Luke AFB Environmental Guide for Contractors_July2022.pdf

56th Civil Engineer Squadron

Environmental Management Office 13970 Gillespie Drive Luke AFB, AZ 85707

(623) 856-3832

Luke AFB Environmental Guide for Contractors

July 2022

Environmental Guide for Contractors July 2022

Table of Contents

Part 1 Obligations Part 2 Responsibilities Part 3 Common Environmental Requirements and Contractor Responsibilities

3.1 Before Construction/Performance/Demolition/Repair

3.2 During Construction/Performance/Demolition/Repair

3.3 After Construction/Performance/Demolition/Repair

Part 4 Environmental Points of Contact

Appendices Appendix A Guidance for Reporting HAZMAT Usage

B Hazardous & Universal Waste Management and Disposal C Environmental Management System Awareness Level Training

Attachments Attachment 1 Dust Control Methods

2 Stormwater Pollution Prevention at Construction Sites 3 Contractor Awareness Training Roster

Part 1 – Obligations

1.1. As a contractor, you are obligated to comply with federal, state, and local environmental regulations, and Luke AFB Environmental Management System (EMS) requirements. Some of the environmental issues to be considered while completing your job at Luke AFB include:

• Hazardous Material usage & management;

• Recovered Materials usage;

• Dust control from activities such as earthmoving, trenching, concrete cutting, etc.;

• Air emissions control from painting or cleaning operations ;

• Stormwater Discharges;

• Construction & Demolition Debris recycling/disposal;

• Waste management;

• Protection of native plants;

• Protection of migratory birds;

• Protection of cultural resources;

• Influence on the installations EMS environmental aspects (Appendix C); and

• Asbestos containing material and lead-based paint.

1.2. As the prime contractor, you are also obligated to ensure all subcontractors also adhere to environmental regulations.

Part 2 – Responsibilities

2.1. Contractors, subcontractors and vendors are responsible for environmental protection while in the process of executing contracts on Luke AFB involving, but not limited to:

• New Construction;

• Renovations and major repairs on existing structures or systems;

• Demolition/removal of old structures or systems; and

• Performance of contract maintenance or services.

2.2. Environmental regulations will be complied with by all contractors, subcontractors, and vendors.

2.3. Pre-work conference: The prime contractor will brief employees and/or subcontractors on environmental regulations and policies as applicable to the project.

2.4. Project sites are subject to inspection by the 56 Civil Engineer Squadron (56 CES) Environmental Office to ensure compliance with environmental regulations and practices.

2.5. Contractors must report spills to the Base Fire Department dial 911 when:

• The spill is greater than two feet; or

• The spill is greater than one gallon; or

• The spill is an unknown substance; or

• The spill is on soil or cracked pavement; or

• The spill may create a threat of fire/explosion; or

• The spill may be a risk to personnel.

2.5.1. The Base Fire Department will report these spills to the Luke Environmental Office.

2.6. Contractors must report small spills (spill less than two feet in area) to the Luke Environmental Office for directions regarding disposal of spill residues 623-856-3832.

2.7. Contractors must report all accidents involving Air Force people, property, or equipment damage, and any contractor personnel injured in the performance of the Air Force contract to the Contracting Office.

2.8. Contractors shall take immediate corrective action to comply with environmental regulations if informed of a violation by the Contracting Office.

2.9. If necessary, appropriate actions will be initiated through the Contracting Office to correct substandard environmental practices or conditions.

Part 3 – Summary of Common Environmental Requirements and Contractor Responsibilities:

The following, organized by the step/action that occurs in a typical construction project, is a list of common Contractor responsibilities. This table is not all inclusive of all environmental requirements that could be encountered during a construction project (for instance the removal of underground storage tanks, or the installation of dry wells). If further guidance is needed on a specific construction project, please contact the 56 CES Environmental Office: 623-856-3832.

3.1. Before Construction/Performance/Demolition/Repair

Requirement When required? What is required? Required Submission

Complete Environmental Management System (EMS) Awareness Level Training

Always unless deemed not applicable by the installation EMS Coordinator

Complete EMS Awareness Training in Appendix C.

This must be accomplished prior to any work being accomplished on the installation.

Submit Employee Training Roster (Attachment 3) to the 56 CES Environmental Office.

Air Quality Dust Control Plan and Permit

When 1/10 of an acre or more of soil is disturbed.

Submit Dust Control Plan and permit application to Maricopa County Air Quality Department

(MCAQD).

Must erect a sign onsite with permit information.

Submit a copy of the permit to Contracting Office.

Contracting Office will forward copies of permits to the 56 CES Environmental Office.

Requirement When required? What is required? Required Submission

Asbestos Determination

Prior to renovation or demolition activities

For projects already designed: Contact the 56 CES Environmental Office regarding any previous asbestos surveys and abatement requirements NOTE: If an asbestos survey has never been accomplished or is more than five (5) years old a new survey will be required.

For projects in design phase: Contractor responsible for the asbestos determination as follows:

• Asbestos data may be available for some buildings. Contact the Asbestos/LBP Program Manager at 856-4569 to determine if data already exists for the specific building or work area.

• If data does not exist or is inadequate testing for asbestos is required. A copy of the new survey will be provided to the Asbestos/LBP Program Manager.

If it is determined that asbestos is present above the action level AND will be disturbed, the Contractor will ensure the necessary abatement and protection procedures are incorporated into work plans and contract documents.

Submit a copy of the Asbestos Survey Report to the Contracting Office.

Contracting office will forward a copy of all surveys to the 56 CES Environmental Office.

NOTE: A NATIONAL

EMISSION STANDARDS

FOR HAZARDOUS AIR

POLLUTANTS

NOTIFICATION OF

DEMOLITION must be submitted to the Maricopa County Air Quality Department for ALL demolitions – even if no asbestos is present.

Demolition = removing a load bearing wall.

Asbestos Abatement Prior to renovation or demolition activities

If asbestos is present, the Contractor must:

• Submit copy of the Asbestos Abatement Plan.

o The 56 CES Environmental Asbestos/LBP

Program Manager will review the plan to ensure protection of the environment and base personnel that may be affected in the project area.

• File a National Emission Standards for Hazardous Air Pollutants (NESHAP) notification and Renovation and Demolition Permit application with the Maricopa County Air Quality Department. Provide copies to the base.

• Submit copies of the waste shipment records for asbestos-containing waste to the 56 CES Environmental Asbestos/LBP Program Manager

Submit Abatement plan and activity permits to the Contracting Office.

Contracting Office will forward copies of all documents to the 56 CES Environmental Office.

Notice of Intent (NOI) to Drill

When drilling, deepening, modifying, capping, or abandoning a monitoring well, drinking water well, piezometer, or environmental well.

Submit a NOI to Arizona Department of Water Resources (ADWR).

Obtain drilling card from ADWR. The drilling card must be kept in the possession of the driller at the well site during drilling. Drilling may not begin until the drilling card has been received. If the driller changes, the new driller cannot begin drilling until he receives a new drilling card from ADWR.

Submit a copy of the NOI and the drill card to the Contracting Office.

Contracting Office will forward a copy of the NOI to the 56 CES Environmental Office.

Hazardous Materials Management Always

Drums and pails of hazardous materials stored outside must be within secondary containment and covered.

Above Ground Storage Tanks for equipment fuel or oil must be within secondary containment with a fire extinguisher nearby.

None.

Hazardous Materials Review Initially

In accordance with FAR Clause 52.223-3, if the project involves using hazardous materials complete the Contractor Hazardous Material Questionnaire.

Refer to Appendix A for guidance.

Submit the Contractor Hazardous Material Questionnaire and SDS’s to the 56 CES Hazardous Materials Management Office.

Lead-Based Paint (LBP) Determination

Testing for LBP is necessary prior to renovation, repair, demolition, sanding, sandblasting, or maintenance activities that will involve or disturb painted surfaces.

For projects already designed: Contact the 56 CES Environmental Office for information regarding any previous LBP surveys and abatement requirements.

For projects in the design phase: Contractor is responsible for the LBP determination as follows:

• Contact the Asbestos/LBP Program Manager

(856-4569) regarding available LBP data for the work area.

• If data does not exist or is inadequate, Contractor is required to test for LBP.

• If it is determined that LBP is present above the action level AND will be disturbed, the Contractor will ensure activities are performed in conformance with OSHA 29 CFR 1926.62.

Necessary abatement and protection procedures shall be incorporated into work plans and contract documents

THE USE OF PAINT WITH A LEAD

CONTENT OF 0.06% OR GREATER IS

PROHIBITED.

Submit a copy of the LBP Survey Report to the Contracting Office.

If LBP is present, submit a copy of the LBP Removal/ Demolition Activity to the Contracting Officer.

Contracting office will forward copies of all documents to the 56 CES Environmental Office.

Lead-Based Paint (LBP) Abatement

Prior to renovation or demolition activities.

If LBP is present, the Contractor must submit copy of the LBP Abatement Plan to the base. The Environmental Asbestos/LBP Program Manager will review the plan to ensure protection of the environment and base personnel that may be affected in the project area. Submit copies of the waste shipment records for LBP waste to the 56 CES Environmental Asbestos/LBP Manager.

Submit abatement plans to Contracting Office.

Contracting Office will forward copies to the 56 CES Environmental Office.

Protection of Native Plants and Urban Forest Management

Ground disturbance or area clearing of any size.

Saguaro Cactus must be relocated on the project site or to another location on base.

Contact the 56 Environmental Office prior to the relocation of Saguaro Cactus.

If mature native trees, such as Palo Verde and Mesquite, must be cleared from the project area they are to be replaced in kind in the final project landscaping.

None.

Protection of migratory birds. (Compliance with Migratory Bird Treaty Act.)

Any removal of vegetation, including landscape tree/cactus maintenance, clearing or grubbing, during migratory bird nesting season (roughly March 1 – Sept 1). Any alteration of power poles, light poles, or other high structures likely to house nesting birds.

Contact 56 CES Environmental Office, (623) 856- 8488 three (3) working days prior to vegetation work to request biologist review of project area to determine if any active bird nests are present. All active nests will be avoided by the activity until any hatchlings are fledged. Nest surveys are valid for 10 days if no active nests are located.

Provide 56 CES Environmental Office with project location maps and details of activity at least 3 days in advance of work.

Permission to Use Equipment Containing Radioactive Material and/or Permission to Use Radiation Producing Equipment

Always required if:

• The equipment contains radioactive material, and/or

• The radiation producing equipment meets any of the following criteria:

o Equipment generating radiofrequency in excess of 7 Watts and/or 1000 MHz;

o Lasers that are class 3b or 4;

o Ionizing radiation such as x-ray equipment for imaging;

o Ultraviolet radiation for industrial use such as welding processes.

Submit a letter to the 56 Bioenvironmental Engineering Flight detailing the work to be done, the equipment to be used, the timeframe for the work, and POCs (including telephone numbers). A copy of the Radioactive Material License (with NRC Form 241 if it is a state license) and the contract must be attached to the letter.

The Bioenvironmental Engineering Flight will provide an approval letter regarding the use of radioactive material on Luke AFB. The radioactive material or radiation producing equipment may not be brought on-base until the contractor receives an approval letter from Bioenvironmental Engineering.

Surveys may be performed to ensure that general public exposure is within limits.

Submit request for the use of radioactive material and/or radiation producing equipment to Bioenvironmental Engineering.

Storm Water Pollution Prevention Plan (SWPPP) and AZPDES General Permit for Discharges from Construction Activities

When 1 acre or more of soil disturbance (if less than an acre, a CGP and SWPPP are not required, but measures must be used to prevent storm water pollution from the project from entering Luke’s Storm Water System).

The AZPDES General Permit for Discharges from Construction Activities requires the preparation of a SWPPP and the submittal of a Notice of Intent (NOI) with ADEQ at least two days prior to the start of construction activities.

When the project is complete submit Notice of Termination (NOT) to ADEQ.

Submit copy of the SWPPP and NOI to the 56 CES Environmental Office.

The SWPPP must be reviewed and approved by Luke’s Storm Water Manager.

3.2. During Construction/Performance/Demolition/Repair

Preservation of Cultural Resources (Compliance with the National Historic Preservation Act.)

When cultural resources are discovered on work site or during construction. ‘Cultural resources’ include any artifact or material relic of past human use, historic or prehistoric, of an area. If in doubt at all, it’s best to call.

Immediately stop work and contact the 56 CES Environmental Office (623) 856-8488. None.

Dust Control Plan Daily

Follow Dust Control Permit requirements.

Must have a MCAQD certified dust supervisor onsite during all earthmoving activities.

Report dust control water usage monthly using Contractor Environmental Reporting Form.

NOTE: Maricopa County Air Quality Department frequently performs inspections of contractor sites on Luke AFB to ensure permit compliance

Submit the Contractor Environmental Reporting Form to the 56 CES Hazardous Materials Management Office.

Hazardous Material Tracking and Reporting

Monthly

Report hazardous materials usage monthly using Contractor Environmental Reporting Form. Materials listed on the worksheet must match the SDSs provided.

Refer to Appendix A for guidance.

Submit the Contractor Environmental Reporting Form to the 56 CES Hazardous Materials Management Office.

Reporting of recycling and disposal of construction and demolition (C&D) debris and water usage.

Monthly

NOTE: Luke AFB is committed to exceeding the Air Force Goal of diverting at least 60% of the C&D debris generated on base. C&D should be recycled whenever feasible.

C&D disposal/reuse and water usage must be tracked and reported monthly on the on the Contractor Environmental Reporting Form (Appendix A).

C&D debris is defined as material generated during construction, renovation, demolition, or deconstruction of buildings and infrastructure. C&D debris typically includes concrete, wood, metals, gypsum wallboard, asphalt, and roofing material.

The 56 CES Environmental Office can provide a scrap metal roll-off for your project.

Submit the Contractor Environmental Reporting Form monthly to the 56 CES Hazardous Materials Management Office.

Identification and proper management of regulated wastes (RCRA Hazardous Waste, Universal Waste, Industrial Wastes).

If potentially regulated wastes are to be generated.

The Contractor must:

• Identify potentially regulated wastes.

• Provide copies of analytical reports, SDSs or other documents characterizing wastes as hazardous or non- hazardous to Hazardous Waste Program manager (HWPM).

• Coordinate storage locations with the HWPM.

• Follow provisions of the Luke Hazardous Waste

Management Plan for management (closed, marked containers, no more than 55 gallons stored, etc.)

• Use Luke AFB EPA ID for all RCRA and PCB waste shipments and ensure ONLY the HWPM signs the manifest.

See Appendix B for guidance.

Waste characterization documents.

For non-RCRA wastes (such as petroleum contaminated soil, lamps, batteries, etc.), submit a bill of lading showing disposal facility.

For RCRA-regulated wastes and PCBs, a uniform hazardous waste manifest must be used, coordinated with the HWPM prior to off-site shipment, and be signed by the HWPM.

SWPPP Daily Maintain storm water pollution prevention Best Management Practices in accordance with SWPPP. None

SWPPP Monthly Accommodate Luke’s Storm Water Manager in performing monthly inspections of the construction site.

None

3.3. After Construction/Performance/Demolition/Repair (Prior to Project Close-out)

SWPPP At project completion

After completion of construction project, contractor must submit a Notice of Termination (NOT) to ADEQ. All BMPs must be removed before submitting the NOT. All Post Construction Storm Water Controls must be inspected by Luke’s Storm Water Manager.

Submit NOT to ADEQ and the Contracting Office, to be forwarded to Luke’s Storm Water Manager.

Part 4 – Environmental Points of Contact

Listed below are the Environmental Office Points of Contact.

ENVIRONMENTAL POC Work Phone Cell Phone

Jeff Rothrock Environmental Chief 856-3832 (602) 245-4987

Scott Mendenhall Stormwater / Tanks 856-3621

Alan Thomas Air Program Manager 856-8486

Heather Hatlestad Hazardous Materials Manager / Recycling 856-4748

Bryan O’Sullivan Hazardous Materials / Recycling 856-4749

Carl Moser Hazardous Waste Manager / Asbestos

/ LBP 856-4569 (602) 228-0235

Chris Black Natural / Cultural Resources Manager 856-8488

APPENDIX A

GUIDANCE FOR REPORTING HAZARDOUS MATERIAL USAGE

Hazardous Materials: A hazardous material is commonly known as a HAZMAT. OSHA defines a hazardous material as any substance to which exposure “results or may result in adverse effects on the health and safety of employees” or “any chemical which is a physical hazardous or health hazard.”

There is no ‘one simple list’ of hazardous materials.

Listed below are the general categories of hazardous materials that require the submission of Safety Data Sheets (SDS) and hazardous material usage reporting to the 56 CES Hazardous Materials Management Office:

• Compressed gases (all types)

• Adhesives

• Sealants

• Paints (including aerosols)

• Lubricants / oils / fuels

• Welding materials

• Solvents

• Chemicals used in testing or as additives

• Any fluids (except water) added to machinery/government-owned or leased equipment

• Pesticides/insecticides/rodenticides

Prior to the start of a project, the Contractor must submit a Contractor Hazardous Material Questionnaire. The Contractor must then submit a Contractor Environmental Reporting Form monthly, no later than 5 days after the end of each month. Forms are required to be submitted to the 56 CES Hazardous Materials Management Office, (623)856-4748/4749.

CONTRACTOR HAZARDOUS MATERIAL QUESTIONNAIRE

CONTRACTOR HAZARDOUS MATERIAL QUESTIONNAIRE

CONTRACTOR COMPANY NAME

NAME OF CONTRACTOR

ADDRESS PHONE NUMBER

CONTRACT NUMBER

DATE, TIME AND LOCATION OF PRE-PERFORMANCE CONFERENCE MEETING

PROJECT TITLE

QUALITY ASSURANCE PERSONNEL (QAP)/CONTRACTING OFFICER (CO)

NAME PHONE NUMBER

PROJECTED CONTRACT PERIOD

START DATE COMPLETION DATE

1.) Will contractor be using any hazardous materials (HAZMAT) during this contract? HAZMAT includes, but is not limited to, adhesives, sealant, paints, lubricants, oils, fuels, welding materials, solvents, pesticides, chemicals, etc. See Luke Environmental Guide for Contractors.

a) If NO, sign and date below. If construction and demolition debris will be generated or potable water used during the project, Contractor must also submit a monthly Contractor Environmental Reporting Form no later than 5 days after the end of each month.

CONTRACTOR NAME (PRINT) CONTRACTOR SIGNATURE DATE

b) If YES, sign and date below. Complete and submit the monthly Contractor Environmental Reporting Form with all Safety Data Sheets no later than 5 days after the end of each month. Any construction and demolition debris that will be generated or potable water used during the project is also required to be reported on the Contractor Environmental Reporting Form.

CONTRACTOR NAME (PRINT) CONTRACTOR SIGNATURE DATE

2.) Contractor has reviewed the Luke AFB Environmental Guide for Contractors and will comply with all applicable requirements?

INITIALS

Yes

Submit forms and SDSs to the 56 CES/CEIE Hazardous Materials Management Office: (623) 856-4748/4749

COMMENTS:

CONTRACTOR HAZARDOUS MATERIAL QUESTIONNAIRE INSTRUCTIONS

This information is required in order to help the Luke AFB track all hazardous materials used on-base.

All blocks must be filled in.

A. Contractor Company Name: self-explanatory

B. Name of Contractor: self-explanatory

C. Address: Provide address for Contractor

D. Phone Number: Provide a valid working phone number for the Contractor.

E. Contract Number: self-explanatory

F. Date, Time and Location of Pre-Performance Conference Meeting: self-explanatory

G. Project: Provide the Project Title and a description of the work to be completed. The Project Title must match with the Title on file with the Contracting Office.

H. Quality Assurance Personnel: Provide the name and phone number of your Luke AFB Contract Officer.

I. Projected Contract Period: Provide the projected project start and end date of the contract.

1.) The Contractor prints, signs and dates verifying either a) No hazardous materials will be used during the contract period or b) Yes hazardous materials will be used during the contract period.

If the Contractor will be using any hazardous materials during the contract period, fill out the accompanying Contractor Environmental Reporting Form and provide SDSs for all materials to be used no later than 5 days after the end of each month. SDSs must be current, and match the materials being brought onto Luke AFB. The Contractor Environmental Reporting Form and all SDSs should be submitted to the 56 CES Hazardous Materials Management Office. Please contact (623) 856-4748/4749 for assistance.

Also reported on the Contractor Environmental Reporting Form is the quantity of any construction and demolition debris generated or potable water used during the project. Construction debris and potable water are required to be reported regardless of whether or not hazardous materials will be used during the contract.

2.) The Contractor is required to review and comply with all applicable requirements in the Luke AFB Environmental Guide for Contractors. Contractor should check the Yes box and initial to indicate agreement.

Environmental Guide for Contractors

CONTRACTOR ENVIRONMENTAL REPORTING FORM

CONTRACTOR ENVIRONMENTAL REPORTING FORM

56 CES/CEIE HAZARDOUS MATERIALS MANAGEMENT OFFICE (623) 856-4748/4749

12. QUANTITY BY TYPE OF CONSTRUCTION AND DEMOLITION DEBRIS REMOVED/REUSED.

CONTRACTOR SIGNATURE DATE BLDG NUMBER(S)

July 2022

1. CONTRACT NUMBER 2. CONTRACTOR NAME 3. HAZMAT STORAGE LOCATIONS 4. REPORTING MONTH & YEAR

5. PRODUCT NAME/MSN 6. MANUFACTURER 7. APPLICATION METHOD

(e.g. BRUSH, ROLLER, SPRAY, etc.)

8. UNIT OF ISSUE

(e.g. 16 OZ CAN)

9. QUANTITY

BROUGHT ON BASE

10. QUANTITY

USED

11. QUANTITY

REMAINING

ON-SITE LOCATION DISPOSAL FACILITY TYPE OF MATERIALS LANDFILL/RECYCLED QUANTITY (lbs)

13. AMOUNT OF

POTABLE WATER

GALLONS

CONTRACTOR ENVIRONMENTAL REPORTING FORM INSTRUCTIONS

1. Self-explanatory.

2. Self-explanatory.

3. Building number and location/room in building. If multiple locations, please list. If stored off base, please indicate.

4. Date of reporting month (e.g. May 2021).

Note: for items 5-10, List HAZMAT information in columns provided.

5. Product name being reported (e.g. latex gloss paint (include colors), walnut wood stain) or locally assigned Material Stock Number

(MSN).

6. Manufacturer of the product.

7. Application process/method: How will product be applied to process?

8. Unit of issue (e.g. 16 oz. aerosol can, 3 oz. tube, 5 gal pail).

9. Amount of material brought on base during reporting month (e.g. 3 cans, 2 tubes, 1 pail).

10. Amount of material used during reporting month.

11. Remaining balance of product at end of reporting month.

12. Construction and Demolition (C&D) debris disposed of by landfill and/or recycled can be reported on this form. Common types of C&D debris include asphalt, concrete, mortar, cleaning products, cylinders of gases especially propane, chlorine, refrigerants, welding/soldering products. Be sure to identify the on-site location, disposal facility, type of material, whether material was disposed of in the landfill or recycled, and the quantity (pounds).

13. Amount of potable water used (gallons)

The Federal Government has targeted the following chemicals for reductions in use. This includes DOD contractor use. Please avoid the use of these items, plus any confirmed human carcinogens, sensitizers, teratogens, mutagens, or extremely toxic materials when possible.

Benzene Dichloromethane or Nickel (and compounds) Cadmium (and compounds) Methylene Chloride Tetrachloroethylene (Perchloroethylene) Carbon Tetrachloride Lead (and compounds) Toluene Chloroform Mercury (and compounds) 1,1,1-Trichloroethane Chromium (and compounds) Methyl Ethyl Ketone Trichloroethylene Cyanides Methyl Isobutyl Ketone Xylene

APPENDIX B

HAZARDOUS AND UNIVERSAL WASTE MANAGEMENT AND DISPOSAL

Hazardous Waste and Universal Waste: The Contractor is required to manage and dispose of hazardous waste, and universal waste in accordance with local, state, and federal laws. It is the Contractor’s responsibility to determine whether any of these wastes will be generated by a particular project and to properly manage such wastes.

Listed below are examples of wastes which can be hazardous waste (this list is not all inclusive):

• Acids or caustics

• Adhesives, caulks, roofing cements

• Empty aerosol cans

• Items that contain lead (such as lead flashing, lead solder, lead-based paint chips)

• Items that contain mercury (such as mercury switches, mercury thermostats, fluorescent bulbs)

• Paints, varnishes, and sealers

• Pesticides, insecticides, and rodenticides

• Waste solvents, thinners, cleaners, and fuels

• Sandpaper, sand blasting residue

• Rags, gloves, coveralls, masking paper contaminated with hazardous materials.

The following table presents a list of questions that the Contractor may use to help identify whether their work will be generating a hazardous or universal waste (these questions are not all inclusive).

What processes will be performed during the project? Potential Regulated Waste

Will any paint be chipped, sanded, abraded, or chemically removed?

Many paints and primers contain lead, cadmium, or chromium, and these paint residues and sandpaper may be RCRA toxic for heavy metals.

Will any flammable paints, varnishes, cements, adhesives, or other coatings be used?

Many flammable coatings & adhesives contain methyl ethyl ketone (synonyms are MEK & 2-butanone) and brushes, rags, etc. contaminated with these may be RCRA toxic for MEK.

Additionally, if these are to be disposed in liquid form they may be RCRA ignitable.

What processes will be performed during the project? Potential Regulated Waste

Will any chemicals be used to clean or strip surfaces?

Many solvents (e.g., chlorinated solvents, benzene, toluene, MEK, xylene, etc.) are hazardous and the stripping residues along with rags and applicators may be RCRA listed spent solvent wastes.

Corrosive strippers (acids, alkalis, etc.) may be RCRA corrosive if disposed in liquid form.

Depending on what is being removed, the residues may also contain RCRA toxic heavy metals.

Will any aerosol cans be used?

Empty aerosol cans are regulated as RCRA reactive.

Non-empty aerosol cans that are disposed may also be RCRA ignitable.

Will any fluorescent lamps be removed?

Fluorescent lamps contain mercury and are regulated as Universal Waste

(No Bulbs may be disposed of in trash receptacles).

Will any electronic equipment be removed (equipment containing circuit boards, switches, thermostats, transformers, soldered parts, CRTs, etc.)?

Some types of equipment may contain heavy metals and be RCRA toxic for mercury, lead, or silver.

Transformers and lamp ballasts may contain Polychlorinated Biphenyls (PCBs).

Some types of equipment may contain batteries that have RCRA toxic metals or are RCRA corrosive or are regulated as Universal Waste.

Will all unused hazardous materials be removed by the contractor at job completion?

Full or partially full containers that are to be disposed may be RCRA wastes. RCRA wastes must be removed by a licensed hazardous waste transporter and accompanied by a hazardous waste manifest.

Environmental Guide for Contractors July 2021

APPENDIX C

ENVIRONMENTAL MANAGEMENT SYSTEM TRAINING

ATTACHMENT 1

DUST CONTROL METHODS

The following are suggested dust control methods that may be used to control fugitive dust from the sources listed.

Please note: Use of these control methods DOES NOT automatically assure compliance with Maricopa County Air Quality Department’s fugitive dust standards (Rule 310).

Use of more than one method may be necessary.

Land Clearing Activities Control Method Description

Watering Application by means of trucks and/or hoses during land cleaning operations.

During periods of high winds

1. Apply chemical stabilizers per manufacturer’s directions, and prior to expected wind events.

2. Apply water as necessary, and prior to expected wind events.

3. Stop work activities temporarily.

Earthmoving Activities Control Method Description

Watering

1. Application of water by means of trucks, hoses, sprinklers at sufficient frequency and quantity to conducting, during, and after earthmoving operation.

2. Pre-application of water to the depth of the proposed cuts or equipment penetration.

Pre-grading planning

1. Grade each phase separately and time to coincide with the construction phase.

2. Grade entire project area but apply chemical stabilizers or ground cover to graded areas where construction is scheduled to begin more than 30 days after grading is complete.

Chemical stabilizers 1. Most effective in areas that are not subject to daily disturbances.

2. Apply per manufacturer’s recommendations.

Wind fencing

1. Three to five foot barriers with 50% or less porosity, adjacent to roadways or urban areas.

2. Normally used in conjunction with watering or chemical stabilization.

3. Use trees and shrubs for long-term sites.

Operate off-road haul vehicles appropriately

1. Mix material with water prior to loading, and/or to entire surface of material after loading.

2. Empty loader slowly and keep bucket close to the truck while dumping.

3. Apply water as necessary during loading operation.

Alternative haul vehicles Use bottom-dumping haul vehicles.

During periods of high winds

1. Apply chemical stabilizers per manufacturer’s directions, and prior to expected wind events.

2. Apply water as necessary, and prior to expected wind events.

3. Stop work activities temporarily.

Storage Piles Control Method Description

Watering 1. Application methods include spray bars, hoses, and water trucks.

2. Frequency of application will vary with site-specific conditions.

Wind sheltering Install three-sided barriers, with no more than 50% porosity, equal to material height.

Chemical stabilizers Best for use on storage piles subject to infrequent disturbances.

Altering loading and unloading procedures

1. Confine loading and unloading procedures to the downwind side of storage piles.

2. May need to be used in conjunction with wind sheltering.

Coverings 1. Tarps, plastic, or other material can be used as a temporary covering.

2. When used, coverings must be anchored to prevent wind from removing them.

During periods of high winds

1. Apply chemical stabilizers per manufacturer’s directions, and prior to expected wind events.

2. Apply water as necessary, and prior to expected wind events.

3. Install temporary covers.

Disturbed Surface Areas or Inactive Construction Sites Control Method Description

Chemical stabilization 1. Most effective when used on areas where active operations have ceased.

2. Apply per manufacturer’s recommendations.

Watering Apply at sufficient frequency and quantity to develop a surface crust.

Wind fencing

1. Three to five foot barriers with 50% or less porosity located adjacent to roadways or urban areas.

2. Normally used in conjunction with watering or chemical stabilization.

Vegetation Establish as quickly as possible when active operations have ceased.

Prevent access

1. Install fencing around perimeter of property.

2. Install “No Trespassing” signs.

Site access improvements Stay on established routes.

During periods of high winds

1. Apply chemical stabilizers per manufacturer’s directions, and prior to expected wind events.

2. Apply water as necessary, and prior to expected wind events.

Unpaved Roads and Shoulders Control Method Description

Paving or chip sealing Requires routine street sweeping if subject to material accumulation.

Chemical stabilization 1. Not recommended for high volume or heavy equipment traffic use.

2. Apply per manufacturer’s recommendations.

Watering

1. Need sufficient quantities to keep the surface moist.

2. Required application frequency will vary according to soil type, weather conditions, and amount of vehicle traffic.

Reduce speed Restrict vehicle speeds to no more than 15 mph.

Eliminate unnecessary travel Restrict access or redirect traffic to reduce vehicle trips.

Gravel/recycled asphalt Maintained to a size and depth effective in controlling dust.

Location Locate haul roads as far from existing housing as possible.

Site access improvements Stay on established routes.

During periods of high winds

1. Apply chemical stabilizers per manufacturer’s directions, and prior to expected wind events.

2. Apply water as necessary, and prior to expected wind events.

3. Stop work and vehicle activity temporarily.

Paved Roads Track-Out Control Method Description

Wheel washers

1. Should be placed where vehicles exit unpaved areas onto paved areas.

2. May be adjusted to spray entire vehicle including bulk-stored materials in haul vehicles.

Sweep/clean roadways Either sweeping or water flushing may be used.

Cover haul vehicles Cover the cargo compartment with a tarp or other suitable closure.

Site access improvements

1. Install a gravel pad or grizzly at the access point to your site.

2. Designate a single site entrance and exit.

3. Stay on established routes.

During periods of high winds

1. Cover all haul vehicles.

2. Clean streets with water flushing.

ATTACHMENT 2

STORMWATER POLLUTION PREVENTION AT CONSTRUCTION SITES

Attachment 3 Contractor Awareness Training Roster

IAW DoD Policy and AFI 32-7001, Environmental Management, all personnel, including contractors, are required to receive both EMS and general environmental awareness training at the level necessary for their job function. Prior to beginning work onsite or within 30 days, all contractor personnel must sign and date the below training roster and return it to the 56 CES Environmental Office. Anyone who works on a contract at any point during the contract period must receive this information and training.

By signing below, you certify that you have read, understood, and accept this document and all attachments. All personnel working within the job site will comply with the environmental policies and regulations herein.

NAME/TITLE/COMPANY NAME SIGNATURE DATE

Submit the completed Training Roster to 56 CES Environmental Office at 56CES.CEIE.Enviromental@us.af.mil mailto:56CES.CEIE.Enviromental@us.af.mil