Attachment_42 _Environmental_Program.pdf

Training Delivery Services

Attachment 42

CDP Environmental and Sustainability Program

Foreword

This Manual provides guidance and policy direction for the administration, implementation, and oversight of the Center for Domestic Preparedness (CDP) Environmental and Sustainability Management System (ESMS) Program.

Table of Contents

CHAPTER 1: GENERAL INFORMATION

1-1. Purpose

1-2. Applicability and Scope

1-3. Supersession

1-4. Authorities/ References

1-5. Policy

1-6. Definitions

1-7. Responsibilities

1-8. Reporting Requirement

1-9. Forms Prescribed

1-10. Questions

CHAPTER 2: PROCEDURES

2-1. Environmental Planning

2-2. Environmental Compliance Program

2-3. Sustainable Practices

2-4. Strategic Planning

Annex A-1: National Environmental Policy Act (NEPA)

A-1.1 Review Requirements

A-1.2 Action Requirements

Annex B-1: Above Ground Storage Tanks (AST)

B-1.1 Environmental Aspect

B-1.2 Human Health, Environmental, and Economic Impacts and Risk . 13

B-1.3 Controls

B-1.4 Applicable Regulations

Annex B-2: Air Quality Management

B-2.1 Environmental Aspect

B-2.2 Human Health, Environmental, and Economic Impacts and Risk . 17

B-2.3 Controls

B-2.4 Applicable Regulations

B-2.5 Table B-2-1 CDP Emergency Generators

Annex B-3: Emergency Planning and Community-Right-To-Know (EPCRA)

B-3.1 Environmental Aspect

B-3.2 Human Health, Environmental, and Economic Impacts

B-3.3 Controls

B-3.4 Applicable Regulations

Annex B-4: Pesticide Management

B-4.1 Environmental Aspect

B-4.2 Human Health, Environmental, and Economic Impacts

B-4.3 Controls

B-4.4 Applicable Regulations

Annex B-5: Spill Prevention, Control, and Countermeasures

B-5.1 Environmental Aspect

B-5.2 Human Health, Environmental, and Economic Impacts

B-5.3 Controls

B-5.4 Applicable Regulations

Annex B-6: Toxic Substances Management for Lead, Asbestos, Radon, and Polychlorinated Biphenyls (PCBs)

B-6.1 Environmental Aspect

B-6.2 Human Health, Environmental, and Economic Impacts

B-6.3 Controls

B-6.4 Applicable Regulations

Annex B-7: UST (Underground Storage Tanks)

B-7.1 Environmental Aspect

B-7.2 Human Health, Environmental, and Economic Impacts

B-7.3 Controls

B-7.4 Applicable Regulations

Annex B-8: Waste Management

B-8.1 Environmental Aspect

B-8.2 Human Health, Environmental, and Economic Impacts

B-8.3 Controls

B-8.4 Applicable Regulations

Annex B-9: Water Quality (Wastewater, Storm Water, and Drinking Water)

B-9.1 Environmental Aspect

B-9.2 Human Health, Environmental, and Economic Impacts

B-9.3 Controls

B-9.4 Applicable Regulations

Annex B-10: Cultural and Natural Resources

B-10.1 Environmental Aspect

B-10.2 Human Health, Environmental, and Economic Impacts

B-10.3 Controls

B-10.4 Applicable Regulations

Annex B-11: Environmental Site Assessments

B-11.1 This annex contains

B-11.2 The CDP is located

B-11.3 The parcels that indicated the potential for contamination

B-11.4 The EBS

B-11.5 Contents of the Administrative Record

B-11.6 Copies of key documents

B-11.7 Table B-11-1

Annex C-1: Environmental Sustainability and Management System (ESMS)

C-1.1 Background

C-1.2 ESMS Program Elements

Annex C-2: Sustainability – Greenhouse Gas Emissions, High Performance Sustainable Design, Water Usage, Pollution Prevention, and Waste Minimization

C-2.1 Reserved

Annex C-3: Sustainability - Green Procurement, Electronic Stewardship, Disaster Operations

C-3.1 Reserved

Annex D-1: COBRATF Agent Contaminated Media and Items

D-1.1 See COBRATF Toxic Agent Exposure Control Plan

Annex E-1: ESMS Five (5)-Year Strategic Plan

E-1.1 Table E-1-1 ESMS Program 5-year Strategic Plan

CHAPTER 1: GENERAL INFORMATION

1-1. Purpose

The purpose of this program is to provide implementing guidance to meet the stated Center for Domestic Preparedness (CDP) policies outlined below.

1-2. Applicability and Scope This Manual applies to all CDP employees, contractors, and visitors.

1-3. Supersession Not applicable – original promulgation.

1-4. Authorities/ References A. NEPA (National Environmental Policy Act) as implemented by 40 CFR

Parts 1500-15081 B. DHS MD 023-1 Environmental Planning Program C. DHS MD 023-02 Environmental Management Program D. DHS MD 025-01 Sustainable Practices E. FEMA FD 108-3 Sustainable Performance and Environmental Management F. 40 CFR (applicable sections) G. Alabama Administrative Code 335-X-x-.xx (Alabama Department of Environmental Management [ADEM/ Divisions 1 thru 17) 1-5. Policy

A. Environmental Planning

1. Stewardship of the air, land, water, and cultural resources is compatible with and complementary to the planning and execution of the CDP mission. Environmental planning processes provide a systematic means of evaluating and fulfilling this aspect of our responsibility. The CDP is cognizant of the impacts of its decisions on cultural resources, soils, forests, rangelands, water and air quality, fish, and wildlife, and other natural resources in the context of terrestrial and aquatic ecosystems.

2. The CDP will employ all practical means consistent with other considerations of national policy to minimize or avoid adverse environmental consequences and attain the goals and objectives stated in the National Environmental Policy Act (NEPA), associated regulations (e.g., 40 CFR Parts 1500-15081), DHS MD 023-1 (Environmental Planning Program), and FEMA FD 108-3.

B. Environmental Compliance Program

1. The CDP will comply with Executive Order (EO) 12088 and all Federal, state, interstate, and local environmental laws as well as all policies and procedures established by the Under Secretary for

Management and the Chief of Administrative Services as required by DHS MD 023-02. Managers shall ensure that all necessary actions are taken for prevention, control, and abatement of environmental pollution with respect to their facilities and activities.

2. Contracting Officer Representatives shall ensure that all contractor operations are conducted in a compliant manner and shall include compliance audits in their routine oversight activities.

C. Sustainable Practices

1. The CDP is committed to developing and implementing programs for sustainable practices to ensure that all operations and necessary actions are carried out in an environmentally, economically, and fiscally sound manner and meet DHS/FEMA goals, targets and objectives. In establishing these goals, objectives and targets, the CDP, where practicable, strives to meet or exceed the sustainable practices, goals, and targets identified for Federal agencies.

2. In order to meet this commitment, CDP shall establish an Environmental and Sustainability Management System (ESMS) consistent with FEMA FD 108-3 and associated FEMA Standard Operating Procedures (SOPs). An Environmental Program manual shall also be developed, implemented, and maintained containing detailed processes and procedures related to the three key aspects listed.

1-6. Definitions A. Contractor – This term will be used to designate any and all prime or sub- contractors performing work for the CDP regardless of the type of work (operations and maintenance, administrative support, logistical support, or training support).

B. SPOC – The CDP Federal employee designated by the Superintendent as the primary Environmental and Sustainability Point of Contact

(SPOC).

C. All other definitions are adopted as stated in the authorities / references listed in Section 1.4 above.

1-7. Responsibilities A. Superintendent is responsible for:

1. Ensuring development of all administrative programs necessary to a) implement DHS and FEMA directives related to Environmental Management and Sustainability; and b) to comply with all applicable Federal, state, and local rules and regulations related to the environment.

2. Appointing a Sustainability Point of Contact (SPOC) and alternate SPOC to develop, implement, and maintain all environmental planning, compliance, and sustainability programs.

B. Director of Business Operations is responsible for:

1. Providing overall management oversight of the environmental and sustainability programs.

2. Ensuring adequate resourcing of approved environmental and sustainability programs.

C. Sustainability Point Of Contact (SPOC) is responsible for:

1. Developing, implementing, maintaining environmental and sustainability programs.

2. Conducting routine audits of environmental and sustainability programs in coordination with the responsible Contracting Officer’s Representative (COR) for that contractor.

3. Ensuring submission of all required environmental regulatory reports or documents on time and accurately by the facility at large or by contractors.

4. Maintaining awareness of current and proposed Federal, state, and local rules, regulations, and other directives related to environmental and sustainability programs.

5. Providing training to managers, supervisors, employees, and CORs on applicable environmental and sustainability requirements.

D. Contracting Officer’s Representatives (CORs) are responsible for:

1. Familiarizing themselves with applicable environmental and sustainability requirements relevant to the contractor operations they oversee through attendance at SPOC provided training.

2. Coordinating with the SPOC to conduct audits of applicable environmental and sustainability programs.

3. Ensuring submission of all required environmental regulatory reports or documents on time and accurately by the contractors, they oversee – including SPOC review prior to submission.

E. FEMA Managers and Supervisors are responsible for:

1. Ensuring their individual operations are conducted in compliance with this document and all referenced requirements.

2. Informing employees under their charge of those requirements.

3. Coordinating with the SPOC on any changes to operations, prior to the change, which might result in changes to the risk to human health, environmental compliance, or sustainability.

4. Identifying opportunities for reducing the environmental risk or improving the sustainability of activities within their work area / area of responsibility.

5. Sustainability program managers (as designated in Annexes C-1 thru C-3) shall perform their assigned responsibilities as outlined therein.

F. Employees are responsible for:

1. Complying with all requirements established by this document and as directed by their manager / supervisor.

2. Reporting any environmental or sustainability issues to their manager

/ supervisor.

3. Identifying opportunities for reducing the environmental risk or improving the sustainability of activities within their work area / area of responsibility.

1-8. Reporting Requirement A. All contractors shall maintain copies of required records and reports per the applicable annex of this document and their contract. These records and reports shall be available to FEMA/DHS representatives as well as Federal, state, and local regulators in a timely manner.

B. All reports mandated by Federal, state, or local regulations shall be submitted on time and complete. Copies of all required regulatory reports will be provided through the contractor COR to the CDP SPOC. To the maximum extent possible all environmental submissions with be reviewed by SPOC or alternate prior to submission.

C. In the event of any actual or potential violations of applicable Federal, State, or CDP environmental rules, regulations, or requirements, the contractor shall notify the COR and the SPOC telephonically immediately but no later than one (1) hour of the finding. The telephonic report will be confirmed with a written report via email or hard copy delivery to the COR and SPOC within 24 hours. In no case shall the contractor make direct contact with external regulatory agencies without prior coordination with the COR and SPOC.

1-9. Forms Prescribed Required forms in support of this Manual are listed in the Annex related to that environmental aspect and impact.

1-10. Questions Questions concerning this document should be directed to the Director of Business Operations at 256-847-2691 or the Sustainability Point of Contact at 256-847-2472.

CHAPTER 2: PROCEDURES

2-1. Environmental Planning

A. In order to provide a systematic means of evaluating the impacts of CDP decisions on the environment (cultural resources, soils, forests, rangelands, water and air quality, fish, and wildlife, and other natural resources in the context of terrestrial and aquatic ecosystems) all activities with potential environmental or sustainability impact will be reviewed in accordance with the procedures established in Annex A.

B. For any operations where the impact may be uncertain, the responsible manager will consult with the SPOC for guidance.

2-2. Environmental Compliance Program A. A review of the environmental aspects and impacts of CDP operations has identified a variety of activities and operations requiring engineering and administrative controls to minimize the environmental impacts. In order to formalize those engineering and administrative controls all operations shall comply with the controls listed in the applicable Annexes to this document.

B. All new operations shall be reviewed by the SPOC or alternate for compliance requirements prior to implementation.

C. All new construction projects shall be reviewed by the SPOC or alternate prior to completion of the engineering work package. No construction shall be initiated until all required permits or licenses have been obtained and copies are on file with the SPOC.

D. Due to the unique operations performed at the Chemical, Ordnance, Biological, and Radiological Training Facility (COBRATF) related to chemical and biological agents, the CDP has established a number of written programs, SOPs, and work instructions to control those operations. The COBRATF’s unique environmental issues are contained in Annex D of this document, the COBRATF document control system, and the ESMS spreadsheet in the CDP Environmental folder on the CDP common drive.

2-3. Sustainable Practices A. Sustainable practices are mandated by executive order and associated

DHS and FEMA management directives. The CDP is committed to meeting those overall goals consistent with the resources provided to that end from higher headquarters. Responsible parties (as outlined in Annexes C-1 thru C-3) shall evaluate their operation in light of these documents.

B. Sustainable goals and objectives shall be captured in the environmental and sustainability 5-year strategic plan.

2-4. Strategic Planning A. It is recognized that environmental planning, compliance, and sustainability efforts require resources (money, time, personnel, etc.). It is also recognized that those resources may fall short of meeting the full set of goals and objectives – either externally or internally imposed. In order to better match resources with requirements a 5-year strategic plan for environmental planning, compliance, and sustainability shall be maintained in accordance with Annex E.

B. Priority for resources shall be as follows:

1. Compliance with existing permits and licenses.

2. NEPA planning review of all new activities and operations or changes to existing operations.

3. Compliance with permitting and licensing requirements associates with approved future operations and facilities.

4. Sustainability improvements required by EO, DHS, or FEMA directives.

5. CDP self-imposed goals and objectives.

Annex A-1: National Environmental Policy Act (NEPA) A-1.1 Review Requirements

The CDP is cognizant of its potential impacts on the environment. As such, the review of all routine and non-routine activities is prudent. Review is also required by NEPA, associated regulations (e.g., 40 CFR Parts 1500-15081), and DHS MD 023-1 (Environmental Planning Program), and FEMA FD 108-3 (Sustainable Performance and Environmental Management).

A-1.2 Action Requirements In order to meet these requirements the following action shall be completed:

A. The Sustainability Point of Contact (SPOC) shall maintain a NEPA master log of all routine and non-routine activities including the date of the review and the result of that review.

B. All reviews will be conducted as outlined in DHS MD 023-1 Environmental Planning Program Figure 1. The initial review will categorize the activity impacts as a Categorical Exclusion (CATEX), Environmental Assessment (EA), or Environmental Impact Statement (EIS). If the activity is classified as a CATEX per Table 1 of DHS MD 23-1 but identified with an asterisk, (meaning a REC - Record of Environmental Consideration is required) then the NEPA log will be supplemented with a Memo for Record (MFR) capturing the REC elements. The REC will be signed by the SPOC and the Director of Business Operations.

C. The review shall be conducted in the planning phase, prior to a final decision that limits the choice of alternatives to satisfy an objective, correct a problem, or address a weakness.

D. In the event the Finding of Suitability to Transfer (FOST), Finding of No Significant Impact (FONSI), Record of Decision (ROD), or other associated findings and documents of the NEPA review require ongoing monitoring or mitigation, the review and associated requirements will be captured or referenced in Annex B-11 Environmental Site Assessments of this Manual.

E. For routine activities, an initial review will be conducted within 90 days of promulgation of this Manual. For non-routine activities (e.g., Engineering Work Packages (EWP), significant changes to existing courses, new course offerings, etc.) the NEPA review will be conducted prior to a final decision that limits choice of alternatives.

Above Ground Storage Tanks (AST) Annex B-1:

B-1.1 Environmental Aspect

CDP has six ASTs:

A. Fuel ASTs

1. Emergency Generator Primary Diesel Fuel Tank (39,500 gal.)

2. Emergency Generator # 1 Day Tank (200 gal.)

3. Emergency Generator # 2 Day Tank (200 gal.)

B. Non-Fuel ASTs

1. Primary Decontamination Wastewater Tank (20,000 gal.)

2. Secondary Decontamination Wastewater Tank (40,000 gal.)

3. Caustic (Sodium Hydroxide) Tank (4,000 gal.)

B-1.2 Human Health, Environmental, and Economic Impacts and Risk All six tanks present the risk of spill from leakage, spillage during fill operations, and overfilling. These spills could result in local soil contamination and if not remediated quickly groundwater or surface water contamination. Given the controls outlined below leakage should be limited to secondary containment so the health, environmental, and economic impact will be minimal. A spill during fill operations of the fuel tank is slightly more probable and is rated as moderate for economic impact due to cleanup costs.

B-1.3 Controls A. The CDP Spill Prevention, Control, and Countermeasure (SPCC) Plan captures the key controls in place to control the health, environmental, and economic impacts associated with these tanks.

B. In addition to the SPCC controls, these six tanks are all located at the COBRATF. They are operated and managed by the Operations and Maintenance (O&M) Contractor. The contract Performance Work Statement (PWS) contains a basic requirement to operate them in accordance with applicable Federal, state, and local rules and regulations. This includes routine preventive maintenance, standard operating procedures, and work instructions – all within the “plan, do, check” International Standards Organization (ISO) structure (contract required). Routine Preventive Maintenance (PM) is captured in the electronic maintenance system (7-I software).

C. Any new ASTs. New tanks will only be installed as part of an approved EWP.

Review of all EWPs shall include NEPA, environmental compliance, and sustainability components by the SPOC or alternate.

D. All contractors shall maintain an appropriately sized spill kit in proximity to any fuel use or refueling area.

B-1.4 Applicable Regulations A. 40 CFR 112 Oil Pollution Prevention B. Alabama Admin Code 335-6-x-.xx. Alabama Department of Environmental

Management (ADEM) Division 6 regulations

Air Quality Management Annex B-2:

Environmental Aspect B-2.1

The primary air quality aspects of CDP operations are as follows:

A. Emergency Generators

The CDP currently has nine emergency generators as listed in Table B-2-1.

These generators are only operated to provide emergency power. They are not operated in a peak shaving mode. Other than emergency operations, they are only run as required by the manufacturer’s maintenance program.

B. COBRATF

1. COBRATF Training Building Filter Banks and Stack. This system provides emission control for all operations conducted inside the Training Building including: agent training bays (VX, GB, B. anthracis dSterne, Ricin A chain); service gallery; agent, biological, and cold laboratories;

air monitoring; ancillary areas (e.g. lobby, mezzanine, locker rooms, safety control, etc.). The system consists of nine sets of filter banks (See Table B-02 – 2) ultimately vented through a common stack. The stack is monitored for both VX and GB agent in accordance with (IAW) the approved air-monitoring plan. Dispersion monitoring was previously conducted.

2. COBRATF Incinerator (pyrolyzer / rich burn furnace). The COBRATF incinerator is operated by the O&M contractor IAW with the Performance Work Statement (PWS) and the Alabama Department of Environmental Management (ADEM) air quality permit (On file with

CDP SPOC).

3. Dispersion monitoring was conducted in 1998 using the EPA SCREEN3 model. Modeling was repeated in 2003 using the ISCST model.

Maximum 1 hour and 24 hour VX and GB agent impact points were calculated using the Allowable Stack Concentration (ASC) and Source Emission Limit (SEL) values for both stacks. Figure 1 below shows these maximum impact points. None of the points exceed the Centers for Disease Control (CDC) General Population Limit (GPL).

C. Boilers

1. Natural gas fired package boilers are located at the building 61, Noble Training Facility (NTF), 900 Area housing, and the COBRATF.

2. Additional boilers may be added as other facilities are renovated.

A complete listing of boilers is on file with the CDP SPOC.

Figure B-2-1 COBRATF Air Dispersion Model maximum impact points

D. Above Ground Storage Tanks

1. See Annex B-01 for a listing of above ground storage tanks.

2. These tanks have limited air emissions during filling and due to incidental off gassing. The fuel tanks are fixed roof tanks so they do not have the air emission control advantage of floating roof tanks.

However, due to their limited size this is not practicable.

E. Vehicle Operations

1. CDP operations include transportation of students to/from area airports as well as between the housing area and the various training venues on the CDP campus. The vehicles are operated by a support contractor. The PWS requires compliance with all applicable Federal, state, and local rules and regulations. Compliance is monitored by the COR. Contractor operated vehicles include buses, shuttles, fifteen passenger vans, and handi-van. Touring bus mileage is typically 1,500 miles per month. Other buses and vehicles typically average less than 100 miles per month. A current inventory, including fuel type, can be accessed from the ESMS spreadsheet in the CDP Environmental folder on the CDP common drive.

2. CDP operations include logistics support activities to move supplies, materials, and equipment to/from the various training venues on the CDP campus. These 14 vehicles are operated by a support contractor. Seven additional vehicles are used as props only for training and are not operated over the road. The PWS requires compliance with all applicable Federal, state, and local rules and regulations. Compliance is monitored by the COR. Vehicles include vans, trucks, ambulances, and utility vehicles.

3. CDP operations include lawn maintenance at the various facilities on the CDP campus. The vehicles are operated by a support contractor.

The PWS requires compliance with all applicable Federal, state, and local rules and regulations. Compliance is monitored by the COR.

Vehicles include trucks, utility vehicles, and mowers.

4. Neither CDP nor its vehicle operations contractors operate a motor pool or other facility for maintenance of the above listed vehicles. All vehicle maintenance is performed at off-site facilities by a third party business not associated with CDP other than a business / customer relationship.

5. Most permanent site personnel (Federal, contractors, and subcontractors) drive their own privately owned vehicle (POV) to and from work. There is limited public transportation in the community.

Human Health, Environmental, and Economic Impacts and Risk B-2.2 A. Emergency Generators

Since these are operated on an O&M and emergency basis only, there is minimal health or environmental impact / risk from their operation. The generators are in place to reduce the economic impact of loss of power causing training interruptions and to maintain emergency systems and COBRATF emission controls. A current inventory of emergency generators can be accessed from the ESMS spreadsheet in the CDP Environmental folder on the CDP common drive.

B. COBRATF Incinerator The incinerator was designed to meet Resource Conservation and Recovery Act (RCRA) hazardous waste standards but was never trial burn tested to demonstrate Destruction Removal Efficiency (DRE). Therefore, the system is only permitted for Municipal Solid Waste (MSW) and limited quantities of Regulated Medical Waste (RMW). It is primarily used to treat potentially agent contaminated materials and regulated medical waste requiring treatment. The incineration process controls risks from these waste streams.

It does create minimal air emission issues but these are controlled by proper operations as outlined in the ADEM operating permit. Inability to operate could result in substantial economic impact from off-site treatment.

C. Boilers All boilers are fueled by natural gas and present minimal air pollution impacts.

D. ASTs The decontamination wastewater has potential health and environmental impact if it were not monitored for agent and other parameters. The fuel tanks have minimal usage other than O&M operations and actual emergency use. Spills could result in localized surface media contamination.

E. Vehicle Operations Vehicles of all types have the potential to emit various hazardous air pollutants. The Calhoun County area is considered an “Attainment” area by the U.S. Environmental Protection Agency – so the aggregate impact of these vehicle operations and associated terrain and other factors does not create a significant health, environmental, or economic impact / risk above background for the community.

Controls B-2.3 A. Emergency Generators

All emergency generators are operated and maintained by the CDP O&M contractors per their respective Performance Work Statement (PWS). The PWS also requires that the O&M contractor comply with all applicable Federal, state, and local regulations and CDP specific requirements. The COR monitors the contract for compliance.

B. COBRATF

1. COBRATF Training Building filter banks and stack. The filter banks include mid-bed MINICAMS monitoring at Short Term Exposure Limit (STEL). The combined stack also includes MINICAMS monitoring. All monitoring is done in compliance with the approved COBRATF air-monitoring plan. The system is operated and maintained by the COBRATF O&M contractor IAW the PWS. The COR monitors the contract for compliance.

2. COBRATF Incinerator The COBRATF incinerator (pyrolyzer / rich burn furnace) operates within the limits of the ADEM issued operating permit. Operating parameters during operation are logged and available for regulatory review. The system is operated and maintained by the COBRATF O&M contractor IAW the PWS. The COR monitors the contract for compliance.

C. Boilers Boilers meet all applicable Federal, state, and local requirements based on their fuel type.

D. Above Ground Storage Tanks

1. All six ASTs (3 fuel and 3 other) are operated and maintained by the

COBRATF O&M contractor IAW the PWS. The COR monitors the contract for compliance. A current inventory of all storage tanks can be accessed from the ESMS spreadsheet in the CDP Environmental folder on the CDP common drive.

2. The tanks are included in the approved SPCC plan (See Annex B-05).

3. All tank operations are conducted IAW written SOPs which include hazard assessments. This process includes monitoring the decontamination wastewater for agent and other environmental parameters.

E. Vehicle Operations

1. All vehicles operated on the roadways comply with Alabama

Department of Public Safety regulations.

2. POVs are required to be registered with security, which includes checking for a valid driver’s license and proof of insurance.

3. Vehicles operated by CDP contractors are maintained IAW manufacturer’s specifications.

Applicable Regulations B-2.4

A. U.S. Department of Transportation (DOT) regulations B. U.S. Environmental Protection Agency (EPA) regulations C. Alabama Admin Code 335-3-XX.XX ADEM Air Division regulations D. Vehicle Manufacturer’s O&M manual

Table B-2-1 CDP Emergency Generators B-2.5

Item No. Location Make Model ID No Serial No. KW In-Service

Date Primary

Fuel

1 Bldg. 294 Gen 1 Caterpillar CAT D379 176229231 68B4317 438 9/28/1978 Diesel

2 Bldg. 294 Gen 2 Caterpillar CAT D379 276229231 68B4318 438 9/28/1978 Diesel

3 COBRATF -

Backup

Caterpillar CAT 3512 24Z01067 600 1986 Diesel

4 COBRATF -

Primary

Caterpillar 5408HEDET 9EP03368 600 2004 Diesel

5 Bldg. 61 Baldor GLC80 M05D075248-4 80 4/22/2005 Natural Gas

6 Bldg. 19 GENERAC QT15068GNSN 4927583 4927583 100 12/3/2007 Natural Gas

7 Bldg. 21 GENERAC QT10068GNAN 4455760 4455760 100 12/13/2007 Natural Gas

8 Bldg. 17 GENERAC SG300 2096303 2096303 300 2/8/2008 Natural Gas

9 Bldg. 61/77 Blood Lab

GENERAC 0058700 6384422 8 8/15/2011 Natural Gas

Emergency Planning and Community-Right-To-Know Annex B-3:

(EPCRA)

B-3.1 Environmental Aspect CDP has no Extremely Hazardous Substances (EHS) or Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) hazardous substances above reportable quantities requiring reporting or release notification under Section 304. The CDP does not have any ongoing releases requiring reporting under the toxic release inventory program outlined in Section 313. The CDP does have some Occupational Safety and Health Agency (OSHA) hazardous chemicals totaling over 10,000 pounds – which require reporting under sections 311 and 312. Material Safety Data Sheets (MSDSs - now Safety Data Sheets [SDSs]) are maintained for all OSHA hazardous chemicals IAW both 29 CFR 1910.1200 and 40 CFR 311 / 312. See most recent Tier II report (on file with CDP SPOC).

B-3.2 Human Health, Environmental, and Economic Impacts Failure to identify and aggregate to combined quantity of hazardous chemicals could result in inadequate emergency response preparedness and response capability. Failure to submit required EPCRA reports could result in fines associated with non-compliance.

B-3.3 Controls A. All EHS and OSHA hazardous chemicals are reported to the SPOC based on a query from the SPOC and historical knowledge of chemicals stored.

B. The SPOC queries all contractors during January of each calendar year for an inventory report. These reports are aggregated to determine which chemicals require reporting.

C. Any new chemical, which is either an EHS or OSHA hazardous chemical, is evaluated to determine if the quantity requires initial reporting or inclusion on the annual EPCRA reporting.

D. The SPOC prepares the annual Superfund Amendments and Reauthorization Act (SARA) Tier II report for signature by the Director of Business Operations No Later Than (NLT) 15 February of each calendar year. The signed forms (or electronic submissions) are then sent to the State Emergency Response Commission (SERC), Local Emergency Committee (LEPC), and Anniston Fire Department to arrive prior to the required submission date (1 March of each calendar year for the previous year).

B-3.4 Applicable Regulations U.S. EPA regulations - 40 CFR 304, 311, 312, 313

Pesticide Management Annex B-4:

B-4.1 Environmental Aspect

As part of our grounds maintenance operations various insecticides, fungicides, and rodenticides are used to control these hazards. No restricted-use pesticides under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) are currently in use or are planned to for use at the CDP.

B-4.2 Human Health, Environmental, and Economic Impacts The human health and environmental impacts of the individual insecticides, fungicides, or rodenticides are outlined on the MSDS / SDS. Use by qualified applicators at specified application rates poses a minimal hazard to human health and the environment. These items are only used to control the economic impact of the targeted pests.

B-4.3 Controls A. Insecticides, fungicides, and rodenticides are only used on an as-needed basis, only for the duration, and at the location requiring pest control.

B. All applications are conducted under the management of an appropriately qualified applicator at the required strength and application rate.

C. All pesticide activities are conducted by the CDP grounds maintenance contract per the PWS IAW all applicable Federal, state, and local rules and regulations. Use includes application either by or under the direct supervision of a state certified applicator. The COR monitors contract compliance.

B-4.4 Applicable Regulations A. Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) B. U.S. EPA regulations - 40 CFR Parts 150 – 189

Spill Prevention, Control, and Countermeasures Annex B-5:

(SPCC)

B-5.1 Environmental Aspect CDP has six ASTs as listed in Annex B-1. The SPCC is a required part of mitigation for spills associated with those tanks.

B-5.2 Human Health, Environmental, and Economic Impacts A release of petroleum or other chemical to the environment could result in both human health and environmental impacts in addition to the cost of cleanup.

B-5.3 Controls A. A compliant SPCC will be developed to include all required elements outlined in 40 CFR Parr 112. (Current copy on file with CDP SPOC and can also be accessed from the ESMS spreadsheet in the CDP Environmental folder on the CDP common drive.)

B. The SPCC will be reviewed and updated as needed but at least every three

(3) years.

C. Any new ASTs or other applicable facilities will added to the SPCC prior to final commissioning and use of the AST/facility.

B-5.4 Applicable Regulations U.S. EPA regulations - 40 CFR 112

Toxic Substances Management for Lead, Asbestos, Annex B-6:

Radon, and Polychlorinated Biphenyls (PCBs)

B-6.1 Environmental Aspect A. Lead and Asbestos

As part of the Army Environmental Baseline Survey (EBS) and Finding of Suitability to Transfer (FOST) evaluations, lead and asbestos data from all buildings was obtained. Most CDP buildings contained at least some asbestos (typically floor tile and some pipe insulation). Some buildings contained lead base paint (primarily associated with trim and doorways. As a result of these findings, all facility projects will be reviewed during the development of the Engineering Work Package (EWP) and a determination made regarding any required remedial action or other controls. If there is uncertainty as to the nature and extent of contamination then an additional survey is conducted to confirm or deny the presence of lead or asbestos as appropriate.

B. Radon To date no radon surveys have been completed.

C. PCBs PCBs were historically found primarily in transformers and light ballasts.

Over the past 10 years as PCB, ballasts have been discovered they have been removed and disposed of IAW applicable regulations. At this time, there are no known remaining PCB ballasts. In 2013, a survey of all CDP owned transformers was conducted. No PCB transformers were identified during that assessment.

B-6.2 Human Health, Environmental, and Economic Impacts A. Lead and Asbestos

The primary lead hazard is due to consumption by children. Since there are no child care or child housing facilities this is a minimal hazard. The primary hazard then is due to inhalation during a remodeling project. Friable asbestos presents a health hazard in the form of asbestosis and other respiratory disease.

B. Radon Radon (if present) can present a cancer risk due to the emitted ionizing radiation.

C. PCBs PCBs may contain carcinogenic components. Given that any remaining PCBs are likely in a limited number of light ballast, they are only a hazard is they fail and exposure personnel during replacement.

B-6.3 Controls A. Lead and Asbestos

The Army EBS and FOST documents are used as an initial screening for these toxics. If the EBS, FOST, or a site walkthrough by safety personnel indicates the potential presence of these hazards then a survey is completed to confirm or deny presence. If lead or asbestos is identified through the records review or sampling then a remedial project is initiated to remove it.

B. Radon No radon controls have been implemented.

C. PCBs PCBs have been removed to the extent possible. If a ballast or transformer is located then the date of manufacture is used to make an initial PCB determination IAW 40 CFR 761.

B-6.4 Applicable Regulations A. Toxic Substances Control Act (TSCA) B. U.S. EPA regulations:

1. 40 CFR 745 Lead-Based Paint Poisoning Prevention

2. 40 CFR 761 Polychlorinated Biphenyls (PCBs)

3. 40 CFR 763 Asbestos

C. OSHA regulations:

1. 29 CFR 1910.1001 Asbestos

2. 29 CFR 1910.1025 Lead

3. 29 CFR 1926.62 Lead

4. 29 CFR 1926.1101 Lead

D. Alabama Admin Code 335-13-4-XX ADEM land disposal of asbestos containing materials and lead-based paint.

UST (Underground Storage Tanks) Annex B-7:

B-7.1 Environmental Aspect

A. CDP has a single 8,000 gallon diesel fuel tank. The tank is registered with the Alabama Department of Environmental Management (Tank ID No.

051281). The tank is routinely inspected by the O&M contractor and by ADEM personnel.

B. Any future USTs will be added to the master inventory (on file with the

CDP SPOC).

B-7.2 Human Health, Environmental, and Economic Impacts A release because of leakage or spill during fill operations could result in soil contamination requiring remediation. This would have economic impact due to cleanup / disposal of waste costs.

B-7.3 Controls The UST is operated and maintained by the CDP O&M contractor IAW the PWS, which requires compliance with all applicable Federal, state, and local rules and regulations. The COR monitors the contract for compliance.

B-7.4 Applicable Regulations A. U.S. EPA regulations – 40 CFR 280 B. Alabama Admin Code 335-6-x-.xx ADEM Water Division regulations

Waste Management Annex B-8:

B-8.1 Environmental Aspect

CDP operations generate a variety of solid waste to include the following:

A. Municipal solid waste – commonly called trash, garbage, refuse, or rubbish.

B. Recyclable material: paper, glass, cans, etc.

C. Inert waste – Construction and Demolition (C&D) waste, dirt, rocks, debris.

D. Electrical and electronic waste – computers, monitors, TVs, etc.

E. Hazardous waste – RCRA regulated characteristics or listed waste.

F. Toxic waste – FIFRA or TSCA regulated waste.

G. Medical waste – ADEM regulated medical waste.

H. Universal waste – batteries, pesticides, mercury-containing equipment, and bulbs (lamps).

B-8.2 Human Health, Environmental, and Economic Impacts

A range of human health, environmental, and economic impacts are associated with each type of waste stream listed above. Improper collection, storage, handlings, treatment, or disposal can result in adverse health effects to workers handing the material, contamination of air, water, or soil; and economic impact due to clean up costs or fines for improper disposal.

B-8.3 Controls All wastes are managed by our various contractors who generate that type of waste. The PWS requires compliance with all applicable Federal, state, and local rules and regulations. Compliance is monitored by the COR. The CDP Waste Management Plan provides a consistent basis for properly classifying all waste and managing it in a compliant manner. Wastes generally fall into one of the following types.

A. Municipal solid waste – commonly called MSW, trash, garbage, refuse, or rubbish. MSW is collected throughout the campus and disposed of at the ADEM permitted Calhoun County Landfill. The facility includes a C&D area and is authorized to accept asbestos waste.

B. Recyclable material: paper, glass, cans, etc. The O&M contractor supports a minimal recycling program with bins in most office areas for aluminum can and plastic bottle recycling. Currently no paper recycling program is being conducted.

C. Inert waste – C&D waste, dirt, rocks, debris. In addition to the Calhoun County Landfill, the McClellan Development Authority (MDA) operates an industrial landfill located on the former Fort McClellan. CDP has access to this facility for disposal of non-hazardous industrial wastes and C&D wastes including tires, trees, tree limbs, packing and crating debris, and asbestos.

Asbestos abatement project wastes have gone to the Calhoun County

Landfill not the MDA Landfill.

D. Electrical and electronic waste – computers, monitors, TVs, etc. Outdated but functional electronic waste is wiped clean of all data and donated to area schools. Items that are no longer functional are transported to UNICOR at the Federal prison in Atlanta, Georgia for recycling.

E. Hazardous waste – RCRA regulated characteristics or listed waste.

1. CDP has historically been a conditionally exempt small quantity generator (CESQG) under Federal and state regulations. As such, no EPA ID number was required. However, due to the recent finding that a batch of our COBRATF decontamination wastewater was a RCRA hazardous waste we are now a Large Quantity Generator (LQG). The CDP EPA identification number is AL000057174.

2. COBRATF consistently generates two RCRA hazardous waste streams: a) mercury cyanide waste (D001, D003, D009) reagent from the M256 chemical agent test kit, and b) silver fluoride (D011) from MINICAMs V-G conversion pads. On occasion the decontamination wastewater may contain chloroform at levels above the Toxicity Characteristic Leachate Procedure limit of 6.0 mg/L. When this occurs this waste stream is a RCRA hazardous waste (D022). All waste streams are managed by the O&M contractor in accordance with the PWS and all applicable Federal, state, and local requirements. The COR monitors the contractor for compliance with the PWS and applicable requirements.

3. The COBRATF incinerator is not authorized to treat any RCRA hazardous waste; therefore all waste streams are evaluated prior to treatment for applicable characteristic or listed waste codes.

F. Toxic waste – TSCA regulated waste. Currently no ongoing TSCA regulated waste is being generated. When lead, asbestos, or PCB remedial projects are conducted the PWS requires the contractor performing the work to dispose of the waste IAW all applicable Federal, state, and local requirements. The COR monitors the contractor for compliance with the PWS and applicable requirements.

G. Medical waste – ADEM regulated medical waste. CDP generates ADEM regulated medical waste at various locations including the RBC Cholinesterase laboratory and emergency treatment locations operated by our medical support contractor. The PWS requires the contractor generating, transporting, storing, or handling the waste to do so IAW all applicable Federal, state, and local requirements. The COR monitors the contractor for compliance with the PWS and applicable regulatory requirements. To further control this waste stream a Regulated Medical Waste Management Plan and SOP have been developed (on file with CDP SPOC and also available from the ESMS spreadsheet in the CDP Environmental folder on the CDP common drive).

H. Universal waste – batteries, pesticides, mercury-containing equipment, and bulbs (lamps). Universal wastes are collected and managed by our O&M contractors. These streams are managed by the O&M contractor in accordance with the PWS and all applicable Federal, state, and local requirements. The COR monitors the contractor for compliance with the PWS and applicable regulatory requirements.

B-8.4 Applicable Regulations A. U.S. EPA regulations – 40 CFR various subparts B. Alabama Admin Code 335-13-x-.xx Solid Waste Management C. Alabama Admin Code 335-14-x-.xx Hazardous Waste Management D. Alabama Admin Code 335-17-x-.xx Medical Waste Management

Water Quality (Wastewater, Storm Water, and Drinking Annex B-9:

Water)

B-9.1 Environmental Aspect A. CDP operations utilize potable water from the City of Anniston and generate wastewater from that use. There is storm water runoff from parking lots and other facilities. CDP does not have a NPDES storm water discharge permit. All sewer and storm water lines are owned and managed by the Anniston Water Works and Sewer Board (AWWSB).

B. Some projects involving surface disturbance require a storm water permit from the State of Alabama ADEM. This requirement is determined during project development and included in the PWS as needed. CDP does not have any areas currently identified, which meet the definition of “industrial activities” under EPA guidelines.

C. The COBRATF has applied for a State Indirect Discharge (SID) permit.

If approved by ADEM, this discharge will be primarily composed of decontamination wastewater from the COBRATF training building.

B-9.2 Human Health, Environmental, and Economic Impacts A. Excess water usage can result in resource depletion and usage limitation by the City of Anniston. No human health hazards exist from the potable water supply for the City of Anniston, which is regulated by ADEM. Water is an ongoing expense to CDP.

B. Water is a natural resource and requires conservation and management.

CDP is in the process of individually metering all facilities to better understand water usage and implement conservation measures.

B-9.3 Controls A. All Engineering Work Packages (EWPs) are reviewed for both NEPA and environmental compliance issues. If a NEPA or compliance (e.g., storm water permitting) requirement is identified then that is addressed prior to final option selection or by inclusion of specific requirements in the contract

PWS.

B. All discharges to the publicly owned treatment works (POTW) are compliant with the AWWSB promulgated standards.

C. The COBRATF SID permit will control the discharge of this wastewater stream.

B-9.4 Applicable Regulations A. U.S. EPA regulations - 40 CFR 122 B. Alabama Admin Code 335-6-XX ADEM Water Division regulations

Cultural and Natural Resources Annex B-10:

B-10.1 Environmental Aspect

A. Cultural Resources No current CDP facilities have been identified by the State Historic Preservation Office (SHPO) as historic buildings.

B. Natural Resources The following table lists threatened or endangered species located within Calhoun County, AL.

C. Table B-10-1 Threatened or Endangered (T&E) Species listed as known or suspected to be present in Calhoun County, AL.

Status Species Type

E Acorn shell, southern (Epioblasma othcaloogensis) Animal

E Bat, gray Entire (Myotis grisescens) Animal

E Bat, Indiana Entire (Myotis sodalis) Animal

E Clubshell, ovate (Pleurobema perovatum) Animal

E Clubshell, southern (Pleurobema decisum) Animal

E Combshell, upland (Epioblasma metastriata) Animal

E Kidneyshell, triangular (Ptychobranchus greenii) Animal

E Moccasinshell, Coosa (Medionidus parvulus) Animal

E Pigtoe, southern (Pleurobema georgianum) Animal

T Pocketbook, finelined (Lampsilis altilis) Animal

T Rocksnail, painted Entire (Leptoxis taeniata) Animal

T Sculpin, pygmy Entire (Cottus paulus (=pygmaeus)) Animal

T Shiner, blue Entire (Cyprinella caerulea) Animal

E Woodpecker, red-cockaded Entire (Picoides borealis) Animal

T Mohr's Barbara Button (Marshallia mohrii) Plant

E Tennessee yellow-eyed Grass (Xyris tennesseensis) Plant

E Green Pitcher-plant (Sarracenia oreophila) Plant

B-10.2 Human Health, Environmental, and Economic Impacts No human health impact, potential environmental or economic impact from habitat or actual animal / plant damage.

B-10.3 Controls

A. Cultural, prior to any building demolition or major remodel, CDP contacts SHPO to check on any change in status of the subject building.

B. Natural Resources, ground maintenance and key facilities personnel will be briefed on T&E species. Areas to be cleared will be surveyed prior to work for T&E species. All EWPs are reviewed for NEPA compliance prior to final development. If a cultural or natural resource issue is identified then appropriate actions are taken to eliminate or mitigate adverse impacts.

B-10.4 Applicable Regulations A. National Historic Preservation Act B. Endangered Species Act C. National Environmental Policy Act

Environmental Site Assessments Annex B-11:

B-11.1 This annex contains a chronological listing of all CDP property and facilities including the environmental assessment associate with each land parcel or facility (e.g., FOST, Phase I ESA, etc.)

B-11.2 The CDP is located within the boundaries of the former Fort McClellan (FTMC) military base. The base was closed under the Base Realignment and Closure Act. As part of that activity, a formal Environmental Baseline Study (EBS) was completed in 1998.

The EBS characterized the Community Environmental Response Facilitation Act (CERFA) land parcels into several categories based on a review of historical use and visual site investigations. Some parcels were identified as “clean” and eligible for immediate transfer using a FOST or Finding of Suitability to Lease (FOSL).

B-11.3 The parcels that indicated the potential for contamination were grouped into one of seven standard Department of Defense (DOD) categories. Sites within each category were then investigated to determine the level of potential contamination and any required remedial actions. Ultimately, some type of Decision Document (DD) was prepared and approved for each location.

B-11.4 The EBS and all other documents associated with the administrative record for FTMC can be found on the Transition Force website URL:

http://www.mcclellan.army.mil/AdminRec.asp

B-11.5 Contents of the Administrative Record include a variety of written material, such as pieces of correspondence, data reports, assessments, plans, newspaper articles, notices, and fact sheets.