Attch_6_AF_Form_813_Environmental_Comment_Form.pdf

30 CES/CEIE ENVIRONMENTAL COMMENT FORM

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DOCUMENT AUTHOR: 30 CEI Staff DOCUMENT TITLE: 813-17-032

COMMENTOR: Multiple DATE OF COMMENTS:

ITEM

NO.

STAFF COMMENT

1 (Cultural) 2017 07 18 – Section 106 complete. No adverse effect to historic properties. Archaeological and Native American monitoring is required for all initial ground disturbing project-related activity within the boundary of the archaeological sites. Coordinate with

(CEIEA Cultural, ) at least 1-week in advance of start of fieldwork to arrange for NA and archaeo monitors…or earlier…and to participate in project kickoff meeting/ initial tailgate safety meeting/ or some other equivalent meeting. Will we see an EPP/103 for this? If yes, please designate staging and storage areas in the EPP/103. If not, and especially if staging and storage areas are off pavement, coordinate with on location. [cdr]

2 (Natural) Provide standard trenching remarks. No additional NR concerns.

3 (Clean Water Act – 401/404) No 401/404 or TE plant issues. Add Weed seed cleaning comments.

4 (Air) Replacement generators must comply with Federal and State emissions requirements. Generator selection must be approved by VAFB air quality manager prior to procurement. Additionally, AFCEC must approve the design before installation can occur, contact Power Pro for guidance. An authority to construct issued by Santa Barbara County Air Pollution Control District is required before installation can occur. It can take up to 8-months to obtain an authority to construct permit, please plan accordingly. Contact me ASAP to begin the permitting process.

5 (Clean Water Act – 402)

- Sediment control measures shall be taken to prevent soil from discharging to the drainage along the north side of the road.

- If the trenching is within the road shoulder vegetation would not need to be re-established for erosion control. If not, vegetation will need to be re-established via the Environmental specs (Sec 01 57 20, 3.17). (Both conditions per comments on the 85% design, confirmed added to the 95% design General Notes on sheet E-101, expanded above to include additional drainage area).

- Prepare (loosen, amend) soil prior to seeding. A minimum of 3,000 lbs per acre of wood fiber or straw mulch or 0.25” to protect seed is recommended. The seed mix shall be approved by the base botanist.

- Biodegradable straw wattles (no plastic netting) may be needed for sediment and erosion control.

- Use BMPs to prevent concrete or curing compound from entering storm water runoff.

- Perform washout of concrete trucks off-base or washout wastes into a properly constructed temporary pit where the concrete can set, be broken up and properly disposed of.

- This project is exempt from coverage under the State NPDES Construction General Permit since it meets the Permit’s definition of Projects and Activities Not Defined as Construction Activity under Attachment A.2.

6 (Drinking Water/Wastewater)

Any activity requiring the connection to and the drawing of bulk water from the drinking water distribution system to support construction and repair projects shall require the approval and coordination of the Vandenberg Cross Connection Control and Backflow Prevention Program Manager, , 30 CES/CEOIU, .

FA4610-17-R-0016 Attachment 6

1169237200C Typewritten Text 28 Feb 2017

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ITEM

NO.

STAFF COMMENT

7 (Greenhouse gases/Ozone Depleting Substances/Tanks/Asbestos/LBP)

Tanks: Aboveground tanks and containers 55 gallons or greater are regulated by the Air Force, federal and state governments and must be added to the SPCC Plan. All tanks, drums, and containers must be doubled-walled or constructed with secondary containment with at least 110 percent of the total capacity. If piping is required to connect the fuel tank to the generator, then an antisiphon valve will be required as part of the installation. All new installations and removals will require an AF IMT 103 to document the action IAW 40 CFR 112, Spill Prevention, Control, and Countermeasure requirements. Please contact 30 CES/CEIEC Tank Manager at for questions.

Asbestos: The AF IMT 813 indicates that a wall in Bldg 23215 must be penetrated to facilitate the removal of the old generators, this action requires a detailed review for impact on asbestos containing materials and demolition permit requirements. Asbestos disturbance and demolition work orders and projects are regulated by 40 CFR 61 the National Emission Standards for Hazardous Materials (NESHAP) and the Santa Barbara Air Pollution Control District (SBAPCD). Other regulations that affect projects are OSHA and Cal-OSHA asbestos standards in 29 CFR Parts 1910, 8 CCR, 29 CFR 1926, and 40 CFR 763 for asbestos materials in schools and banned asbestos. Under NESHAP and SBAPCD, prior to commencement of a renovation or demolition project, the area shall thoroughly be inspected for the presence of asbestos. Also prior to project start, all regulatory notifications and abatement plans must be reviewed by 30 CES/CEIEC. You must also provide 30 CES/CEIEC a copy of the approved SBAPCD Notification for Renovation and Demolition form ENF-28. Please contact 30 CES/CEIEC at for questions.

8 (Hazardous Materials)

No comment.

9 (Hazardous and Solid Waste)

Construction/Demolition contractor shall provide disposal and recycling tonnages to 30 CES/CEI. Copies of weight-tickets are sufficient. Contact .

10 (Installation Restoration Program/Military Munitions Response Program)

No IRP/MMRP concerns.

11 (Coastal Zone Resources)

The proponent for this action is responsible for implementing all applicable management requirements identified in the referenced Environmental comments attached. If the proponent is unable to accommodate these requirements, the proposed action will require additional environmental analysis and this CATEX will not apply.

FA4610-17-R-0016 Attachment 6

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Standard Comments, Natural Resources Trenches and Pits

Animals including (but not limited to) the California red-legged frog are protected by the U.S. Endangered Species Act of 1973 (as amended). “Harm” or “harassment” to these species is a violation of Federal law.

Trenches and pits must be maintained at the end of each work day to prevent wildlife from falling in; three options

• Filled in at end of day

• Covered upon completion of work each day.

• Dig or install “ramps” every 50 feet (a sloped cut or board or stick placed to allow animals to climb out)

In areas specifically identified by 30 CES/CEIEA as likely or known occupancy of threatened or endangered species, a biological monitor may be required. Monitor may or may not require pre-approval by 30 CES/CEI and/or the U.S. Fish and Wildlife Service, potentially including possession of a current section 10(a)(1)(A) recovery permit.

30 CES/CEIEA Natural Resources

Contractor Equipment/Vehicles:

Equipment vehicles (dozers, mowers etc.) shall be cleaned of weed seeds prior to use in the project area to prevent the introduction of weeds. Prior to site transport, any skid plates shall be removed and cleaned. Equipment should be cleaned of weed seeds daily especially wheels, undercarriages, and bumpers. Prior to leaving the project area, for vehicles that have caked-on dirt or mud, vehicles shall be cleaned with hand tools such as bristle brushes and brooms at a designated exit area; vehicles may subsequently be washed at the AAFES car wash or approved wash area. For vehicles with dry dusted dirt on vehicles (and no caked-on dirt or mud), prior to leaving a site at a designated exit area, equipment vehicles shall be thoroughly brushed; vehicles may alternatively be air blasted on site.

Air Quality Comments General Construction Activities

1. Any portable equipment powered by an internal combustion engine with a rated horsepower of 50 bhp or greater used for this project must be registered in the California State-wide Portable Equipment Registration Program or have a valid Santa Barbara County Air Pollution Control District Permit to Operate. Examples of such equipment are portable generators, compressors and light-carts.

Copies of each registration or permit along with fuel usage and hours of operation must be submitted to the 30 CES/CEIEC Air Quality section at the end of the project or by 15 January, whichever occurs first.

2. Off-road construction equipment must be compliant with all Federal, State and local regulations. A description of each piece of equipment to include make, model, serial number and rated brake- horsepower along with fuel usage and hours of operation must be provided to the 30 CES/CEIEC Air Quality section at the end of the project or by 15 January, whichever occurs first.

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3. The following Santa Barbara County APCD Rules apply (copies of these rules can be obtained at www.sbcapcd.org or by contacting the 30 CES/CEIEC Air Quality Section):

201. Permits Required (contact 30 CES/CEIEC Air Quality Section to determine applicability)

302. Visible Emissions;

303. Nuisance;

304. Particulate Matter Northern Zone;

306. Dust and Fumes Northern Zone

311. Sulfur Content of Fuels

317. Organic Solvents

321. Solvent Cleaning Operations

323.1. Architectural Coatings

324. Disposal and Evaporation of Solvents

329. Cutback and Emulsified Asphalt Paving Materials

345. Control of Fugitive Dust from Construction and Demolition Activities

353. Adhesives and Sealants

4. Contractor must be enrolled in the Hazardous Material Pharmacy and all hazardous materials must be barcoded. Hazardous materials include paints, coatings, adhesives, sealants, solvents, asphalt, etc.

5. Abrasive blast materials must be certified by the California Air Resources Board. Total amount of abrasive material used must be submitted to the 30 CES/CEIEC Air Quality Section at the end of the project or by 15 January, whichever occurs first.

http://www.sbcapcd.org/

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1. STATIONARY DIESEL-FIRED GENERATORS:

a. CONTACT 30 CES/CEANQ, AIR QUALITY SECTION AT 805-606-6863 PRIOR TO PURCHASING STATIONARY DIESEL EMERGENCY GENERATORS.

INSTALLATION OF A DIESEL-FIRED EMERGENCY BACK-UP GENERATOR WITHOUT THE REQUIRED AUTHORITY TO CONSTRUCT (ATC) FROM THE SANTA BARBARA COUNTY AIR POLLUTION CONTROL DISTRICT (APCD) WILL RESULT IN A NOTICE OF VIOLATION (NOV). A PERMIT FROM THE

APCD CAN TAKE UP TO 210 DAYS TO OBTAIN.

b. The APCD requires permits to operate (PTO) for diesel-fired emergency back-up generators greater than 50 bhp. An ATC must be obtained from the APCD prior to installation.

c. Diesel generators must meet the requirements of APCD Rule 333 , and the pollutant emissions standards in the California Air Resources Board Diesel Air Toxic Control Measure as listed in the table below:

2. STATIONARY GASOLINE/PROPANE-FIRED GENERATORS:

a. Gasoline and Propane fired emergency back-up generators are exempt from permit conditions pursuant to APCD Rule 202 provided they do not exceed 200-hours of operation annually. If hours of operation will exceed 200-hours annually, a permit to operate will be required and must be obtained prior to exceeding the 200-hour limit. Operations in excess of 200-hours annually without the required PTO will result in an NOV.

Maximum Engine Power Model year(s) PM NMHC+NOx CO

50 . HP < 75 2007 5.6 (7.5)

(37 . kW < 56) 2008+ 3.5 (4.7)

75 ≤ HP < 100 2007 5.6 (7.5)

(56 ≤ kW < 75) 2008+ 3.5 (4.7)

100 ≤ HP < 175 2007

(75 ≤ KW < 130) 2008+

175 ≤ HP < 300 2007

(130 ≤ kW < 225) 2008+

300 ≤ HP < 600 2007

(225 ≤ kW < 450) 2008+

600 ≤ HP < 750 2007

(450 ≤ kW < 560) 2008+

HP > 750 2007

(kW > 560) 2008+

2.6 (3.5)

2.6 (3.5)

2.6 (3.5)

0.15 (0.20)

0.15 (0.20)

3.0 (4.0)

3.0 (4.0)

3.0 (4.0)

3.0 (4.0)

4.8 (6.4)

Table 1: Emission Standards for New Stationary Emergency Standby Diesel-Fueled CI Engines g/bhp-hr (g/kW-hr)

0.15 (0.20)

0.15 (0.20)

0.15 (0.20)

0.15 (0.20)

0.15 (0.20)

3.7 (5.0)

3.7 (5.0)

3.7 (5.0)

2.6 (3.5)

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3. ALL GENERATORS:

a. In accordance with 30 SWI 32-702, a Source Profiling Form (30 SW Form 156) must be provided to the environmental flight upon installation of the unit in order to enter the generator in the Base air emissions inventory database.

b. Recordkeeping and Reporting will be required by APCD Permit Conditions and by 30 SWI 32-702.