to-fence line and implementation at all appropriate levels. Federal Policy mandates that PMs, Prime Contractor Points-of-Contact, and the on-site Project Superintendent shall ensure all workers on USAG Fort Lee meet this requirement, for which training is updated annually.

Once the presentation has been reviewed, a single list with the names of those who have completed the training shall be submitted to the Pollution Prevention Program Manager for inclusion in the annual Environmental Management Review meeting. Having a copy of the quick reference handout at your desk is also recommended. Additionally, the International Organization for Standardization developed the ISO 14001 standard to provide a set of http://www.lee.army.mil/dpw/emd/mi.ems.aspx http://www.lee.army.mil/dpw/emd/documents/MI-EMS_EGAT_Slides.pdf mailto:usarmy.lee.imcom.mbx.leee-dpw-environment-management@mail.mil?subject=EGAT%20Training http://www.lee.army.mil/dpw/emd/documents/MI-EMS_EGAT_Handout.pdf http://www.iso.org/iso/iso14000

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internationally recognized criteria for Environmental Management Systems. The Army adopted the ISO 14001 standard because it provides a proven, systematic approach to managing the environmental risks associated with an organization's activities, products, training and services. ISO 14001 offers some flexibility, allowing an organization to pursue its own performance goals as long as they are consistent with environmental policy. Under this standard, organizations commit to continuous improvement, prevention of pollution and compliance with legal requirements.

Environmental Document Submittal Procedures For environmental issues, the DPW-EMD serves as USAG Fort Lee’s repository for copies of permits obtained by contractors as required by environmental regulatory agencies such as the United States Environmental Protection Agency (EPA) and the Virginia Department of Environmental Quality (VDEQ). Upon request, copies of permit applications, mandatory notification requirements (to include spills and releases), mandatory reports, and proof of compliance actions (including records, checklists, logs, etc.) are required to be submitted to the DPW-EMD. Unless otherwise noted, submittals shall be provided to the DPW-EMD Administrative Assistant, Building 6005 Room 110, 804-734-5014.

Environmental Protection Plans

The Contractor will establish and implement an Environmental Protection Plan (EPP), which is a single document comprised of several smaller documents addressing the topics of air pollution, asbestos/lead abatement, erosion and sediment control, pest management, spill control, stormwater pollution prevention, unexploded ordnance/munitions, explosive of concern, hazardous materials management, waste management and cultural and natural resources. Within 30 calendar days from contract award, the Contractor shall submit to the KO or designated Government representative, a comprehensive EPP which describes the policies and procedures being implemented to ensure compliance in each of the above areas. All matters in reference to environmental protection shall be coordinated with the KO (or designated Government representative) and the DPW-EMD. No site work may be performed prior to DPW-EMD receipt and approval of the EPP.

The Contractor shall also comply with AR 200-1, and all regulating entities regarding pollution control, clean air, clean water, toxic substance control, resource conservation and recovery, natural resources, cultural resources, the Installation Spill Contingency Plan, the Installation Hazardous Waste Management Plan, SWPPP, Qualified Recycling Program, Installation Pest Management Plan (IPMP), Refrigerant Management Plan (RMP), Green Procurement Plan, as well as any other Federal, State, and local programs and policies and construction standards.

Project plans shall include pollution prevention provisions such as the elimination and minimization of oil and pollutant releases, address solid waste management (including hazardous waste, C&D debris) and all other potential impacts that Contractor activities may https://www3.epa.gov/ http://deq.state.va.us/ http://deq.state.va.us/ http://armypubs.army.mil/Search/ePubsSearch/ePubsSearchForm.aspx?x=AR

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have on environmental quality. Environmental constraint maps are available by request from the DPW-EMD, Building 6005, Room 110.

PMs can reduce delay to projects by:

Emphasizing interagency cooperation prior to the preparation of environmental reports rather than submission of inadequate information resulting in the return of documents requiring amendments.

Using the scoping process for an early identification of project-specific issues.

Noting that USAG Fort Lee must follow Federal, Department of the Army, State, Local and

USAG Fort Lee policies and regulations. When more than one agency has jurisdiction, the most stringent regulation or policy applies.

Combining environmental documents with supporting documents such as maps, drawings, specifications, and written statements.

Non-Compliance, Fines and Inspections

Informal and formal enforcement actions (e.g. citations and notices of violation) issued by regulatory authorities against the Contractor and/or Government-owned Contractor Operated facilities found to be in noncompliance with environmental requirements will be resolved by the Contractor through coordination with the KO (or designated Government representative), the DPW-EMD and issuing office of the affected Federal, State, or local environmental agency.

In accordance with Federal Acquisition Regulation (FAR) 31.205-15 (fines, penalties and mischarging costs), the Contractor will be solely responsible for paying any penalties levied for noncompliance resulting from the action or inaction of the Contractor or the contractor’s employees. The Contractor shall also be solely responsible for non-compliance resulting from the action or inaction of the owner(s) or employee(s) of firms with whom the Contractor has sub-contracts or agreements, in order to fulfill requirements of or related to their contract with or for work at USAG Fort Lee.

Environmental Program Areas The Directorate of Public Works-Environmental Management Division (DPW-EMD) focuses on four major areas: Compliance, Conservation, Pollution Prevention and Restoration. The DPW- EMD provides the means necessary to meet the Army’s mission of protecting the environment by utilizing an integrated environmental and training platform. Protection and preservation of the environment ensures that USAG Fort Lee will remain a major Army asset with the flexibility to meet future mission needs. Nearly all actions have environmental impacts and it is the DPW-EMD’s mission to supply the best advice and guidance to Army decision makers.

Additional duties include creating sustainable programs and operations and offer solutions which minimize impacts of training and mission success.

https://www.acquisition.gov/?q=/browse/far/31 http://www.lee.army.mil/dpw/emd/compliance.aspx http://www.lee.army.mil/dpw/emd/conservation.aspx http://www.lee.army.mil/dpw/emd/pollution.prevention.aspx

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COMPLIANCE

This program area encompasses Air Quality, Asbestos, Lead, Refrigerants, Hazardous Materials, Hazardous Waste, Solid Waste and Stormwater. The requirements for each are discussed below.

Air Quality

Fixed, installed real property that produces or has the potential to produce any of the six criteria pollutants, hazardous air pollutants (HAPs), greenhouse gases (GHG), or fugitive ozone depleting chemical (ODC) emissions into the atmosphere constitutes an emissions unit at USAG Fort Lee, and is subject to regulations set forth under the Clean Air Act. All emissions units on Department of the Army property, USAG Fort Lee, must meet all applicable requirements and performance standards, as specified by USAG Fort Lee’s Garrison Commander, through USAG Fort Lee’s DPW-EMD. DPW-EMD will make final recommendations on whether environmental regulatory, stewardship, sustainable and technical aspects of current and future operations are sufficient to meet the intent of the Clean Air Act and USAG Fort Lee's specific sustainability goals and strategies. Only projects found by the DPW-EMD Air Quality Program to demonstrate compatibility with the aforesaid aspects are eligible for approval and may proceed through procurement and construction.

Regulatory requirements pertaining to non-stationary mobile sources are also enforced by the Environmental Special Conditions requirements below. Any owner/operator of a stationary or mobile source on USAG Fort Lee property has a duty to understand and adhere to the applicable legal requirements to protect human health and the environment.

The following requirements do not set forth all existing stationary and/or mobile source Clean Air Act regulatory requirements for which the owner/operator may be subject.

Adherence to these Environmental Special Conditions requirements does not imply adherence to all applicable requirements set forth under the Clean Air Act to which the entity may be subject.

Air Emission Producing Units Stationary sources of air pollutants are required to be permitted, and their use and throughputs tracked in accordance with Fort Lee’s Air Permit to ensure that USAG Fort Lee remains in compliance with all Federal, State, local and Army regulations. The installation is quantitatively limited by the amount of pollutants emitted from its sources.

The following equipment list contains examples of common stationary sources which emit regulated criteria pollutants and GHGs, and as such, requires written approval from DPW-EMD PRIOR to procurement:

Natural Gas-Fired Heating Equipment (including but not limited to boilers, water heaters, furnaces, unit heaters, space heaters) https://www.epa.gov/clean-air-act-overview/clean-air-act-text

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Compression / Spark Ignition Reciprocating Internal Combustion Engines (including but not limited to non-emergency / emergency generators, fire pumps, light sets, popper / deformer generators)

Paint Booth Equipment / Blasting Equipment Fire Fighting Training Equipment Welding Equipment Solvent Cleaners (including but not limited to parts washers and weapons cleaners) Underground Storage Tanks (USTs) (including but not limited to those storing gasoline, MOGAS, E-85, jet propulsion-8 (JP-8), No. 2 distillate oil, diesel fuel, or biodiesel)

Aboveground Storage Tanks (ASTs) (including but not limited to those storing all of the above fuel types)

Woodworking Equipment Pumps Engine Testing / Heating Equipment (not including kitchen, dining facility, laundry equipment) or portable heaters, unless said portable heater will remain in operating mode in one location for 12 months or more.

X-Ray Operations Landfills Make-Up Air Unit Roof-Top Units Any other equipment that emits pollutants regulated under the Clean Air Act

Air Emission Producing Unit Procurement and/or Installation Process Prior to procurement and/or installation, all proposed emissions units operated by

USAG Fort Lee, a tenant organization, or other duly assigned non-USAG Fort Lee operational entity must be reviewed and approved by the DPW-EMD Air Quality Manager. Approval is acquired through the submission of a formal request to DPW- EMD with the project details, and the proposed product specification sheet. Failure to obtain said pre-procurement formal approval from DPW-EMD may result in equipment retrofit, uninstall or removal from USAG Fort Lee property at the cost of the contractor.

To ensure the emissions unit meets USAG Fort Lee’s air quality regulatory requirements, the applicable point of contact (Government PM, Tenant Organization POC, or Contractor) will submit the product specifications via email or hand deliver to

DPW-EMD.

mailto:usarmy.lee.imcom.mbx.leee-dpw-environmental-management@mail.mil

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Air Emission Producing Units Owned by USAG Fort Lee

Emissions units for which USAG Fort Lee assumes full ownership with complete guidance, management, and operational control are required to be included in USAG Fort Lee Air Permit. Prior to procurement, each proposed emissions unit to be operated at USAG Fort Lee, by the Garrison or by a Contractor, must have an official request submitted for review and receive written approval from the DPW-EMD Air Quality Program.

Air Emission Producing Units Owned by Tenants/Other Organizations

Only emissions units for which USAG Fort Lee assumes full ownership and complete guidance, management, and operational control are authorized to be included in USAG Fort Lee Air Permit. Emissions units associated with the following tenant organizations are NOT included on USAG Fort Lee Air Permit:

U.S. Air Force/Navy U.S. Marine Corps Army Air Force & Exchange Service Defense Contract Management Agency Defense Commissary Agency Old Dominion Utility Service Virginia American Water Company AT&T New Cingular Wireless Petersburg Cellular Partnership / Verizon Wireless Power Secure USAG Fort Lee Commonwealth Communities (Pinnacle Properties LLC) T-Mobile Wireless

Since the above entities constitute public/private organizations separate and distinct from the USAG Fort Lee, USAG Fort Lee assumes no legal responsibility for the emissions units operated by or on behalf of the aforementioned organizations, or any future organization that proposes the installation of an emissions unit at USAG Fort Lee. Although legal title to the property on which USAG Fort Lee tenant organizations’ facilities are located is held by the United States Government and carried on USAG Fort Lee’s property book, operational control of the individual units are held by that tenant organization regardless of installed equipment, property book, ownership considerations, assignment, or other circumstances. All units installed by tenant organizations must still adhere to all federal, state, and local laws, as well as Fort Lee’s ESC. Failure to submit technical data regarding emissions of proposed units, and receiving approval

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from DPW-EMD-AQ to proceed with procurement and install could result in unit retrofit at the cost of the contractor, or complete removal from Fort Lee property.

Low Nitrogen Oxides (NOx): Furnace/Boilers/Unit Heaters/Make-up Air

Units/Other External Combustion Units The emissions units covered in this section must be high-efficiency units and fired with only natural gas. Under no circumstance will these emissions units be equipped with the capability of burning No. 2 distillate fuel oil or any other distillate, residual fuel oil type. They shall be equipped with a low nitrogen oxide (NOx) burner system for guaranteed NOx performance when using natural gas at no greater than 30 parts per million (ppm), dry volume basis and corrected to 3% excess oxygen (O2).

Prior to equipment purchase, low NOx certification must be obtained and sent to the DPW-EMD Air Quality Program Manager or by calling 804-734-5061 to arrange hand delivery. Reference that the equipment is on a South Coast Air Quality Management District (SCAQMD) low-NOx list or that it is in compliance with Rule 1146.2 is not adequate to demonstrate compliance with this performance standard. The SCAQMD standard states that any unit that is in compliance under Rule 1146.2 is required to possess stack testing data for each unit. A sticker indicating NOx emissions performance is also not adequate to demonstrate compliance with this performance standard.

If quantitative low-NOx documentation that is technically-sufficient to meet the DPW- EMD's requirements is not obtainable from the manufacturer after equipment installation is completed, the Contractor must provide the services, at its cost, of a field representative for stack testing. The Contractor shall provide the DPW-EMD Air Quality Program with a copy of these stack testing results adequate to demonstrate compliance with the 30 ppm NOx guarantee within five (5) business days after commissioning the unit.

Volatile Organic Compounds (VOC) All coatings and solvents used in the performance of this contract shall meet required performance specifications and not exceed the volatile organic compound (VOC) limits of the Air Pollution Control Districts where they are used.

VOC Work Practice Standards

Solvent products which contain VOCs shall not be intentionally spilled, discarded in sewers, stored in open containers, or handled in any other manner that would result in evaporation beyond that consistent with air pollution practices for minimizing emissions.

mailto:brandy.l.reeves.civ@mail.mil

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If the Contractor anticipates a significant amount of VOC containing material to be used during the course of a project, they shall maintain Material Safety Data Sheets (MSDS) or other vendor information on site demonstrating the VOC content substance used.

Solvent Use

Depending on the type of solvent cleaning equipment, USAG Fort Lee will be subject to 9 VAC 5-40-3260 (Rule 4-24), Emission Standards for Solvent Metal Cleaning Operations Using Non-Halogenated Solvents. As part of an effective ozone pollution control strategy, operations that utilize solvent containing materials (e.g., hand wiping, immersion, or vapor degreasing for surface cleaning, paint clean up, and general maintenance activities) should employ pollution prevention measures such as use of non- or low-VOC content solvents.

In addition, HAP emissions can be reduced by substituting very low HAP (less than five percent) or HAP-free/exempt products. A HAP-free water-reducible product should be used for cleaning paint guns and lines. Notably, the decision and authority to use an alternative product must follow the appropriate implementation route. Although methyl ethyl ketone was recently delisted as HAP, it is not to be considered a viable alternative solvent. Ozone Depleting Substances (ODS) containing solvents shall not be used without the approval of the Environmental Support Office of the Assistant Secretary of the Army (Acquisition, Logistics and Technology). Solvent Distillers should be used wherever possible to reduce the amount of solvent materials purchased by reclaiming and reusing the solvent on site.

Fugitive Dust Emission Controls Contractors and government personnel shall not cause or permit any materials or property to be handled, transported, stored, used, constructed, altered, repaired or demolished without taking reasonable precautions to prevent particulate matter from becoming airborne. Reasonable and approved precautions include, but are not limited to:

Use, where possible, water or chemicals for control of dust in the demolition of existing buildings or structures, construction operations, the grading of roads, application of gravel or the clearing / grubbing of land. Water must be on site daily prior to beginning work.

Application of asphalt / gravel, water, or approved chemicals on dirt roads, material stockpiles and other surfaces which may create airborne dust and maintaining them in a dirt free condition.

Installation and use of hoods, fans and fabric filters to trap, catch, enclose and vent the handling of dusty materials. Adequate containment methods approved by the DPW-EMD shall be employed during sandblasting or other similar operations.

http://law.lis.virginia.gov/admincode/title9/agency5/chapter40/section3260/

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Open equipment for conveying or transporting materials likely to create objectionable air pollution when loaded with dusty materials shall be covered or treated in an equally effective manner at all times when in motion or awaiting transportation.

The prompt removal of spilled, tracked dirt, dried sediments or other materials from paved streets resulting from soil erosion (9 VAC 5-40-90).

Emergency/Non-Emergency Generators Regardless of the engine's power or date of manufacture, all generators shall be in accordance with 40 CFR 60, Subpart IIII and JJJJ, and be certified to Tier 4i emission standards.

“No compression ignition or spark ignition internal combustion engine (CI/SI) shall be installed at USAG Fort Lee that is unable to demonstrate compliance with the tiered emission limits set forth by New Source Performance Standards Subpart IIII or Subpart JJJJ corresponding to either the actual year of physical installation or a year subsequent to the actual year of physical installation, unless the emission standards for a previous model year are equivalent in magnitude. This requirement applies to emergency, non-emergency, or any combination of units.”

Fuel Requirements

All diesel stationary engines with a displacement of less than 30 liters per cylinder must use diesel fuel with a maximum sulfur content of 15 parts per million.

Pollutant Emitting Equipment/Vehicles All pollutant-emitting equipment shall operate in strict accordance with Virginia Regulation 9 VAC 5-40-5670, PART II Emission Standards and ARTICLE 41 Emission Standards for Mobile Sources (Rule 4-41).

In the event a unit fails to meet these criteria by emitting smoke during times other than immediate start-up or shut- down, the operator must shutdown the unit immediately and in a manner that ensures safety. The operator must ensure that repairs are made by a qualified technician, or replace the unit with one that can be operated in a manner that adheres to this regulation.

Anti-Idling Policy USAG Fort Lee’s Energy Conservation Measures Policy states that the maximum amount of idling time for vehicles should not exceed 30 seconds. In most gasoline engines, the amount of gasoline used to start the engine is equal to the amount of gasoline used to idle for 30 seconds. This means that fuel used to idle after 30 seconds is considered wasting precious resources and also leads to unnecessary contributions to air pollution. With exception of diesel-powered vehicles, such as tour buses and http://law.lis.virginia.gov/admincode/title9/agency5/chapter40/section90/ https://www.gpo.gov/fdsys/pkg/CFR-2011-title40-vol6/xml/CFR-2011-title40-vol6-part60.xml http://www.deq.virginia.gov/Portals/0/DEQ/Air/Regulations/441.pdf http://www.lee.army.mil/documents/policy/FL%20Policy%2010-06%20Fort%20Lee%20Energy%20Conservation%20Measures.pdf

This document is subject to change at any time. It is the user’s responsibility to be aware of updates and/or additions.

fire/emergency service vehicles, State law requires that vehicles used during commercial and public service (which includes every government vehicle on the installation) shall not idle for more than three minutes. For diesel-powered vehicles, idling is limited to ten minutes. Not only does unnecessary idling of vehicles waste fuel and impair air quality, it is against both State law and Army regulation.

Ozone Depleting Substances and Chemicals The Contractor shall comply with the EPA regulations issued under Title VI, Sections 601-608 of the Clean Air Act pertaining to ODS and the Montreal Protocol.

The Contractor shall not utilize or provide Class I ODS equipment on USAG Fort Lee, Virginia. Contracts may not include any specification, standard, drawing, or other document that requires the use of a Class I ODS in the design, manufacture, test, operation or maintenance of any system, subsystem, item, component, or process.

This includes the delivery of any items of supply that contains a Class I ODS or any service that features the use of a Class I ODS.

Asbestos

Asbestos containing materials (ACM) or lead based paint (LBP) will not be used on USAG Fort Lee projects. Contact the DPW-EMD to determine the extent of ACM or lead present in existing facilities impacted by a project. Contractors will coordinate with the DPW-EMD Asbestos/Lead Specialist and shall be included in the Asbestos/Lead testing protocol to determine the appropriate tests needed based on the scope of work. If asbestos not previously known to exist is exposed, the Contractor shall cease work in the affected area immediately and notify the KO and DPW-EMD.

Hazardous Material Inspection prior to renovation and demolition:

Federal, state, and local laws require a thorough inspection for asbestos prior to any renovation or demolition, regardless of the age of the building! These laws are not new.

The federal law that requires asbestos Air Pollutants):

NESHAP (40 CFR 61.145) states in part, “thoroughly inspect the affected facility or part of the facility where the demolition or renovation operation will occur for the presence of hazardous materials.” The law does not specify any limit on the age of the building, nor does it limit the type or size of the activity. By definition (61.141), any activity that alters one or more facility components in any way is a renovation. These requirements will be tested with the same requirements as listed below.

For questions about Asbestos or Lead Testing please contact the Fort Lee Air Program Specialist at:

804-734-5123 https://www.epa.gov/clean-air-act-overview/title-vi-stratospheric-ozone-protection https://www.epa.gov/clean-air-act-overview/title-vi-stratospheric-ozone-protection https://www.epa.gov/ozone-layer-protection/international-actions-montreal-protocol-substances-deplete-ozone-layer

This document is subject to change at any time. It is the user’s responsibility to be aware of updates and/or additions.

Testing procedures for lead and asbestos shall adhere to the following:

The DPW-EMD shall be notified in advance of testing/sampling of ACM or LBP in order to have the option of being on site for witnessing.

All testing shall be performed by a third-party contractor that is trained, certified and licensed in the Commonwealth of Virginia as an Inspector.

The third-party contractor must be contracted by the Prime Contractor and have no affiliation to the abatement contractor.

All samples shall be accompanied by a Chain of Custody (COC).

The DPW-EMD shall receive a copy of the COC and lab results.

Failure to follow the procedures above may result in the rejection of sample results.

Asbestos Abatement Plans USAG Fort Lee complies with all regulations involving asbestos and requires contractors to submit an Asbestos Abatement Plan if there is the possibility of asbestos to exist, or if there are current surveys that indicate it is present.

The Contractor will submit the Asbestos Abatement Plan, revisions, and all other associated documentation requested by the DPW-EMD to the COR as part of the EPP prior to the initiation of work. No work can begin until the plan is reviewed and approved by the DPW-EMD Asbestos/Lead Specialist.

Asbestos Abatement Plans must include, but are not limited to the following elements:

Location, quantity, and description of how abatement is to be performed.

Schedule the Contractor will use to comply with notification deadlines, requirements.

Contractor’s and Sub-contractor's current licensing, certifications, fit test, safety requirements and air sampling documentation.

The DPW-EMD approved third-party contractor who will be conducting the environmental sampling and monitoring should be onsite at all times during the duration of abatement procedures.

Drawings which include the locations of units on-site such as negative air machines, decontamination units, and waste dumpsters.

Landfill Certifications As soon as practicable, the Contractor will submit final air clearance results to the KO for forwarding to the DPW-EMD. Upon review and approval of final air clearance results, the DPW-EMD will notify the COR that the final sample results meet the applicable performance standards. This approval will then be forwarded to the Contractor that USAG Fort Lee has accepted the results. This formal communication must occur prior to containment teardown to allow area re-occupancy. Breakdown of containment features prior to receiving approval of final air clearance results originating

This document is subject to change at any time. It is the user’s responsibility to be aware of updates and/or additions.

from the DPW-EMD may result in the re-establishment of the containment at the cost to the contractor.

Asbestos Awareness Training Requirements

The Contractor will adhere to the following requirements for individuals who are in contact but not removing ACM.

The Contractor shall provide, at no cost to the Government, for those Contractor employees who may perform housekeeping operations in an area which contains ACM or Presumed Asbestos Containing Material (PACM), an asbestos awareness training course.

The training shall be as needed but no less than once per year and consist of a minimum 30-45 minute awareness training course; and

The training course shall, at a minimum, contain the following elements:

Health effects of asbestos.

Locations of ACM and PACM in the building/facility.

Recognition of ACM and PACM damage and deterioration.

Requirements in this standard relating to housekeeping.

Proper response to fiber release episodes.

Asbestos Abatement or Removal Notification If the project requires the removal of ACM, the Contractor is responsible for the proper disposal of asbestos waste and debris. The Contractor is subject to Occupational Safety and Health Administration (OSHA), EPA and Commonwealth of Virginia compliance and inspections before, during and after asbestos abatement. The Contractor must perform asbestos removal work in accordance with these specifications and EPA’s National Emissions Standards for Hazardous Air Pollutants for asbestos, and any subsequent updates thereto.

Notifications are required to be submitted to state and EPA Region 3 notifications at least 20 days prior to starting any asbestos abatement or removal. A copy of the notification shall be submitted to the KO and DPW-EMD Asbestos/Lead Specialist.

Asbestos Manifests

If the project requires asbestos removal, all asbestos waste manifests shall be signed by the DPW-EMD prior to the removal of such waste from USAG Fort Lee. A copy of the completed manifest (signed by the receiving landfill) shall be submitted to the DPW-EMD within 10 days of removal of the waste from the Installation.

For questions about Asbestos or Lead please contact the Fort Lee

Air Quality Specialist at:

804-734-5123 https://www.epa.gov/asbestos/asbestos-neshap https://www.epa.gov/asbestos/asbestos-neshap

This document is subject to change at any time. It is the user’s responsibility to be aware of updates and/or additions.

Lead

USAG Fort Lee assumes that all buildings built prior to 1978 contain lead, but buildings built after this date may also have such elements. While lead is known to exist in certain locations based on the age of the building, there have been cases where lead not previously known to exist is exposed. If lead is found during any phase of a project, the Contractor shall immediately cease work in the affected area and notify the KO and

DPW-EMD.

USAG Fort Lee complies with all regulations involving lead disturbance that include but not limited to renovation, abatement, and disposal and requires contractors to submit a Lead Disturbance/Abatement Plan if there is the possibility of lead to exist, or if there are current surveys that indicate its presence.

The Contractor will submit the Lead Disturbance/Abatement Plan, revisions, and all other associated documentation requested by the DPW-EMD to the COR and the Installation Asbestos/Lead Specialist prior to the initiation of work. No work can begin until the plan is reviewed and approved by the DPW-EMD Asbestos/Lead Specialist.

If the project requires lead disturbance, renovation, removal, or abatement, the Contractor will submit work plans to include, but not limited to, the following elements:

Location, quantity, and description of how abatement is to be performed.

Schedule the Contractor will use to comply with notification deadlines, requirements.

Contractor and Subcontractor current licensing, certifications, fit test, safety requirements and air sampling documentation.

The DPW-EMD approved third-party contractor who will be conducting the environmental and clearance sampling. A project monitor will be onsite at all times during the duration of abatement procedures.

Drawings which include the locations of units on-site such as negative air machines, decontamination units, and waste dumpsters.

Lead Training Awareness Requirements

The Contractor will adhere to the following requirements for individuals who may be in contact with but not removing lead-containing material.

The Contractor shall provide, at no cost to the Government, a lead awareness training course to all workers.

The training shall be as needed but no less than once per year and consist of a minimum 30-45 minute lead awareness training course; and

The training course shall, at a minimum, contain the following elements:

Identify activities covered by the OSHA lead standards.

This document is subject to change at any time. It is the user’s responsibility to be aware of updates and/or additions.

Recognize the dangers of lead exposure and the features of a medical surveillance program.

Recognize the purpose of and the elements of an exposure control plan.

Recognize requirements of the Construction Lead Standard.

Recognize the importance of respiratory protection, proper hygiene and housekeeping procedures.

Identify key features of a medical removal program.

Lead Clearance and Re-occupancy As soon as practicable, Contractor will submit final wipe sample results to the KO for forwarding to the DPW-EMD. Upon review of final wipe sample results, the DPW-EMD will notify the COR whereupon the Contractor will receive formal communication originated by DPW-EMD that sample results meet the applicable performance standards prior to containment teardown for work area re-occupancy.

Lead Disposal Lead waste and lead contaminated debris must be sampled to determine the quantitative level of lead. This may be determined by using lead totals. However, if sampled totals exceed 20 times the Toxic Characteristic Leaching Procedure (TCLP) limit, then a TCLP must be performed. The DPW-EMD will inform the Contractor on management procedures. If wastes are determined to be hazardous by TCLP, the containers cannot leave the installation until a completed manifest is reviewed and signed by the DPW-EMD. If the Contractor knows that the quantity of hazardous waste generated will be less than 55 gallons, he/she must arrange to have that material removed from the installation within 72 hours of generation. If this cannot be accomplished, the Contractor must contact the Hazardous Waste Manager to arrange storage of full drums of lead-contaminated waste at the USAG Fort Lee hazardous waste facility site for no more than 90 days. The drums must be in good condition, labeled properly and tightly sealed. Storage of Contractor’s containers will only be provided on an emergency basis.