Attachment 11 - Environmental Protection Plan -- 20240514.pdf

ENVIRONMENTAL PROTECTION PLAN

Submitted by

Contractor Name

Project Title (project name) Contract #:

Plan Author (print name): Date:

Project Location (Nearest Building or Street/Runway):

This document is for reference only.

Please ensure that the data you fill in your EPP is reflective of your project. Do not copy and paste examples unless you know for sure it is relevant to your project. Some examples are much larger then is needed. We put in more than enough examples so that you can see all of the options and information we are looking for.

Black font is what exists in the document and should not be changed Red font is directions (delete when final)

Grey font are examples (delete when final)

Attachment 11 to FA466425R0001

ENVIRONMENTAL PROTECTION PLAN 2024

Table of Contents

1. Introduction

1.1 Project Description

2. Personnel Duties

3. Procedures

4. Communications and Training

5. Contact Information

6. General Site Information

6.1 Drawings

6.2 Work Area

6.3 Documentation

7 Management of Natural Resources

7.1 Natural Resources Habitats

7.2 Natural Resources Priority Species (Federal and State listed)

7.3 Other Natural Resources of Concern

7.4 Tree protection

8. Protection of Historical and Archaeological Resources

9. Stormwater Management and Control

10. Protection of the Environment from Waste Derived from Project

11. Solid nonhazardous Waste:

12. Recycling and Waste Minimization Plan

13. Hazardous Waste

13.1 Hazardous Waste Management Procedures

13.2 Identification

13.3 Sampling/Analysis Documentation

13.4 Accumulation and Storage

13.5 Satellite Accumulation

13.6 Transportation

13.6 Recyclable Hazardous Materials

13.7 Used Oil Management Procedures

13.8 Hazardous Waste Permitted Facilities

14. Hazardous Material

14.1 Storage of hazardous materials

14.2 On-site fueling sources

14.3 AST Information

14.4 Releases to the Environment

14.5 Notifications on Base

15. Spill Control Plan

15.1 Reporting of Spills

15.2 Response to a Spill

15.3 Materials and Equipment

16. Regulatory Notification and Permits

17. Clean Air Act Compliance

17.1 Haul Route

17.2 Pollution Generating Equipment

17.3 Stationary Internal Combustion Engines

17.4 Refrigerants

17.5 Air Pollution-Engineering Processes

17.6 Compliant Materials

18. Wastewater Management Plan

19. Signatures

1. Introduction:

The purpose of the Environmental Protection Plan (EPP) is to provide a comprehensive review of known or potential environmental issues which may be encountered by the Construction Team during project construction as well as preventative measures associated with those issues. This EPP provides Contract

Name’s procedures, agreements and information required by “The Environmental Protection Guide

Specifications (EPGS), March ARB, based on the Unified Facility Guide Specification Division 01 -

Existing Conditions Section 01 57 19, prepared by 452 Mission Support Group, Base Civil Engineer

Squadron (BOS), Environmental Flight (CEV).

The EPGS provides:

• List of applicable laws, regulations and guidance;

• Order of preference for references,

• Definitions of terms applicable to environmental compliance,

• Submittals which may be required by a contractor performing work at March ARB;

• Environmental requirements of a contractor performing work at March ARB,

• Minimal contents of an EPP, and

• A discussion of execution requirements related to environmental protection when performing work at March ARB.

The information discussed and presented in the EPGS is not repeated in this EPP, but, is included by reference.

The EPP is submitted to March ARB, 452 MSG/CEV, in accordance with the above contract and the processes and procedures outlined become required under the contract by this submittal.

1.1 Project Description

(Provide a short description of the project, usually found in the general introduction to the contract

Statement of Work)

(Insert or attach an Aerial Photo of the Project Location)

Contract Name shall be responsible for compliance with applicable federal, state, and local environment laws and regulation. The information contained herein shall be supplemented, as needed, with additional information (i.e. plans, specifications, procedural information, etc.) by Contract Name. Such information shall be submitted to 452 MSG/CEV for approval before being included in the EPP, as applicable.

2. Personnel Duties

Provided below are the names, duties and level of authority assigned to the person(s) on the job site who oversee environmental compliance:

Project Superintendent

Duties: A construction superintendent oversees the operations of a construction site, from planning to completion. The duties of a construction superintendent will vary, however, they can expect to be responsible for daily scheduling, supervising all activities and tasks, and ensuring the safety and compliance of the site.

Level of Authority: full level

Name: Joe Smith

Phone: 951-555-1212

Email:

Environmental Related Certifications: OSHA 30, Lead Renovator, Asbestos Renovator

Project Manager

Duties: The Project Manager manages key client projects. Project management responsibilities include the coordination and completion of projects on time within budget and within scope. Oversees all aspects of projects. Sets deadlines, assign responsibilities, monitors and summarizes progress of project. Prepare reports for upper management regarding status of project; work directly with clients to ensure deliverables fall within the applicable scope and budget.

Level of Authority: full level

Name: Joe Promag

Phone: 951-555-1212

Email:

Environmental Related Certifications:

Environmental Manager

Duties: Create, implement and maintain programs and procedures to facilitate a safer environment; train or direct employees to follow those procedures; survey work site to make sure everything's operating normally and file reports on what they find; prepare other types of paperwork, such as accident reports;

perform administrative tasks as necessary; retains the authority to stop, redirect work in order to correct non-conformities, acts as liaisons between the company and government agencies.

Level of Authority: Limited to Environmental Compliance Policy Enforcement / Advisement / Reporting

Name:

Phone:

Environmental Related Certifications:

Spill cleanup

Duties: Environmental Remediation finds and removes various pollutants from soil and water with the objective to redevelop these polluted sites or restore them to their natural states.

Level of Authority: Limited, Under the Direction of the Environmental Manager / Superintendent Name:

Joe cleanup

Phone:

Email:

Environmental Related Certifications: Lead Renovator Certification Initial

Training personnel on spill response procedures

Duties: Prepare Site Specific Spill Response Procedures and analysis to ensure assigned personnel are aware of criteria that comprises a spill, containment, notification and reporting procedures, as well as the proper use of spill response material IAW installation /state / federal regulations and industry practices.

Level of Authority: Administrative/Instructional/Supervisory

Name:

Phone:

Environmental Related Certifications: Lead Renovator Certification Initial

Manifest Preparation of hazardous waste to be removed from the site (if applicable)

Duties: Manifest hazardous waste and ensure hazardous material is identified / marked and stored properly prior to, during, and after removal. Prepare manifest for Installation Hazardous Waste Manager to inspect and sign when waste is ready to leave base.

Level of Authority: Administrative/Instructional/Supervisor Name:

Phone:

Email:

Environmental Related Certifications: Lead Renovator Certification Initial

(If positions are not valid, then delete these otherwise fill in)

Training the Contractor's environmental protection personnel.

Duties:

Level of Authority:

Name:

Phone:

Environmental Related Certifications:

California Qualified Storm Water Erosion and Control Manager Duties:

Level of Authority:

Name:

Phone:

Email:

Environmental Related Certifications:

3. Procedures

Discussed below, are (Contractor Name)’s procedures which will meet environmental compliance requirements of March ARB and addresses methods, procedures, and practices pertaining to air quality emissions, ozone depleting substances (ODS), greenhouse gases (GHG), water quality standards, waste water permit requirements, storm water effluent and containment, cultural resources and natural resource protection, storage tanks and applicable laws pertaining to construction and materials, hazardous waste management, hazardous materials management, spill/release management, recycled/recovered materials and use, solid waste and construction debris management, PCBs, lead-based paint and asbestos management as applicable to the above described project. Also included in this

EPP is a listing of all Contractor combustion source equipment with appropriate California Air

Resource Board registration and permits as applicable to this contract.

Executive Order (EO) 13423, Strengthening Federal Environmental, Energy, and Transportation

Management, requires that the AF establish and maintain an Environmental Management System (EMS).

The EMS shall conform to the International Organization for Standardization (ISO) 14001 Standard, Environmental Management Systems – Requirements and shall follow guidance for use, in Federal and

Department of Defense (DoD) guidelines. The AF outlines its process to follow ISO 14001 and these guidelines in Air Force Instruction 32-7001. The EMS is the framework for continual program and process improvement through clearly defined environmental roles and responsibilities, planning requirements, budgeting, effective implementation and operation, and management review. The EPGS ensures that contractors meet the requirements of AFI 32-7001 in their procedures and practices.

By submission of this EPP, contractor states that its procedures and practices comply with Air Force

Instruction 32-7001, Environmental Management, and the environmental management system described therein.

Provided below are copies of standard or project-specific operating procedures that will be used to effectively manage and protect the environment on the project site, consistent with the Air Force EMS.

Name Procedure (Attach copy or provide description of each):

Spill Prevention and Response (Attachment x). Describes management of all potential spills

Construction Waste Management Plan (Appendix x). Describes management of all Waste derived from the project

Lead Abatement Plan (Attachment x). Describes the complete plan for Lead abatement

Solid Waste Management Plan (Appendix x). Describes management of all solid waste derived from the project

4. Communications and Training

The following are the communication and training procedures that will be used to convey environmental management requirements to Contractor employees and subcontractors. Construction environmental protection personnel shall be properly trained in all applicable aspects of environmental protection and pollution control by the individual listed in 2 above. Environmental protection and pollution control meetings shall be conducted prior to and routinely during construction to ensure specific anticipated environmental issues are addressed throughout the course of the project and to ensure new personnel are properly trained should site conditions change. Examples of training subjects to be addressed include, but are not limited to, the following:

• The contents of the EPP;

• Pollution detection and avoidance

• Pollution and spill control standards

• Applicable pollution control laws and regulations;

• Installation and maintenance of environmental controls and monitoring devices

• Anticipated hazardous or toxic wastes and chemicals at the construction site and proper handling, storage and containment protocols associated with those and other regulated substances including

SDS sheets and location

• Physical hazard recognition and avoidance

• First aid station and material location at the construction site

• Recognition of archaeological sites and artifacts as well as proper protocols should these items be inadvertently discovered during construction

• Recognition and protection of Resource Protection Areas (if applicable)

• Recognition and protection of threatened or endangered species and their habitat now or likely to be located in the project area

• Worker safety detailed in the OSHA Construction Resource Manual (29 CFR 1903, 1904, 1910, and 1926)

• U.S. Army Corps of Engineers Safety and Health Requirements Manual, EM 385-1-1.

• Supplemental training appropriate for an individual worker’s responsibilities (i.e.

OSHA HAZWOPER)

• The effects of products expected to be utilized at the site to human health and the environment;

• The responsibility of each person to prevent and contain spills;

• Specific precautions for each area of operation including proper chemical storage, handling and labeling;

• Proper operation and maintenance of associated equipment;

• Proper use of Personal Protective Equipment (PPE);

• Potential spill area contaminant migration routes at the site;

• Initial spill response procedures and location and proper use of spill control equipment; and

• Appropriate spill notification procedures and channels.

(Company Name) shall inform and train employees in the hazard notification standards stipulated in the

OSHA Hazard Communication Standard 29 CFR 1910.1200. This standard provides employees the right to notify of the potentially hazardous conditions and/or chemicals which may be present at a job site.

Additionally, the standard includes provisions for informing employees about protective measures to prevent adverse effects from occurring. Effectively communicating the potential work-site hazards to site personnel will help minimize harmful workplace incidents.

Personnel with the potential to respond to releases of hazardous materials are required to be trained in accordance with a 40-Hour OSHA HAZWOPER Certification course. Additionally, a minimum of one (1) individual at the site should have completed the 8-Hour OSHA HAZWOPER supervisor training course.

Emergency response personnel are also required to be trained in the First Responder Operations Level specified in 29 CFR 1910.120 (g)(6)(ii).

(Provide further specific information).

5. Contact Information

Below are emergency Contract and Government contact information (office phone number, cell phone number, and e-mail address).

ABC President (Off Site)

John Pres

Cell: (951) 555-1212

Email: John.Pres@fake address.com

ABC Project Manager / Superintendent (On Site)

Dan Proj

Email: Dan.Proj@fake address.com

Sunrise Painting

Mike painter

Email: Mike.painter@painting.com

Government COR (On Site)

Kevin Engineer

Office: (951) 555-1212

6. General Site Information

6.1 Drawings

Below are Drawings showing locations of proposed temporary excavations or embankments for haul roads, material storage areas, structures, sanitary facilities, storm drains and conveyances, and stockpiles of excess soil. (Copies of contract drawings must be legible as a pdf drawing and may be attached. Identify what drawings are attached)

Diagram 1 Below is the drawings for the building. (example) mailto:Mike.painter@painting.com

Below is the map of the work area including haul route, temp road, construction site and staging areas. This map is only an example

6.2 Work Area

Below is provided the project work area plan showing the proposed activity in each portion of the area and identifying the areas of limited use or nonuse. Included are measures for marking the limits of use areas, including methods for protection of features to be preserved within authorized work areas and methods to control runoff and to contain materials on site, and a traffic control plan. (copies of contract drawings must be legible as a pdf drawing and may be attached. Identify what drawings are attached)

Explain below the areas of this specific project facility/building which are approved or will be utilized for construction activities. This map is only an example

(Insert Work Area Plan Here or attached Attachment Number)

6.3 Documentation

Provided below is a letter signed by an officer of the firm appointing the Environmental Manager and stating that person is responsible for managing and implementing the Environmental Program as described in this contract. Included in this letter is the Environmental Manager's authority to direct the removal and replacement of non-conforming work.

(Insert Letter Here or attach Attachment Number)

7 Management of Natural Resources

Are there any known natural resources associated with this project? Contractor must schedule a meeting with CEV in order to determine resources affected by the project. Have EPP mostly done and questions ready.

(Contractor Name) shall minimize disturbance to biological resources outside the approved footprint of disturbance. Examples of biological resources include fish, wildlife, and plants and trees, including their habitat and disturbance of these resources are to be limited by remaining within the Work Area Limits approved by March ARB CEV. Inadvertent destruction or degradation of adjacent areas outside the approved Work Area Limit shall be remedied as soon as practicable by restoring the site to its original condition. Protective fencing shall be utilized around trees and shrubs that are designated to remain on- site after construction, if applicable. Damage caused to preserved trees should be documented and repaired and/or restoration plans shall be approved by the customer prior to implementation. Finally, appropriate measures shall be implemented to prevent the migration of sediment and fugitive dust from the construction site to protect off-site terrestrial and aquatic biological resources. Special care should be taken with work around storm drains, culverts, swales or other drainage features which may discharge to surface waters. Should natural resources be encountered during construction, (Contractor Name) shall cease operation and contact the customer immediately. A description of the situation and/or resource encountered shall be provided and guidance obtained to resume construction activities.

7.1 Natural Resources Habitats

Describe any land resources (habitat, vegetation, or other resources) in the project area that are of concern and how they will be protected. (Insert map as needed). –If you do not know the answer, NRM can speak to this when CEV meets with contractor for Pre-con or during review of the EPP. They can directly give you the wording required here.

Example 1.

‘There are no natural resources land or within the project area”

Example 2.

The project proposed ground disturbing activity at or near natural resources habitat. However, biological surveys have been done and there is currently no species or habitat that will be affected by this project.

Example 3.

The project proposed ground disturbing activity at or near natural resources habitat. All project operations will avoid and protect these habitats with mitigations that include;

• No vehicles on field during wet season to avoid vernal pools

• No digging near protected buffered area to avoid burrowing owls

• Contact NRM if suspected habitat is located during operations

7.2 Natural Resources Priority Species (Federal and State listed)

Example 1

There are no priority species either federally listed or state listed species within the project area

Example 2

Known Burrowing owls are currently occupying areas close to project area. No ground disturbance will occur within the established buffered habitat. If these species show up closer to the project site then NRM will be contacted for further direction and protective measures.

Example 2.

Surveys and report was completed. The project area has been known as Burrowing owl habitat but only one active burrow was documented during surveys. This site with recommendation of 100 feet avoidance area plus seasonal restriction will be avoided and work will begin within the recommended seasonal restriction.

7.3 Other Natural Resources of Concern

Hangers are known to have frequent birds hang out. In the event that there are wildlife within or without the hanger hanging out, operations will avoid them or gently shoo them off. If a nest is found then NRM will be contacted to remove the nests or any other wildlife issues that need removal

Landscaping features can often harbor several species grazing on grub or seed. All such wildlife will be avoided or gently shoo’d off. If wildlife persist and may affect project operations then NRM will be contacted to resolve the issue.

7.4 Tree protection

Describe any trees in the project area that are of concern and how they will be protected. (Insert map as needed.)

Example 1

The effects on landscaping is not expected. Most will be covered with light fabric to prevent paint overspray from accumulating and harming the vegetation. If in the process of the project damage occurs, then replacements of landscape will be the responsibility of the ABC Contracting

There are no trees within the project area.

Example 3

There are a few trees on the road where excavation will occur. These trees will be avoided and protected from any damage. . If in the process of the project damage occurs, then replacements of landscape will be the responsibility of the ABC Contracting

7.5 Replacement of damaged landscape features

Describe procedures for resolving damaged landscape. (Insert map as needed.)

Example1.

There is no landscaping within the project area that will be effect by this project.

“The effects or damage on landscaping is not expected. Most will be covered with light fabric to prevent overspray from accumulating and harming the vegetation. If in the process of the project damage occurs, then replacements of landscape will be the responsibility of the (insert contractor name)

8. Protection of Historical and Archaeological Resources

Meeting with CEV- Are there any known historical, archaeological or cultural (HAC) resources associated with this project that have been identified by CEV? (List the known resources)

Example 1 This project is not within the historic district and will not affect any historic feature both physically and visually.

"This project is within the Historic District and the building itself is on the national registry of historic places. All precautions will be in place to prevent any damage to historic features of the building

Example 3

This project is the direct line of site to the Historic District. SHPO consultation has been completed and the mitigations to this protect are as follows;

• Building will match the historic element and feel of the historic district. Added elements include tile roof, matching paint and additional artistic doors and trim that will blend this building in historically.

In the event of an inadvertent discovery of previously undocumented HAC resources, (Contractor Name) will immediately cease construction operations and notify CEV within 24 hours of the discovery.

Potential HAC resources which would cause cessation of work include any human skeletal remains or burial, artifacts (i.e. ceramics, pottery, tools, etc.), shell, midden, bone, charcoal or other deposits rock or coral alignments, pavings, walls or other constructed features and any other indication of previous agricultural or other human activities. Until CEV has decided on the historical or cultural significance of the inadvertently discovered resources, (Contractor Name) shall effectively secure the area in a manner that prevents employees or other persons from trespassing on, removing or otherwise disturbing such resources. Failure to follow these procedures could result in fines and penalties under 36 CFR 800.

Any work on historic structures or the associated grounds must comply with the Secretary of The Interior's

'Standards for the Treatment of Historic Properties,' AFI 32- 7065, Cultural Resources Management, as well as State and installation guidance, March ARB Integrated Cultural Resources Management Plan

(ICRIMP), the “Programmatic Agreement Among the Air Force Reserve, the Advisory Council on

Historic Preservation, and the California State Historic Preservation Officer Regarding Routine

Maintenance of Historic Properties Within the March Air Reserve Base Historic District, Riverside

County, California”, “Programmatic Agreement Between the United States Department of the Air Force and the California State Historic Preservation Officer for the Disposal of Portions of March Air Force

Base, California” and the “Maintenance Manual for the March Field Historic District”.

Person responsible for ensuring compliance with above and objectives, procedures and methods to ensure compliance are provided below:

Program Manager, Joe Promag, 951-555-1212

CEV Cultural Resources Manager, Chris Wagner 951-655-3653

9. Stormwater Management and Control

The (Contractor Name) shall comply with, but not be limited to compliance of: The Clean Water Act, State of California Water Resources Control Board National Pollutant Discharge Elimination System

(NPDES) General Permits; March ARB Storm Water Pollution Prevention Plan (SWPPP), March ARB

Spill Prevention Control and Countermeasure Plan (SPCC).

452 MSG/CEV requires all construction on March ARB that will disturb the paved or unpaved areas of

March ARB to include use of March ARB roadways to haul dirt or other construction materials or paved surfaces to store materials to have a Storm Water Control Certificate signed by a person responsible for the preparation of the certificate. Depending upon the area disturbed, this may need to be a certified person, as stated below. The Certificate must be approved by the Chief Environmental Flight or designated person, prior to any outside construction that disturbs any land or pavement area, to include demolition and construction of facilities. All repair, renovation, construction and service contracts must have the local

March ARB, Environmental Protection Specification (EPS), modified for that project and approved by 452

MSG/CEV, contained within the contract Statement of Work or Performance Work Statement and all contractors and sub-contractors must be required to meet the specification. Self-help or military performed projects must also meet the requirements of the EPS. These specifications require the contractor to adhere to the requirements of Federal, State, local and March rules and regulations.

This mandatory requirement is an effort to prevent violations of the Federal Clean Water Act, as amended, the California Porter Cologne Water Act as amended 2018, the California Storm Water Enforcement Act of 1998 contained within the Portage Cologne Water Act, local ordinances, and US Department of

Defense and US Air Force Instructions to include AFI 32-7041, WATER QUALITY COMPLIANCE.

Tenants and non-452 AMW units and contractors performing work for those units are responsible for any and all fines and penalties for noncompliance with environmental regulations.

Penalties, as established in the California law, begin at $5,000 for violations of not having a permit and

$1,000 for various requirements such as not filing an annual report, per day or deficiency.

To avoid the potential for a penalty or fine a Storm Water Control Certificate must be completed. This

Certificate will accompany the March form 103, Base Work/Dig Permit Application and be approved and signed before 452 MSG/CEV will concur on the form 103. A site plan [contained in the Erosion and

Sediment Control Plan (ESCP) or Storm Water Pollution Prevention Plan (SWPPP)] of the proposed project must be attached to the application. The plan must show nearby storm sewers and drains to which any dirt or debris might flow if unimpeded, locations of any digging required, to include depth, width and length of each dig, limits of any lay-down areas and haul roads used to move dirt or debris, a description of

Best Management Practices (BMP) (e.g. sand bag location at sewer drains.) to be used during the dig to prevent the flow of dirt and debris in the event of a rain from reaching the storm sewer system, and means of preventing dust from entering the air (e.g. wetting or covering the dirt piles, or vehicles, cleaning of wheels, etc.). A calculation of the total area to be disturbed to include any lay-down areas, roadways or access ways to be created, etc. must be provided to show the area of each separate dig area.

(Contractor Name) has completed and signed a March ARB Stormwater Erosion Control Certificate, required for any disturbance of soil or potential pollution of the storm water drainage system of March

ARB, providing the required calculations, maps and information as required. A copy is provided below or attached as attachment (Attachment number)

(If a project is greater than 1 acre and a Storm Water Pollution Prevention Plan is required to be filed with the State Water Board, a draft shall be attached): Otherwise discuss and list all BMP’s put in place to prevent the flow of dirt and debris in the event of a rain from reaching the storm sewer system, and means of preventing dust from entering the air.

Examples

• Sandbags will be placed along culvert and drainage into storm drain system when digging and any watering is released in order to avoid sediment flow into storm drain.

• All debris removed from exterior walls will have a plastic sheet on the ground to catch all waste debris

• Hepa vacuum will be used to suck up all dust and small debris produced from paint removal

• Temp road will be reinforced after project with bark dust in order to avoid sediment flow into storm drains

• Temp road will be rehabilitated with new native seed in order to stabilize the soil thus increasing the chance of sediment flow into storm drains

9.1 SURFACE AND GROUNDWATER

Is dewatering expected with this project? _______________________

Has this site been tested for concentrations of PFAS?______________

Where will the water go until project is completed?_______________

What facility will treat this waste? ____________________________

9.1.1 Cofferdams, Diversions, and Dewatering

Contractor (dischargers) with dewatering activities shall prepare a project specific dewatering plan for approval by the March ARB Environmental Office. Dischargers may be required to obtain an

NPDES permit for dewatering in accordance with the California State or Regional Water Board.

Dewatering discharges authorized by the general permit include mechanical pumping or syphoning of non-potable water from sources including: excavations, trenches, foundations, utility vaults, groundwater removal specifically related to the construction activities, and/or water collected in impoundments.

Dischargers shall comply with the dewatering discharge requirements, and the dewatering monitoring and reporting requirements for dewatering discharges. Dewatering discharges from construction projects with a footprint of one or more acre shall adhere to Attachment J of the

California Construction General Permit No. CAS000002. Dewatering discharges from vaults shall follow these requirements and best management practices/pollution prevention plan in the

California Utility General Permit No. CAG990002.

The general permit does not limit the State or Regional Water Boards’ authority to modify dewatering discharge requirements upon providing written notice to the Discharger, including but not limited to the following:

1. Adding constituents to be monitored;

2. Adding or modifying frequency of monitoring;

3. Adding or modifying sampling locations;

4. Requiring all or part of the discharge to be treated by an active treatment system (i.e. IAW

CGP, Attachment F) prior to discharge; and/or

5. Revoking authorization of dewatering dischargers under the General Permit and requiring the discharger to obtain a different NPDES permit coverage for dewatering discharges to waters of the United States.

Dewatering discharges that do not contain pollutants of concern at levels that pose a threat to water quality may be eligible for discharge to grade provided that the contractor’s dewatering plan submittal contains:

1. A complete profile of the discharge;

2. Narrative and graphic description of the project site location dewatering activities;

3. Equipment and procedures to dissipate energy, prevent erosion, monitor and to preclude discharge to surface water and drainage courses;

4. Coordination, and authorization from the Installation Environmental Office.

Permits and processes for dealing with Polyfluoroalkyl Substances (PFAS) in the environment (soil and water) continue to evolve in response to the EPA, changes in the 40CFR, and subsequent regulatory thresholds. The below information is the most current guidance as of the writing of this document. Drinking water treatment standards may not be directly applicable to all scenarios of

PFAS treatment; however, based on past experience it is possible that regulatory agencies may applying drinking water standards to ground, storm, and sanitary water in the absence of other regulatory standards. The Air Force Civil Engineer Center (AFCEC) issued enterprise-level PFAS guidance in April 2024 based on guidance from the Secretary of the Air Force (SAF).

The DoD Interim Guidance on the Destruction or Disposal of Materials (soil) Containing PFAS was not intended to specify that any detection of PFAS requires disposal to a landfill.

The SAF/IEE guidance is to look at each situation on a case-by-case basis and apply the following criterion:

1. Regional Screening Levels: Do the soils exceed or are they below the RSLs?

2. ARARs/State MCLs: Any state ARARs to include State MCLs?

3. Other RCRA Hazardous Waste: Is there any other RCRA hazardous waste detections?

4. End Use: What is the proposed use of the soil?

5. Existing Site/OU: Is it part of an existing cleanup site?

As of April 2024, no action is required to treat PFAS in soils if the following three conditions are met:

1. the soil is below RSLs and ARARs,

2. PFAS is the only detection, and

3. the soil will be placed back into the same excavated location.

Other scenarios not meeting the three conditions listed above (for soil) will require discussion and decision at the leadership (SAF) level to ensure a consistent and measured approach given the existing regulatory environment.

Construction operations for dewatering, removal of cofferdams, tailrace excavation, and tunnel closure must be constantly controlled to maintain compliance with existing California state water quality standards and designated uses of the surface water body. Comply with the State of California water quality standards and anti-degradation provisions and the Clean Water Act Section 404. Do not discharge excavation ground water to the sanitary sewer, storm drains, or to surface waters without prior specific authorization in writing from the Installation Environmental Office. Discharge of hazardous substances will not be permitted under any circumstances. Use sediment control BMPs to prevent construction site runoff from directly entering any storm drain or surface waters.

If the construction dewatering is noted or suspected of being contaminated, it may only be released to the storm drain system if the discharge is specifically permitted. Obtain authorization for any contaminated groundwater release in advance from the Installation Environmental Chief and the federal or state authority, as applicable. Discharge of hazardous substances will not be permitted under any circumstances.

On April 10, 2024, the EPA announced a final rule on drinking water standards for certain PFAS under the

Safe Drinking Water Act (SDWA). The rule applies to all regulated drinking water purveyors, including

Department of Defense (DoD). DoD is also integrating the PFAS levels established by the final rule into its cleanup program.

The rule:

1. Establishes maximum contaminant levels (MCL) for several PFAS in drinking water.

2. Applies to SDWA regulated water purveyors, including DoD.

3. Includes enforceable levels for five PFAS and a Hazard Index (HI) MCL, calculated as a mixture of four PFAS.

4. Sets the MCLs at the following levels in parts per trillion (ppt):

• PFOS = 4 ppt

• PFOA = 4 ppt

• GenX = 10 ppt

• PFNA = 10 ppt

• PFHxS = 10 ppt

• HI MCL for PFHxS, PFNA, PFBS, and GenX = 1 (unitless).

The rule provides five years for regulated drinking water purveyors to comply with the specified MCL levels. MCLs are also used as cleanup standards and can be used as a risk trigger level to take short-term actions (e.g., drinking water treatment), under the federal cleanup law, the Comprehensive Environmental

Response, Compensation, and Liability Act (CERCLA).

DoD follows CERCLA, as amended, and long-standing Environmental Protection Agency (EPA) regulations for all chemicals in DoD’s cleanup program, including PFAS. The DoD PFAS website

(www.defense.gov/pfas) offers additional information about DoD’s actions to investigate and clean up

PFAS resulting from DoD activities, DoD PFAS policies, DoD PFAS Task Force, DoD PFAS community outreach activities, and PFAS research and development efforts.

An array of PFAS treatment options exists, including off-site “drum and ship” methods and on-site treatment with technologies such as granulated activated carbon (GAC). The method of treatment, if any, will be determined by the appropriate permit requirements, concentration of PFAS, and volume of water to be treated. There are multiple companies located in the Moreno Valley which offer services for on-site or off-site treatment. Two companies are listed below for informational purposes only. March ARB does not endorse either company as a preferred treatment method/provider. All applicable competitive bid processes, acquisition laws, and contract laws shall be followed.

1. Environmental Logistics offers off-site treatment options and can be reached at https://envlogs.com

2. Griffin dewatering offers on-site treatment options and can be reached at griffindewatering.com.

10. Protection of the Environment from Waste Derived from Project.

Outlined below are information and procedures concerning operations control and disposal of solid and sanitary waste and control and disposal of hazardous waste.

Types of wastes expected to be generated (list):

• Lead paint chips

• Low Grade Steel Conduit (electrical)

• Painted Wood

• Concrete / Cinder Blocks

• Access soil or erodible soils

• All construction debris

• Access soil from building foundation excavations

11. Solid nonhazardous Waste:

Provided below is a project specific plan detailing what material is to be disposed of, why these materials cannot be recycled, the schedules for disposal and the method of transportation to be used and the destination. The plan requires that once material is disposed of, the (Contractor Name) shall submit to the

March ARB 453 MSG/CEV through the Contracting Officer, a Non-hazardous Solid Waste Diversion

Report for each disposal event. Each report shall specify the total amount of waste generated and the total amount of waste diverted in cubic yards or tons along with the percent that was diverted.

Examples

• Due to the anticipated amount of lead paint coated and condition of the waste material, we do not anticipate diverting any of the project waste to a Non-Hazardous Solid Waste disposal facility.

• Low Grade Steel Conduit. Cannot be recycled because there is no market for it.

• Concrete / Cinder Blocks will be sent to a facility that crushes and reuses in asphalt roads

• All construction debris not recyclable will be sent to the landfill

• Access soil from building foundation excavations will be reused on base at rehabilitation site

Provided below is the quantity of anticipated solid waste or debris that is anticipated or estimated to be generated by construction and quantities disposed and recycled.

Examples

PVC Piping - 150 lbs

Low Grade Steel Conduit (electrical) – 200 lbs

Painted Wood – 400 lbs

Chicken Wire Glass – 100 lbs

Concrete / Cinder Blocks – 500 lbs

Junction Boxes – 100 lbs

Lead Paint Chips / Residue – approx. 55 Gallons https://envlogs.com/

Masking Paper / Tape – 150 lbs

Solid non-hazardous wastes will be disposed of at (Insert name of facility and State Certification Number for that type of waste):

Non-hazardous liquid wastes are required to be placed in DOT-approved steel drums with proper labels including the contents and the non-hazardous nature of the material. These vessels shall be stored in a separate designated area prior to removal and disposal.

Non-hazardous wastes removed for off-site disposal shall be weighed and ticketed. Trip tickets shall be obtained from the landfill, incinerators and/or recycling facilities utilized and shall be submitted to CEV to document the amount (tonnage) of waste and debris land-filled, incinerated, reused, recycled or salvaged.

Quantity of non-hazardous liquid waste to be generated by the project. (Lbs. or tons of waste)

• There is no non-hazardous liquid waste expected to be generated by this project

• Approximately 5-10 55 gallon drums of lead waste is expected

• Approximately 2 large 40 cubic yard roll bin

12. Recycling and Waste Minimization Plan

Described procedures for separating wastes for recycling or reuse, including but not limited to, papers, metals and glass, that are identified as recyclable material pursuant to the Installation Solid Waste

Management Plan, to be provided by contracting Officer.

13. Hazardous Waste

March ARB is a large-quantity generator (LQG) of HW operating under California/federal Identification

Number CA4570024527. (insert contractor name) will use the procedures contained within Hazardous

Waste Management Plan to comply with both federal and state legislation and regulations. 452 AMW also has contractors working on the installation including those who provide Base Operating Services (BOS) support, those who perform temporary construction or maintenance work, and their subcontractors.

Contractors who perform primary Base functions, for purposes of this HWMP, are Base personnel and must comply with this HWMP. Contractors and subcontractors who perform construction and maintenance work shall:

• Comply with all federal, state, and local regulations;

• Comply with this HWMP, except to the extent certain portions of the HWMP are delegated to

Base personnel; and

• Ensure any contractor employees working with HW have all required training.

This HWMP covers the control and management of HW through the generation, accumulation, and shipment of HW for off-site treatment, storage, or disposal. Effective execution of March ARB’s HW management program requires the maximum cooperation of all personnel on the Base including 452 AMW, tenants, on-base contractors, and other support contractors.

13.1 Hazardous Waste Management Procedures

Provided below are the management procedures for hazardous waste to be generated during the contract period. The elements of those procedures coincide with the Installation Hazardous Waste Management

Plan (HWMP). The Contracting Officer will provide a copy of the HWMP. Before any work can be done, all potential hazardous waste generated must be identified. A plan Hazardous waste management plan for the project will have the identification of all hazardous wastes expected and include how accumulation, offsite transportation and disposal will occur. The HW Manager ensures that appropriate procedures are properly communicated and followed by all necessary personnel. In this section we will go over management procedures for identification, accumulation, offsite transportation and disposal.

13.2 Identification

The HW Manager determines the nature of waste based on a detailed qualitative analysis of the regulated waste generating process, associated Safety Data Sheet (SDS) information, and coordination with generating activity personnel involved in the use of hazardous materials. Below are procedures to ensure a written waste determination is made for appropriate wastes that are to be generated

(Describe procedures)

Describe procedures example 1- identification

For the building xxx project, we have identified that lead paint does exist. Laboratory tests and reports were provided prior to contract approval.

Describe procedures example 2- identification

For the demolition of building xxx project, we have identified several hazardous waste generated by this project. The hazardous waste identified are as follows;

• Lead based paint

• Asbestos

• Light bulbs

• Light ballasts

• Batteries

• Used oil

Example 1.

Building was built before 1975 so the likelihood of existing asbestos was high enough to have laboratory testing done to determine. Lab results confirmed asbestos is present so we included a plan to properly store, label and remove as hazardous waste

Example 2.

Building was built before 1978 so the likelihood of existing lead paint was high enough to have laboratory testing done to determine. Lab results confirmed lead is present so we included a plan to properly store, label and remove as hazardous waste

All lighting will be removed from building for interior remodel. All lights and light ballasts’ are known to have hazardous wastes present so we included a plan to properly store, label and remove as hazardous waste.

Example 4.

Laboratory testing was not necessary because based on age of the building and previous tests, we are assuming that asbestos does exist so we included a plan to properly store, label and remove as hazardous waste.

13.3 Sampling/Analysis Documentation

Provided below is the Sampling/analysis plan, including laboratory method(s) that will be used for waste determinations (complete): if waste determination was already completed for contractor, add statement “Laboratory sampling and analysis documentation was completed by MARCH ARB” (see

Attachment xx) for Laboratory reports and certificates”. Then delete next request.

Example 1

(company name) will have a certified laboratory take samples of various parts of the building to include all potential waste determination. Results will be updated in this plan.

Lab reports for lead paint are located in attachment 3 Lab reports for asbestos are located in attachment 3

Sampling was already complete by March ARB and provided to us. See attachment 4

Example 4 Laboratory testing was not necessary because based on age of the building and previous tests, we are assuming that asbestos does exist and we will be doing full asbestos abatement.

Example 5 Laboratory sampling and analysis documentation was completed by MARCH ARB. See Attachment 4 (LBP Survey)

Provided below are laboratory certifications or State certification numbers for Labs to be used

(complete):

13.4 Accumulation and Storage

Example

Daily accumulation will occur within the staging area. At the end of the day all waste will be separated into non hazardous waste and recyclables and Hazardous waste. The non hazardous waste and recyclables will be stored within a designated waste area usually within the staging area until it can be removed. The hazardous waste will be properly sorted, contained and labeled and put into a hazardous waste satellite accumulation area.

13.5 Satellite Accumulation

A Satellite Accumulation Point is a HW accumulation area located at or near the point of generation and under the control of the operator of the process generating the waste. Each container is properly marked and labeled from initial accumulation area to HWAS to disposal/turn-in. The waste-generating activity ensures that the label on each waste container is clearly visible for inspection. All hazardous waste must be removed within 3 calendar days of filling the container if the waste is stored at the Satellite

Accumulation Point. Satellite Accumulation Point volume accumulation is limited to one 55- gallon drum of HW, 1 quart of acute HW, or 1 quart of extremely HW. Containers used to store HW to be shipped off-site for treatment, storage, and/or disposal must meet DOT requirements for transport of the waste stored in the container. The container used to accumulate waste must meet DOT requirements (49 CFR 173).

Describe below methods for hazardous waste accumulation/storage (that is, in tanks or containers, etc. IAW the HWMP)

Example 1

All waste will be accumulated into drums as the removal occurs. These drums will be stored in a temporary satellite accumulation area and then be moved to a locked enclosure by the end of the day.

All waste removed will be accumulated into various containers depending on the waste. Asbestos will be loaded into a large 40 cubic yard roll bin. All lead based paint and other materials will be loaded into 55 gallon drums. All light bulbs collected will be put into strong cardboard boxes. All various other hazardous wastes such as light ballasts will be put into bags. All contained wastes will be properly labels and closed and locked by the end of the word day. All smaller hazardous wastes will be put together within a satellite accumulation area. Furthermore all waste will be put into proper containers as required by CCR title 22 which is also covered in detail within the HWMP.

During accumulation at an IAP, HW containers are marked with the following:

• The words “Hazardous Waste”

• A description of the contents of the container

• The hazards associated with the waste

• Name and Address will be March Air Reserve Base (we are the waste generator). Our address, our EPA ID No #CA4570024527

Example1

There is one designated satellite accumulation site located at the point of waste generation. This site will store all waste generated from the project until transportation to the treatment facility is planned.

There are 2 designated satellite accumulation sites for this project. The first is an area at the generation point where containers will be loaded and labeled. At the end of the day these container will them be moved to a secondary locked area at the end of each day until transportation of the waste can be arranged.

Example 3

Containers will be loaded until full. Once the container is full, transportation will be arranged to transport waste directly to the treatment facility.

Insert photo of waste labels that will be used here

Provided below is a map of proposed locations for hazardous waste accumulation/storage

(insert below or attach (Attachment number ) (see map X)

Example 1 Explanation

Listed…