Attachment 13 AF Form 813 Construct ADC Facility.pdf

17 July 2020

MEMORANDUM FOR 325 CES/CEIEC

FROM: 325 FW/JA

SUBJECT: Legal Review – AF IMT 813 – Construct New Area Defense Counsel (ADC)

Facility, Tyndall AFB

1. You requested a legal review and sufficiency determination of the proposed categorical exclusion (CATEX) from further environmental analysis for this proposed action. I have reviewed the Request for Environmental Impact Analysis (AF IMT 813) titled “Construct New Area Defense Counsel (ADC) Facility” and find it legally sufficient.

2. Background: The purpose of this proposed action is to construct a new ADC facility to replace the current facility B1287. The current ADC facility was severely damaged as a result of Hurricane Michael and is scheduled for demolition. The new facility will provide the office space and parking for the Area Defense Counsel to perform its functions with the privacy that is needed.

a. The project will construct a 1550 SF facility in the footprint of the previous ADC building.

The total area for the construction will be approximately 7600 SF which includes the facility and all pavements. The addition will connect to existing utilities that are already onsite. Max depth for all ground disturbances will be 2’-3’ for the footings and slab. The facility itself will be contracted as a Design-Build. It will include administrative and maintenance services complete with associated utilities, storm drainage, communications, electric, HVAC, lightning protection, fire protection/alarm system, paving and sidewalks, curbs, gutters, access drives, exterior lighting, grading, and physical security requirements. The site shall be prepared to provide relatively uniform sub-grade support for the proposed development, including the removal of existing foundations, grade slabs, pavements, and old fill that may be encountered in discrete locations within the building limits during site excavations. Abandoned utility pipes within the building's footprint shall be removed. Any waste excavation shall be disposed of off-site per required guidelines. A storm sewer system shall be designed by the DOR to facilitate positive drainage of the parking facilities and general site. All gutters and downspouts shall connect to the storm sewer system.

b. No other alternatives were identified or evaluated except the no-action alternative. Under the no-action alternative, the current building will be demolished without a replacement being constructed, negatively impacting the ability to provide adequate facilities for essential ADC services.

c. The source of the proposed CATEX is Appendix B to Part 989, CATEX A2.3.11, actions similar to other actions which have been determined to have an insignificant impact in a similar setting as established in an EIS or an EA resulting in a FONSI. The EPF must document

DEPARTMENT OF THE AIR FORCE

325TH FIGHTER WING (ACC)

TYNDALL AIR FORCE BASE FLORIDA

application of this CATEX on AF Form 813, specifically identifying the previous Air Force approved environmental document which provides the basis for this determination. The Environmental Assessment Hurricane Recovery and Installation Development, dated April 2020, is the Air Force-approved document forming the basis for use of this CATEX. The construction project is in the same general area and similar in nature to projects evaluated in the EA. 325 CES/CEIE has conducted an evaluation of subject EA to ensure the document is still valid in accordance with 32 CFR 989.20 (c), including an on-site survey, finding no new environmental impacts as a result of the proposed action.

3. Discussion: An AF IMT 813 Review Checklist is attached summarizing my review.

a. The cited EA resulting in a FONSI evaluated the proposed demolition, construction and renovation of numerous facilities throughout the installation that were severely damaged by Hurricane Michael in 2018. Under that proposed action, 28 individual projects spanning six planning areas throughout the installation were evaluated, as well as three additional projects which covered more than one planning area (Multi-Area projects). The purpose of implementing the installation development projects at Tyndall AFB was to recover mission capabilities at Tyndall AFB impacted by Hurricane Michael, and rebuild Tyndall AFB to a fully operational base, thereby providing new facilities/infrastructure, as well as executing repair, demolition and functionality improvements necessary to support the 325 FW mission and tenant units. That EA resulted in a finding of no significant impact. I find that the proposed action is sufficiently similar in nature and location to support application of A2.3.11 to this proposed action, taking into consideration the EPF’s updated environmental survey, tribal and historic consultation and analysis of the site finding no new information providing contrary indications or negative impacts.

b. The project is within the boundary of Environmental Restoration Program (ERP) Site FR038, undergoing a contamination study. Contaminants affecting the project area include metals (lead, antimony, arsenic) in the soil and shallow groundwater of the project boundary.

There are no known PFOS/PFOA spill sites in the project area. The action proposes to ensure attached ERP Guidelines are followed when working in this area with potential contamination to avoid negative impacts. After consultation with the Air Force Legal Operations Agency (AFLOA) Environmental Liaison Officer (ELO) at HQ ACC/JA and Environmental Law Field Support Center (ELFSC) restoration attorneys as required by policy, AFLOA attorneys raised no legal objection based on ERP concerns so long as the proposed guidelines are followed when working within this area.

c. 32 CFR 989 requires both air quality NEPA and General Conformity Rule assessments within the EIAP process. While 32 CFR 989 Appendix B provides a list of CATEX actions that exclude further environmental analysis in an EA or an EIS, 32 CFR 989.13(e) states that “application of a CATEX to an action does not eliminate the need to meet air conformity requirements”. Therefore, even if a proposed action has been excluded from EIAP analysis based on a CATEX, further air quality analysis is required if a proposed action is located where General Conformity applies. Since this action will occur within an attainment area, the action is exempt from General Conformity. See Air Quality EIAP Guide Volume I, Table 5-2, List of General Conformity Exemptions; EIAP Guide p. 49; 40 CFR 93.153.

4. Recommendation: Proceed with the proposed action. The Request for Environmental Impact Analysis is legally sufficient. If you have any questions or concerns please contact me at 283-8151.

GERALD D. LAVER

Attorney-Advisor

Attachment:

AF IMT 813 Review Checklist, 17 July 2020

AF IMT 813 Review Checklist Construct New Area Defense Counsel (ADC) Facility

Mr. Gerald Laver, 17 July 2020 This checklist provides an overview for conducting a legal review of an AF IMT 813, Request For Environmental Impact Analysis (Form 813). The Air Force uses Form 813 to document the need for environmental analysis under the National Environmental Policy Act (NEPA), 42 U.S.C. Sec. 4321-4370f, or for certain Categorical Exclusions (CATEX) determinations for proposed actions. Generally, the AF IMT 813 is the starting point that initiates the AF Environmental Impact Analysis Process (EIAP). An attorney reviews the AF IMT 813 to ensure the proposed project meets the requirements of NEPA and the EIAP. If after completing the checklist, any one of blocks 1-19 are not checked or marked N/A, the AF Form 813 will be legally insufficient.

The AF EIAP regulation can be found at 32 CFR Part 989. AFI 32-7061, The Environmental Impact Analysis Process which adopts 32 CFR Part 989, is the controlling instruction for AF EIAP. CATEX determinations and descriptions identified by number are found in 32 CFR Pt 989 Appendix B.

If you have questions not addressed by the checklist, or you are uncertain about the sufficiency of the analysis in any portion of the AF Form 813, please contact your MAJCOM-ELO (Maj Milott). If you are coordinating with the Environmental Law Field Support Center Planning and Sustainment Branch, they may be contacted at 210-395-8998, DSN 969-8998 or by email at afloa.jaceps@us.af.mil.

Check if Met

Comments

SECTION I - PROPONENT INFORMATION

1. Blocks 1-3, Blocks 6-6b have been completed

Blocks comprised of self-explanatory administrative data.

X

2. Block 4 - Proponent has included a purpose and need statement in block or in an attachment.

3. Purpose statement clearly describes what the proponent intends to accomplish with the action.

4. Need statement clearly identifies why the proposed action is necessary.

Examples could include mission requirements or legal/regulatory changes, etc.

5. Block 5- Description of Proposed Action and Alternatives Proposed Action (DOPAA)

Block includes description of what action the proponent wants to take.

6. Description of proposed action is sufficiently detailed to ensure it meets the purpose and need as articulated in Block 4.

Block 5 may contain reasonable alternatives to the proposed action along with the no action alternative. Those items will be addressed at a later point in the checklist.

SECTION II – PRELIMINARY ENVIRONMENTAL SURVEY

7. One of the columns under each Block 7-16

Checked.

X

8. Blocks 7-16 Assessment makes sense based upon the type of action

Use common sense, for instance, if the proposed action requires filling some portion of a wetland and block 12 no effect is checked there are likely questions that you need to ask the environmental planner.

The project to Demolish and Rebuild Area Defense Counsel B1287 is within the boundary of Environmental Restoration Program (ERP) Site FR038, undergoing a contamination study. Contaminants affecting the project area include metals (lead, antimony, arsenic) in the soil and shallow groundwater of the project boundary. There are no known PFOS/PFOA spill sites in the project area. Contractor must followed attached guidelines when working with this area.

9. Action assessed to have unknown environmental impacts

If NO then mark as N/A.

If the action has any unknown effects, the decision maker cannot determine that unknown effects are not significant. A CATEX cannot be applied at this time and an Environmental Assessment (EA) or Environmental Impact Statement (EIS) should be considered.

N/A

10. Action assessed to have potential adverse effects in blocks 7-16.

If NO, then mark as N/A.

If an action has any potential adverse effect it will probably result in an Environmental Assessment (EA) or an Environmental Impact Statement (EIS) and will not qualify for a categorical exclusion

(CATEX)

If uncertain contact ELO or Planning and Sustainment Branch of ELFSC.

SECTION III – ENVIRONMENTAL ANALYSIS DETERMINATION

11. Block 17 indicates a CATEX is applicable.

If NO Mark Checklist Items 11-15 N/A and skip to

12. CATEX applied has been identified by number

CATEX descriptions identified by number are found in 32 CFR Pt 989 Appendix B

CATEX A2.3.11, “Action similar to other actions which have been determined to have an insignificant impact in a similar setting as established in an EA resulting in a FONSI.” The Environmental Assessment for Hurricane Recovery and Installation Development at Tyndall Air Force Base, April 2020, is the approved environmental document cited for CATEX.

13. CATEX applied is consistent with the description of the proposed action.

If NO, determine if another CATEX in Appendix B might apply. If one does discuss with environmental planner and have form accomplished again.

If uncertain about the proper application of a particular CATEX contact ELO or Planning and Sustainment Branch of ELFSC.

14. Review 32 CFR 989, Appendix B, A2.2. Categories of Actions with “unique circumstances” described in subparagraphs have not been implicated.

If categories have been implicated, application of a CATEX may be legally insufficient and additional analysis may be required.

If uncertain whether A2.2 has been implicated or whether it precludes the application of a CATEX, contact ELO or Planning and Sustainment Branch of

ELFSC

Construction on active IRP site will be addressed consistent with AFLOA restoration coordination.

Certain CATEX’s will require review of additional documents, you must be certain to review all necessary documentation that supports analysis. Two common instances are listed below. Review CATEX to determine if other documentation also needs review.

A2.3.7 requires proposal to have been originally evaluated in accordance with applicable regulations.

A2.3.11 requires proposal to be sufficiently similar to other project with EA/FONSI or EIS (an EBS is insufficient).

15. Use of CATEX is consistent with Preliminary

Environmental Survey

Checklist Item #9 MUST be marked N/A

Checklist Item #10 MUST be marked N/A OR you have consulted your environmental planner and/or ELO and are satisfied that the application of a CATEX is consistent with 32 CFR 989.13(b)

32 CFR 989.13 provides guidance regarding the applicability of a CATEX. Per 989.13(b) categories of actions that ordinarily do not require an EA or EIS include: “Minimal adverse environmental impacts.”

If adverse impacts are indicated further environmental study is then ordinarily done, Coordinated IRP siting with AFLOA ELFSC restoration branch.

however, if the action fits within CATEX and the adverse impacts are consistent with 32 CFR 989.13(b)(1) document may be considered legally sufficient.

16. Block 17 - indicates further environmental analysis required.

If NO mark as N/A then move to Checklist Item #17.

17. Block 17 – not completed

If Either box on Block 17 has been checked mark as N/A.

There may be instances where the AF Form 813 is being used to record the fact that environmental issues were considered but that neither a CATEX nor further study was required. In this instance you should see some further information in Block 18 of the form. If you encounter this situation, contact your ELO or the ELFSC Planning and Sustainment Branch to discuss prior to determining legal sufficiency.

18 Block 18 offers valid explanation how AF Form 813 is being used to create a record of environmental consideration when an action is not subject to a CATEX and does not require further environmental analysis.

An example of a situation where this would apply is where an action that does not fit into a CATEX and there will clearly be NO environmental impacts arising from the action but a record is required

Circumstances where this would occur are likely to be rare, please contact ELO or Planning and Sustainment Branch of ELFSC to discuss.

19. Block 18 includes a statement indicating that conformity requirements pursuant to Section 176(c) of the Clean Air Act have been addressed. See 32

CFR 989.30

Possible examples of an appropriate statement could be:

“The proposed action will occur in an area that is in attainment for all criteria pollutants and no conformity determination under the Clean Air Act is required”; or

“The proposed action will occur in an area that is in nonattainment for [insert criteria pollutant]; however emissions from the action will be de minimus so no conformity determination under the Clean Air Act is required.”

Note: If Block 17 indicates that further environmental analysis must be completed, conformity requirements will be addressed in the EA/EIS and this checklist Item may be checked.

If you have questions contact your ELO or the Planning and Sustainment Branch of ELFSC to discuss.

20. Block 18: information in block does not impact the previously reviewed information.

If Block 18 does impact previous analysis, reconcile questions before determining legal sufficiency.

If you are uncertain about whether comments included in Block 18 call into question the other Checklist Items previously reviewed, contact ELO or Planning and Sustainment Branch at ELFSC for assistance.

21. Return to Block 5 on Form 813

Block 5 Includes reasonable alternatives to the Proposed Action (ONLY REQUIRED IF

FURTHER ENVIRONMENTAL ANALYIS

REQURIED)

AF must analyze reasonable alternatives for all EA’s and EIS’s. See 32 CFR 989.8(a). The Block 5 DOPAA will serve as the basis for the DOPAA in an EA/EIS if needed and should identify reasonable alternatives.

Sometimes proponent will include reasonable alternatives for projects subject to valid CATEX.

This is acceptable but not required.

No action alternative is the only alternative provided.

22. Block 5 identifies that No action alternative is included in DOPAA.

Unless otherwise excused by law the no action alternative must be analyzed. See 32 CFR 989.8(a).

(ONLY REQUIRED IF FURTHER

ENVIRONMENTAL ANALYISS REQURIED)

Sometimes proponent will include no action alternative for projects subject to valid CATEX.

This is acceptable but not required.

AF FORM 813, 19990901 (EF-V1) Page 1 of 2THIS FORM CONSOLIDATES AF FORMS 813 AND 814.

PREVIOUS EDITIONS OF BOTH FORMS ARE OBSOLETE.

REQUEST FOR ENVIRONMENTAL IMPACT ANALYSIS

SECTION I - PROPONENT INFORMATION

INSTRUCTIONS: Section I to be completed by Proponent; Sections II and III to be completed by Environmental Planning Function.

Continue on separate sheets as necessary and reference appropriate item number(s).

1. TO (Environmental Planning Function)

325 CES/CEIEC

2. FROM (Proponent organization and functional address symbol)

325 CES/CENPD

2a. TELEPHONE NO.

(850) 283-4362

3. TITLE OF PROPOSED ACTION

Construct New Area Defense Counsel (ADC) Facility

4. PURPOSE AND NEED FOR ACTION (Identify decision to be made and need date)

The Purpose and Need For Action is attached. See Page 2.

5. DESCRIPTION OF PROPOSED ACTION AND ALTERNATIVES (DOPAA) (Provide sufficient details for evaluation of the total action)

The Description of Proposed Action and Alternatives is attached. See Page 2

6. PROPONENT APPROVAL (Name and Grade) Quentin Morales, GS-11

6a. SIGNATURE 6b. DATE 20191022

SECTION II - PRELIMINARY ENVIRONMENTAL SURVEY (Check appropriate box and describe potential environmental effects including cumulative effects) (+=positive effect; 0=no effect; - = adverse effect; U=unknown effect) + 0 - U

7. AIR INSTALLATION COMPATIBLE USE ZONE/LAND USE (Noise, accident potential, encroachment, etc.)

8. AIR QUALITY (Emissions, attainment status, state implementation plan, etc.)

9. WATER RESOURCES (Quality, quantity, source, etc.)

10. SAFETY AND OCCUPATIONAL HEALTH (Asbestos/radiation/chemical exposure, explosives safety quantity distance, bird/wildlife aircraft hazard, etc.)

11. HAZARDOUS MATERIALS/WASTE (Use/storage/generation, solid waste, etc.)

12. BIOLOGICAL RESOURCES (Wetlands/floodplains, threatened or endangered species, etc.)

13. CULTURAL RESOURCES (Native American burial sites, archaeological, historical, etc.)

14. GEOLOGY AND SOILS (Topography, minerals, geothermal, Installation Restoration Program, seismicity, etc.)

15. SOCIOECONOMIC (Employment/population projections, school and local fiscal impacts, etc.)

16. OTHER (Potential impacts not addressed above.)

SECTION III - ENVIRONMENTAL ANALYSIS DETERMINATION

17. PROPOSED ACTION QUALIFIES FOR CATEGORICAL EXCLUSION (CATEX) # ; ORA2.3.11

PROPOSED ACTION DOES NOT QUALIFY FOR A CATEX; FURTHER ENVIRONMENTAL ANALYSIS IS REQUIRED.

18. REMARKS

Conformity determination is not required based off TAFB being in an attainment area for air emissions. The FESOP permit will not be violated by this action.

19. ENVIRONMENTAL PLANNING FUNCTION CERTIFICATION

(Name and Grade) Edwin Wallace, GS-12

19a. SIGNATURE 19b. DATE

MORALES-

PERRYMAN.QUENTIN.L.1090977500

Digitally signed by MORALES-

PERRYMAN.QUENTIN.L.1090977500

Date: 2019.10.22 11:07:47 -05'00'

WALLACE.EDWIN.

BLAIR.1047698347

Digitally signed by

WALLACE.EDWIN.BLAIR.1047698

Date: 2020.06.22 08:50:45 -05'00'

Construct New ADC Facility AF Form 813 continuation sheet

4.0 Purpose and Need for Action

The purpose of this proposed action is to construct a new ADC facility to replace the current facility B1287. The current ADC was severely damaged, as a result of Hurricane Michael, and is scheduled for demolition.

The new facility will provide the office space and parking for the Area Defense Counsel to perform its functions with the privacy that is needed.

5.0 Description of Proposed Action and Alternatives (DOPAA)

Proposed Action: Construct a 1550 SF facility in the footprint of the previous ADC building.

The total area for the construction will be approximately 7600 which include the facility and all pavements. The addition will connect to existing utilities that are already onsite. Max depth for all ground disturbances will be 2’-3’ for the footings and slab.

The facility itself will be done as a Design-Build. It will include administrative and maintenance services complete with associated utilities, storm drainage, communications, electric, HVAC, lightning protection, fire protection/alarm system, paving and sidewalks, curbs, gutters, access drives, exterior lighting, grading, and physical security requirements. The site shall be prepared to provide relatively uniform sub-grade support for the proposed development, including the removal of existing foundations, grade slabs, pavements, and old fill that may be encountered in discrete locations within the building limits during site excavations. Abandoned utility pipes within the building's footprint shall be removed. Any waste excavation shall be disposed of off-site per required guidelines. A storm sewer system shall be designed by the DOR to facilitate positive drainage of the parking facilities and general site. All gutters and downspouts shall connect to the storm sewer system.

No Action Alternative: Status Quo – Under the no-action alternative, the current building will be demolished without a replacement being constructed.

5.1 Anticipated Environmental Issues

• Short term air emissions during construction

• Short-term increases in sediment to storm water during construction

• Contamination under existing slab

5.2

ACUIZ/ Noise:

The proposed actions would result in a localized and temporary increase in noise levels due to operation of heavy equipment; this noise is not expected to be significant. The proposed action would not significantly contribute to the noise levels of the area.

The proposed action would be compatible with existing land use in the vicinity of the project.

The Air Force site selection and design planning process assures compliance with Air Force regulations pertaining to compatible land use, AICUZ, and prevention of obstructions to air navigation.

Air Quality:

Tyndall AFB is in an attainment area for National Ambient Air Quality Standard. The Federally Enforceable State Operating Permit (FESOP) for Tyndall will not be violated by the implementation of the proposed project. Temporary minor exhaust emissions would occur in the immediate vicinity of the construction. Fugitive dust would be controlled at the sites using best management practices (BMP’s), such as periodic watering of cleared areas and stockpiled materials and mulching or groundcover for the cleared areas. The air quality will not be significantly impacted by the proposed action. Therefore a Conformity Determination is not required for this action.

Water Resources:

Best management practices for erosion control shall be implemented prior to construction activities and maintained at all times during construction to prevent siltation and turbid discharges. Install erosion control measures along the perimeter of all work areas to prevent the displacement of fill material outside the work area into waters of the United States. Immediately after completion of the final grading of the land surface, all slopes, land surfaces, and filled areas shall be stabilized using appropriate vegetation, degradable mats, barriers, or a combination of similar stabilizing materials to prevent erosion. Methods could also include, but are not limited to the use of staked hay bales, staked filter cloth, sodding, seeding, and mulching; staged construction; and the installation of turbidity screens around the immediate project site. Identify and cover Stormwater structures using protection devices before performing any work. Devices must remain in place until all work is complete and the area has been cleaned and free of construction potential discharges. The erosion control measures shall remain in place and be maintained until all work is completed and the work areas are stabilized.

The Contractor shall be responsible for taking all actions necessary to comply with the erosion and sedimentation control laws and implementing the permit. No major disturbances in the natural flow, discharge, and recharge of surface water resources would be expected as a result of the Proposed Action. Implementation of Proposed Action is not expected to impact the quality of groundwater at Tyndall AFB or the surrounding area.

The proposed action will require the following BMP's:

• Use of silt fencing or turbidity screens

• Stockpiling equipment outside of (wetlands, swales and ditches)

• Spill response equipment on hand

All stormwater conveyance structures shall remain in operable condition and shall not be allowed to deteriorate or otherwise contribute to a water quality violation. A stormwater permit and/or pond may be required. It is recommended that the overall site be looked at to determine if additional Stormwater features should be added to reduce flooding in that area due to previous construction which did not properly address Stormwater needs.

If dewatering is needed to complete the task, a state and/or federal permit may be required. All dewatering must be coordinated with CEIEC and AFCEC to verify dewatering and discharge locations. Additional drawings may be requested. All permit applications must be reviewed by CEIEC and signed by the 325th CES Commander prior to submittal. All costs associated with permits will be paid for by the contractor

Soil Impact:

Under the Proposed Action, construction activities, such as removal, grading, excavating, and contouring of the soil, would result in soil disturbances. The soils in the vicinity of the proposed construction area has been altered over time, and the project areas have been disturbed by existing facilities and paved areas. The project to Demolish and Rebuild Area Defense Counsel B1287 is within the boundary of Environmental Restoration Program (ERP) Site FR038, undergoing a contamination study. Contaminants affecting the project area include metals (lead, antimony, arsenic) in the soil and shallow groundwater of the project boundary. There are no known PFOS/PFOA spill sites in the project area. Contractor must followed attached guidelines when working with this area.

Biological Resources:

The proposed action would occur in a developed area. The nature of the location results in poor habitat for threatened and endangered species. Therefore, proposed action would not adversely affect any federally protected species. Proposed action is not sited in the 100 year floodplain or wetlands.

Cultural Resources:

The proposed undertaking was coordinated with the State Historical Preservation Office and Native American Tribes. The proposed undertaking will have no effect on historical properties.

All work should cease and the Cultural Resources Manager should be contacted if archaeological deposits or human remains are encountered.

Hazardous Material/ Waste:

The use of hazardous materials during the implementation of the Proposed Action is expected to be limited to construction vehicle maintenance (fuel, oils, and lubricants) activities and construction materials (adhesives, sealants, etc.). These materials would be required to be properly contained, manifested, and managed in accordance with all federal, state, and local regulations, AFIs, and DoD Directives. Authorization from the Tyndall AFB Hazardous Materials Office would need to be acquired prior to use of hazardous materials. Contractor and all sub-contractors must submit TAFB Forms 81/82 and Safety Data Sheets. The chemicals listed on the Form 82 must be approved by the 325 CES/CEIEC Hazardous Materials Office prior to bringing the materials onto the installation. The contractor must submit TAFB Form 83 at the completion of the project. If the project duration is longer than 30 days, the contractor must submit the TAFB Form 83 on a monthly basis until the project is complete.

The proposed action may generate small quantities of hazardous materials/wastes. Disposal of hazardous waste must be completed in accordance with Tyndall AFB Hazardous Waste Management Plan. Additionally, management of hazardous waste must be completed in accordance with 40 CFR 260-279. Hazardous waste transportation and disposal shall be coordinated through 325 CES/CEIE. The transportation and disposal facilities shall be approved by 325 CES/CEIE prior to their use. Manifests shall be signed only by 325 CES/CEIE. Drums shall be disposed of within 90 days of placing the first material in the container. Any excess excavated soil must be spread-out on land adjacent to the excavation site or must be tested for disposal at a RCRA Facility. If reuse is desired, soil must be certified clean. A Hazardous Waste Determination must be conducted/recorded for any Solid Wastes Generated.

Solid Waste:

Construction activities associated with the Proposed Action would result in a short-term increase in solid waste generated at Tyndall AFB. The contractor will be responsible for disposing of solid waste in accordance with all federal, state, and local laws. Recyclables generated from the construction and demolition shall be recycled and proceeds returned to the U.S Treasury.

Concrete Slab shall be disposed of in a C&D Landfill. If recycling is desired, a Full TCLP must be conducted with all results below the Toxicity Characteristic Regulatory Limit found in Table #1 40 CFR 261.24(b).

Cumulative Impacts:

There will be no accumulative effects for this proposed project. However, this action will be included to evaluate long term cumulative impacts of construction and demolition projects as part of the Tyndall AFB reconstruction activities.

5.3 Environmental Requirements

Digging/Excavation

Prior to any digging, an Excavation permit will be required. An Air Force Form 103, BCE Work Clearance Request, will be required.

5.4 List of Required Permits

Permits may be required for the proposed action. Contractor is responsible to ensure all permits are submitted to the 325 Civil Engineer Squadron for review.

5.5 CATEX Statement

The proposed project will not adversely impact Tyndall AFB environmental attributes; therefore, qualifies for Categorical Exclusions (CATEX) A2.3.11. Actions similar to other actions which have been determined to have an insignificant impact in a similar setting as established in an EIS or an EA resulting in a FONSI. The EPF must document application of this CATEX on AF Form 813, specifically identifying the previous Air Force approved environmental document which provides the basis for this determination.

The Environmental Assessment Hurricane Recovery and Installation Development, dated April 2020, is the Air Force approve document which form the basis for using this CATEX.

The construction project is in the same general area and is smaller in scope than the projects area evaluated in the EA. 325 CES/CEIE has conducted an evaluation of subject EA to ensure the document is still valid in accordance with 32 CFR 989.20 (c). As part of the re-evaluation, CEIE personnel conducted an on-site survey and found that the affected environment and environmental consequences:

1. The methodology/analytical approach previously used is appropriate for the proposed action.

2. The direct and indirect impacts of the proposed action are not significantly different than those identified in the existing document.

3. The proposed action would not change the previous analysis of cumulative impacts.

4. Public involvement in the referenced analysis provides appropriate coverage for the proposed action.

5. There has been no significant change in circumstances or significant new information relevant to the proposed action.

PROJECT ENVIRONMENTAL REVIEW SHEET

Project Title: Construct ADC Facility

Project Description:

Project Number:

1. Natural Resources

Reviewed By: _____ewallace________________ Does project affect flora? YES _ ___ NO _X__ Does project affect fauna? YES ____ NO ___X_ Does project affect BASH? YES ____ NO __X__ Does project affect wildlife management area? YES ____ NO _X___ Does project affect forestry management area? YES ____ NO _X___ Does project affect erosion? YES ____ NO _X___

2. Threatened and Endangered Species Reviewed By: _____ewallace________________ _X_ Project has no potential for affecting threatened or endangered species or critical habitats.

__ Based on advice from USFWS or host nation liaison _____, threatened or endangered species in the vicinity of the project will not be affected.

__ Consultation with USFWS underway in accordance with the Endangered Species Act.

__ Formal Consultation with the Regional Director, USFWS completed on ______.

__ Biological Assessment is required. Estimated completion date completion date is ______.

__ Biological opinion issued by USFWS on ______.

3. Cultural Resources Reviewed By: _______ewallace______________ __ Properties affected by project are addresses in a programmatic Agreement that was fully executed with the State Historic Preservation Officer and the ACHP on ______.

__ Project area has not been surveyed for historic properties. Survey requirements are identified in the A-

106 system and the estimated completion date is ______.

_ _ Project area has been surveyed and no historic properties were identified; the State Historic

Preservation Officer was notified by letter dated _ __ Survey identified historic properties but the project will have no effect on them; written concurrence by the State Historic Preservation Officer is dated ______.

__ After consultation, State Historical Preservation Officer concurred that the project will have no adverse effect on historic properties. The Advisory Council on Historic Preservation concurred in writing with this determination on _______.

_ X_ Project will have no adverse effect on historic properties or archeological material.

__ Estimated sate to execute the MOA is _______ or no MOA was developed and the formal comments of the Council are being sought.

__Archeological Monitor must be present during any ground disturbance.

__ Appropriate Native American Tribe or Group contacted on _______.

1. Wetlands Reviewed By: ___ewallace__________________ _X_ Project is not sited in a wetland __ Requirements of EO11990 in progress. Estimated completion date is ______ __ Requirements of EO 11990 completed on ____.

__ Other

2. Flood Plain Reviewed By: ____ewallace_________________ _X_ Project is not sited in a 100-year flood plain.

__ Requirements of EO 11990 in progress. Estimated completion date is ______ _ _ Project is sited in a 100-year flood plain. Requirements of EO 11990 completed on ______ Finding of "No Practicable Alternative signed 18 April 2001______

3. Potentially Regulated Substances Reviewed By: __ewallace___________________

a. Water:

__ Construction permit required for extension of water system per 62.555, FAC.

__ No permit required because less than 2 in. diameter pipe and less than 100 if extension.

__ Backflow preventer(s) required. Must be field tested by licensed inspector upon installation.

__ Sprinkler system must have rain sensor device per FS 373.62.

__Well drilling/mod/abandonment must be conducted by a licensed contractor. Permit required per 4OC-3, FAC.

_X_ Other: Permits may be required for this project.

b. Wastewater:

__ Construction permit required to connect to collection system per 62-600, FAC.

_X_ No permit required per 62-604.1 10 (single facility, gravity service connection, no pretreatment, compatible discharge) __ Other: No Wastewater required for this project.

c. Stormwater:

__ Environmental Resource Permit required from: _______________

a. Creates more than 4,000 s.f. impervious surface subject to vehicular traffic;

b. Creates more than 5,000 s.f impervious surface; or

c. Project affects 5 acres or more (includes recreation areas, golf course, ball fields, etc.)

__ Site included in station stormwater master plan; permit required but may access existing stormwater treatment system. (Basin no. __________ pond no._________ ; approx ________________ s.f.)

__ NPDES 1-acre site; construction contractor must obtain permit and implement Stormwater Pollution Prevention Plan.

_X_ No permitting required. BMP’s must be installed during demolition/construction.

__ Upon completion site will be included in Base Stormwater Pollution Prevention Plan.

_ _ Other:

d. Asbestos:

_X_ Not present: _________ survey underway.

__ Survey required, If present must be abated prior to demolition

e. Lead Based Paint:

_X Not present: _________ survey underway.

__ Present

f. Ozone Depicting Substances:

_X_ Not present: _________ survey underway.

__ Present (describe mitigation, or state why mitigation is not necessary).

g. Polychlorinated biphenyls (PCBs):

X__ Not present: _________ survey underway.

__ Present (describe mitigation, or state why mitigation is not necessary).

h. Other known hazardous or toxic substances and pollutants (e.g. contaminated soils):

_ Not present: _________ survey underway.

_X_ Present (guidelines attached).

4. Hazardous Materials _X__ Will chemicals (such as, but not limited to, compressed gases, adhesives, aerosol cans, sealants, paints, lubricants, solvents, oils, cleaners, degreasers and pesticides) be used ____ Submit TAFB Form 81 (Contractor Questionnaire) and TAFB Form 82 (Chemical Inventory) 7-10 days upon issuance of the notice to proceed and prior commencement of work on site.

____ Submit copies of manufacturer-specific Material Safety Data Sheets ____ Submit TAFB Form 83 (Reporting Entry Form) at the end of the project or as indicated by CEV.

____ Notify CEV if anything changes from the original submittal (i.e. new chemical is added, size of container or unit of issue changes or if the manufacturer changes).

_ _ Will not use chemicals

5. Air Pollutants

Reviewed By: _____________________ __ Will not be generated by the operation or construction of this facility.

__ Will be generated by the operation or construction of this facility. Describe type and amount of substance expected to be generated, existing control systems, and the need for additional controls.

X__ Conformity determination not required.

__ Conformity determination required.

6. Solid and Hazardous Wastes

Reviewed By: _______________________ X _Facility will not be used for generating/managing solid and/or hazardous wastes.

__ Facility will be for generating/managing solid and/or hazardous waste.

_Yes Will the work being performed on the project generate any wastes?

7. Storage Tanks (Check all that apply)

Reviewed By: _____________________ _X_ No storage tanks are involved.

__ New storage tanks will be installed.

__ Material to be stored, quantity ____________.

__ Existing tanks on the project will be relocated. Ensure regulatory agency has been notified.

__ Contamination exists.

__ Contamination unknown.

__ Existing tanks on projects it will be retained.

1. Environmental Impact Analysis Process

_X_ Categorical exclusion number _A2.3.11______ __________ applies.

__ Environmental Assessment under preparation. Expected completion date is __________.

__ Finding of No Significant Environmental Impact signed on __________.

__ Draft Environmental Impact Statement (EIS) under preparation. Expected completion date is ________. __ Draft EIS filed on ___________.

__ Final EIS filed on ___________.

__ Record of Decision signed on __________.

__ Foreign nation or protected global resource exemption number ___________ applies.

__ Environmental study (or review underway) under preparation. Expected completion date is __ Environmental study (or review) completed on ___________.

2. Interagency and Intergovernmental Coordination for Environmental Planning

Reviewed By: _______ewallace______________ X__ Coordination of proposed project with the state Single Point of Contact or other agencies is not required.

__ Coordination with the state Single Point of Contact is in progress. Expected date of completion is __ Proposed project was coordinated with the state Single Point of Contact or other agencies on _

3. Environmental Permits

Reviewed By: ____ewallace_________________ _ No permits are required unless dewatering is needed.

__ No permits required but regulatory agency notification required prior to construction (e.g.

underground storage tank removals).

X Permits may be required for this project.

1. Environmental Restoration Program (ERP)/Petroleum Contamination (PCA)

__ Facility is not sited on or near an ERP/PCA site.

__ Facility is sited near an ERP/PCA site.

_X_ Facility is within the boundary of an IRP/PCA site ERP Guidelines must be followed.

__ The following activities must be coordinated with the IRP Manager:

excavation, sampling, and 40 hour H&S training.

__ The site is projected to be remediated and/or closed out on _________, prior to commencement of construction activities.

__ The nature of the site contamination does not preclude the type of construction activity proposed.

__ There is a Compliance Agreement associated with this site.

__ A Remedial Investigation/Feasibility Study was completed on _______ to accurately delineate the aerial extent of the contamination.

14. Comments

RON DESANTIS

Governor

LAUREL M. LEE

Secretary of State

Division of Historical Resources

R.A. Gray Building • 500 South Bronough Street• Tallahassee, Florida 32399

850.245.6300 • 850.245.6436 (Fax) • FLHeritage.com

Mr. José J. Cintron June 3, 2020 Chief, Environmental Element 325th Civil Engineer Squadron 540 Mississippi Avenue, Mail Stop 42 Tyndall Air Force Base, Florida 32403-5014

Re: DHR Project No.: 2020-3177 – Received by DHR on May 29, 2020

Proposed Construction of Air Defense Council Building Tyndall Air Force Base, Bay County

Dear Mr. Cintron:

This office reviewed the referenced project for possible impact to historic properties listed, or eligible for listing, in the National Register of Historic Places. The review was conducted in accordance with Section 106 of the National Historic Preservation Act of 1966, as amended and 36 CFR Part 800: Protection of Historic Properties.

We note that Facility 1287 (BY1150) is within the project site. However, this office previously determined that it did not appear to meet the criteria for listing in the National Register. Therefore, based on the information provided and the conditions outlined in your letter concerning fortuitous finds or unexpected archaeological discoveries, it is the opinion of this office that the proposed undertaking will have no effect on historic properties.

If you have any questions concerning our comments, please contact Scott Edwards, Historic Preservationist, by electronic mail scott.edwards@dos.myflorida.com, or at 850.245.6333 or 800.847.7278.

Sincerely, Timothy A. Parsons, Ph.D.

Director, Division of Historical Resources and State Historic Preservation Officer

Site Diagram - ADC, B1287

Facility

Main Water Line

Sewer Line

Impact Area

Sidewalk

Area Defense Counsel October 22, 2019 0 25 5012.5 ft

0 8 164 m

1:282

*Location estimates are based on satellite imagery

Electrical Utilities

Transformer

Environmental Restoration Program Guidelines

Work on Environmental Restoration Program Site FR038 – ADC B1287

19 June 2020

The project to Demolish and Rebuild Area Defense Council B1287 is within the boundary of Environmental Restoration Program (ERP) Site FR038, undergoing a contamination study. Contaminants affecting the project area include metals (lead, antimony, arsenic) in the soil and shallow groundwater of the project boundary. There are no known PFOS/PFOA spill sites in the project area.

Projects within ERP study areas shall be conducted within the following guidelines. To the extent these guidelines conflict with provisions contained within the contract, Statement of Work, or approved work plans, those documents control.

1. It is the responsibility of the contractor to fulfill its obligation under 29 CFR 1910.120, Occupational Safety and Health Administration Standards, Hazardous Waste Operations and Emergency Response, and address the health and safety of its employees associated with construction activities relative to this project.

2. Contaminated soil from excavation or construction activities may be temporarily moved within the ERP study area, as long as it is subsequently redeposited in the same excavated area. Soils should be staged on visqueen and shall not leave that ERP study area. Best management practices shall be utilized to prevent spreading contamination into previously uncontaminated or less contaminated areas within the ERP study area. If soils are to be removed for disposal from the site, they shall be tested prior to disposal or reuse.

3. For disposal, waste soils must be tested utilizing the TCLP and the results provided to

AFCEC/CZOE and the 325 CES Hazardous Waste Program Manager prior to any transportation for proper disposal at an authorized disposal facility or may be conservatively handled as hazardous waste in accordance with appropriate hazardous waste laws and regulations if approved by AFCEC/CZOE and the 325 CES Hazardous Waste Program Manager or required by the contract or statement of work. Copies of transportation and disposal documents (profiles, manifests, bills of lading) must be provided to AFCEC/CZOE and the 325 CES Hazardous Waste Program Manager. The contractor is responsible for the sampling, profiling, proper handling, and disposal of any contaminated media. Utilize the services of a qualified environmental professional for sampling and testing.

4. In order to remove soils from an ERP study area (from an area within the study area, but not known to be contaminated) and reuse those soils as fill in an area other than same excavated area from which the soils were removed, soils should be staged in stockpiles of 400 CY, and sampled and analyzed for the same parameters identified in Section 7 below. One composite sample of eight aliquots will be collected from each 400 CY stockpile. Analytical results will be compared to the FDEP residential Soil Cleanup Target Levels to determine acceptability of the proposed material for reuse anywhere on base. Analytical results will be compared to the FDEP industrial Soil Cleanup Target Levels to determine acceptability of the proposed material for reuse along the flightline. Utilize the services of a qualified environmental professional for sampling and testing.

5. Documentation of any sampling and testing results, contaminated soil excavation volumes/depths/delineation, and reuse or disposal actions should be provided in a summary report to AFCEC/CZOE and 325 CES/CEIEC.

6. Construction activities shall avoid damaging or disturbing any monitoring wells (and shall protect wells from the introduction of contaminants (mud/dirt or PVC glue introduced/caps or plugs removed/risers compromised)) that may be located in the construction area. Cost to sample, repair and/or replace damaged wells, as a result of construction, shall be incurred by the construction project. If wells must be eliminated, they shall be abandoned properly (and/or replacements installed) and surveyed by a Florida licensed water well driller. Monitoring well abandonment or installation documentation shall be provided to AFCEC/CZOE. Placement of replacement wells will require coordination with EPA, FDEP, and AFCEC/CZOE.

7. Any soils brought on-site and used for backfill should be properly tested or certified clean

(with appropriate documentation) to ensure that no contaminants are being applied on-site.

The source of backfill should be natural or virgin material (other than the operation of a borrow pit facility) and should be in an area which has not previously been used for commercial or industrial activities. If the soils to be used for backfill are not certified clean with appropriate documentation, testing of the soils shall be required and must include at least one (1) soil sample collected from the borrow source and analyzed for the following parameters:

- Volatile Organic Compounds (VOCs) per Method 8260

- Semi-volatile Organic Compounds (SVOCs) [Base/Neutrals (e.g., PAHs, Pesticides, PCBs) and Acid Extractables (e.g., Phenols)] per Methods 8270/8081/8082

- RCRA metals by Method 6020

- Petroleum Residual Organics (by FL-PRO)

Analytical results will be compared to the FDEP residential Soil Cleanup Target Levels to determine acceptability of the proposed material as clean fill.

8. Contractors must be made aware of the appropriate procedures if any contamination is encountered (i.e. suspicious odors, fuel smells, soil staining, odd soil colors, unfamiliar liquids, buried materials, etc.) at the site. If these conditions are encountered, AFCEC/CZOE and 325 CES/CEIEC must be contacted. If discovered, these soils should be separated, stockpiled on, and covered with visqueen until properly tested/disposed.

9. If dewatering is required, the contractor must be prepared to address permitting, handling, storage, characterization, treatment, and disposal of any potentially contaminated dewatering effluent. Dewatering within a groundwater plume may be allowed as long as effluent is allowed to percolate back into the known plume areas (if available).

10. Any equipment that comes in contact with contaminated soils or groundwater shall be properly decontaminated before mobilizing off-site. Any decontaminated fluids must be collected and stored in 55-gallon drums, properly labeled and stored in the manner and not to exceed the time requirements of RCRA and applicable laws on pallets on site until sampled, tested, and disposed of at a proper disposal facility.

11. Any PFOA/PFOS waste shall be handled in accordance with Air Force Guidance Memorandum 2019-32-01 (Air Force Guidance Memorandum Establishing Aqueous Film Forming Foam [AFFF]-Related Waste Management Implementation Guidance).

Metal Exceedances in Surface Soil

Groundwater Exceedances