Attachment 8 - Contractor Environmental Guide-July2026.pdf
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- Attached to
- GOV Parking and Roadway paving, Camp Murray, WA
- Solicitation number
- W50S9E26BA002
- Issued by
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Department of the Army National Guard
About this file
194th Contractors Environmental Guide Camp Murray ANGS
This is an installation-specific Contractor Environmental Guide (CEG) for Camp Murray Air National Guard Station, last published July 23, 2026, designed to assist contractors, suppliers, vendors, and others performing work at the installation in meeting federal, state, and local environmental regulations and Air Force requirements. The guide establishes mandatory environmental protection requirements for all construction, demolition, and renovation operations and specifies that contractors must implement work practices to prevent environmental pollution and minimize damage to air, water, and land resources. All site workers must read and understand the CEG prior to commencing work, maintain a copy on-site at all times, and acknowledge receipt by completing a Project Design Checklist before beginning work.
The CEG addresses comprehensive environmental compliance programs including air quality management (fugitive dust control, low-VOC painting specifications, refrigerant handling by EPA-certified technicians, and 5-minute vehicle idling limits); hazardous materials usage tracking through Safety Data Sheets submission prior to bringing chemicals on base; hazardous waste and regulated waste management with monthly reporting requirements and Very Small Quantity Generator status limitations; universal waste and used oil handling procedures; toxic substances management for asbestos, lead-based paints, and PCBs; solid waste disposal and recycling programs; natural resources and migratory bird protection under the Sikes Act; cultural resources and inadvertent discovery protocols requiring immediate work stoppage and notification; water management including stormwater pollution prevention plans for projects disturbing one acre or more; sustainable procurement requirements; and concrete washout water management. The guide includes appendices with environmental commitment statements, project design checklists, emergency response contact procedures, inspection forms for secondary containment and above-ground storage tanks, natural resource and invasive species lists, and comprehensive definitions and acronyms for environmental compliance terminology.
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Text version
194th Contractors Environmental Guide Camp Murray ANGS
Last Published: 07/23/2026 Organization and Office Symbol (OPR):
Signature Page
No Signature Found.
1. Introduction
1.1. Contractor Responsibilities
2 Environmental Compliance Programs
2.1 Air Quality
2.1.1 Particulates
2.1.2 Painting
2.1.3 Refrigerants
2.1.4 Vehicle Idling
2.2 Hazardous Materials
2.2.1 Hazardous Materials Usage
2.2.2 Hazardous Materials Storage and Containment
2.2.3 Hazardous Materials Spills
2.3 Hazardous Waste and Regulated Waste
2.3.1 Hazardous Waste Generation and Accumulation
2.3.2 Hazardous Waste Disposal
2.3.3 Hazardous Waste Training
2.3.4 Universal Waste
2.3.5 Used Oil
2.4 Toxic Substances
2.5 Solid Waste
2.5.1 Solid Waste Disposal and Storage
2.5.2 Recycling and Reuse Program
2.5.3 Solid Waste Reporting
2.6 Natural Resources
2.7 Cultural Resources
2.8 Water Management
2.8.1 Wastewater
2.8.2 Stormwater
2.9 Sustainable Procurement
2.10 Other Information
A. Installation Environmental Commitment
B. Project Design Checklist
C. Emergency Response Contact Information & Procedures
D. Inadvertent Discovery SOP
E. Inspection Forms
F. Definitions / Acronyms
About this Plan
This installation-specific Contractor Environmental Guide is the Air National Guard's (ANG) standardized template developed as an ANG best management practice to fulfill requirements outline in AFI 32-7001, para 2.31.11
Sections of this Contractor Environmental Guide begin with ANG-wide “standard content” language that address ANG, Air Force, and Department of Defense (DoD) policy and requirements. This standard content is maintained and updated by the NGB/A4VN EMS Coordinator in coordination NGB/A4VN SMEs. The standard content is restricted from editing at the installation-level to ensure that it remains standardized throughout all plans. Immediately following the ANG-wide standard content sections, are installation supplements. The installation supplements contain content to address state, local and installation-specific requirements. Installation supplements are unrestricted and are maintained and updated by ANG installation personnel.
This document is optimized to accessed and viewed electronically; however, a print copy can be utilized to suit the needs of the contractor. The Virtual Environmental Management Office (VEMO) website at https://intelshare.intelink.gov/sites/vemo is the primary communication tool for the installation's environmental program.
Document Control
The initial Contractor Environmental Guide is reviewed and approved by the installation Environmental Management Office (EMO) at the time of publication. Thereafter, the plan will be reviewed annually by the EMO and make record of updates/changes noted below:
Record of Updates – The Contractor Environmental Guide is updated as changes to DAFI 32-7001 occur as well as changes in specific subject matter areas in accordance with the appropriate regulations and/or other requirements.
Record of Annual Review – In accordance with (IAW) DAFI 32-7001 & ANG EMS/installation document control procedures, the Contractor Environmental Guide must be maintained and reviewed annually by the EMO, updated as appropriate, and approved by EMO lead. Substantive revisions should be coordinated with installation stakeholders and primary POCs for disciplines applicable to contractor activities on the installation.
Record of Updates to Template
Nature of Change Template Publish Date Approved By:
Populated required preliminary sections; add installation applicability, where feasible;
major update to languages in section 2. Environmental Compliance, 2.2 Hazardous Materials,
2.3. Hazardous Waste and Regulated Wates, 2.3.1. Hazardous
Waste Generation and Accumulation, 2.3.2. Hazardous Waste Disposal; general review of plan by ANGRC SMEs.
4/12/2023 K. Cox
Solicited comments from ANGRC SMEs. Reviewed and incorporated changes.
5/16/2023 K. Cox
Administrative updates to language. Updated section 2.2.3 Hazardous Materials Spills to include F3 (Fluorine-Free Foam).
Solicited comments from ANGRC SMEs. Reviewed and incorporated changes.
7/25/2024 K. Cox https://intelshare.intelink.gov/sites/vemo/SitePages/Home.aspx https://intelshare.intelink.gov/sites/vemo
Record of Updates to Plan
Nature of Change Plan Publish Date
Approved By:
Reviewed, No Updates 9/11/2024 Cheryl Settle
Reviewed, No Updates 6/18/2025 Cheryl Settle
Revised 5 sections - brought them up to date
7/23/2026 Cheryl Settle
1. Introduction
The Contractor Environmental Guide is provided to assist contractors to include suppliers, vendors, and others doing work on behalf of the installation in meeting federal, state, and local environmental regulations and Air Force requirements while working at the Air National Guard installation.
Adherence to this guide is necessary and will help increase your company’s awareness of the Air National Guard and the installation's Environmental Management System (EMS) and environmental regulatory requirements.
Environmental Management System (EMS) requirements are outlined in Appendix A.
No requirement in the Contractor Environmental Guide will relieve the contractors of complying with any applicable federal, state, or local regulations. Contractors are responsible for being knowledgeable of all applicable federal, state, local laws and regulations, permit requirements, and US Air Force policies and procedures. Whenever there is a conflict among federal, state, and local laws, regulations and/or permit requirements, the more restrictive provision shall apply. In the event of noncompliance, contractors shall take corrective and/or preventive actions and shall immediately notify the Contracting Office Representative or Contracting Officer.
This Contractor Environmental Guide (CEG) establishes mandatory environmental protection requirements for all construction, demolition, and renovation operations performed under this contract. The Contractor shall implement work practices as specified in the CEG to prevent environmental pollution and minimize damage to air, water, and land resources. This includes, but is not limited to, the management of visual aesthetics, natural and cultural resources, noise levels, solid waste, dust, hazardous waste, toxic waste, and radioactive materials. The CEG is compliant with the 194WG Environmental Plans, Air Force Environmental Protection Regulations, and all applicable federal, state, and local environmental laws and regulations. All site workers are required to read and understand this CEG prior to commencing work on-site, and the Contractor shall maintain a copy of the CEG on-site at all times. The 194 Wing Environmental Office will conduct inspections to ensure compliance with environmental regulations and requirements.
IMPORTANT NOTE: While this CEG may reference the Environmental Office, the primary communication channel is through the Contracting Officer (CO) or the Contracting Officer Representative (COR). The Contractor shall first contact the CO/COR regarding environmental concerns. The CO/COR will then contact the Environmental Office if appropriate. Direct contact with the Environmental Office by the Contractor is permissible only when the CO/COR are unavailable.
1.1. Contractor Responsibilities
Contractors performing work at the Installation are responsible for:
Compliance with federal, state, and local environmental regulations/requirements. Installation-specific environmental requirements are outlined in this Contractor Environmental Guide.
Conformance with the Installation's Environmental Commitment to Air Force Policy Directive 90-8, which is provided in Appendix A of this Contractor Environmental Guide.
Ensuring all subcontractors adhere to environmental regulations/requirements and policies, acknowledge receipt of the Contractor Environmental Guide, and submit reports, as required.
Briefing employees and/or subcontractors on environmental regulations/requirements and policies as applicable to the project.
Reporting all spills in accordance with procedures outlined in this Contractor Environmental Guide.
Reporting all accidents involving Air National Guard people, property, or equipment damage, and any contractor personnel injured in the performance of the Air National Guard contract to the Contracting Office.
Taking immediate corrective action to comply with environmental regulations/requirements if informed of a violation by the Contracting Office.
Contractor project sites are subject to inspection by the Environmental Management Office (EMO) to ensure compliance with environmental regulations/requirements and practices.
ENVIRONMENTAL PROTECTION QUALITY CONTROL
The Contractor is responsible for implementing and maintaining a robust quality control program to ensure all environmental protection requirements outlined in this contract are met. The Contractor must immediately notify the Contracting Officer Representative (COR) of any challenges or failures in meeting these requirements.
KNOWLEDGE AND COMPLIANCE WITH ENVIRONMENTAL REGULATIONS
The Contractor is responsible for knowing and complying with all applicable federal, state, and local environmental laws, regulations, permit requirements, and U.S. Air Force policies. In cases of conflict, the most restrictive provision will govern. The Prime Contractor is responsible for ensuring all subcontractors comply with this contract's environmental guidelines (CEG).
CONTRACTOR COMPLIANCE
This section addresses potential in-house compliance issues that involve specific elements within the 194WG ANG. This could include providing lead time on actions that would disrupt the base population. Or restrictions that the base may enforce such as contractor parking or cleaning up the contract site.
PERMIT COMPLIANCE AND MODIFICATIONS
The Contractor must adhere to all terms and conditions of any permits issued for this project (or related projects) by local, state, or federal agencies. This includes, but is not limited to, permits such as the Washington Department of Ecology Pollution Discharge Elimination System Permit, Puget Sound Air Quality Permit, and EPA Hazardous Waste Permit. Any proposed changes to existing permits must be justified and approved by both the COR and the 194th Environmental Management Office (EMO).
ENVIRONMENTAL MANAGEMENT SYSTEM (EMS) AWARENESS AND COMPLIANCE
The 194th Wing is committed to environmental protection through its Environmental Management System (EMS). (See Appendix A for the 194th Wing Environmental Commitment, adhering to AFPD 90-8, and prioritizing Compliance, Reducing Risk, and Continuous Improvement.) This commitment incorporates environmental considerations into all decision-making processes. The Wing uses a proactive Environmental, Safety, and Occupational Health (ESOH) Council to continuously improve mission processes and reduce operational ESOH management risks.
The Contractor must perform all work in a manner that aligns with the 194th Wing's Environmental Commitment and its associated Environmental Management Programs and Operational Controls. This includes, but is not limited to:
Pollution prevention Waste reduction Energy conservation Natural resource protection
The Contractor shall provide monitoring and measurement data as required to assess environmental performance, particularly regarding solid waste disposal goals and Hazardous Material reporting requirements. Furthermore, the Contractor is responsible for ensuring all employees are aware of their EMS roles and responsibilities and how these requirements affect their work under this contract.
Contractor Responsibilities:
While operating within the constraints of this contract, all Contractor personnel are responsible for:
1. Waste Reduction and Recycling: Minimizing solid waste generation from construction, demolition, and scrap metal through reduction, reuse, and recycling. Recycling eligible materials, including ferrous metals and copper (wire and pipe), and depositing them in designated base collection containers.
2. Hazardous Material Minimization: Reducing the use of hazardous materials and/or solvents by purchasing fewer hazardous products and prioritizing those with recycled content.
3. Pollution Prevention: Minimizing outdoor ground pollution by:
• Using ground cover in areas where grinding, sanding, or painting (any action that releases something to the ground) occurs.
• Cleaning and servicing tools and equipment indoors or on a ground protective cover to prevent chemical or petroleum spills on the ground.
• Maintaining equipment with potential leaks or spills within containment systems or using absorbents to prevent ground contamination.
• Mixing and storing hazardous materials in designated areas that will contain spills.
4. Energy and Water Conservation: Conserving energy and water by turning off lights and equipment when not in use and using only the necessary amount of water to complete tasks. Continuous conservation of natural resources is required.
5. Environmental Impact Awareness: All contractor employees must be aware of the environmental impacts associated with their construction activities.
2.1 Project Design Checklist
Prior to providing a product, service or beginning construction work, the contractor shall provide a completed and signed Project Design Checklist or other written acknowledgement to the Contracting Office Representative or Contracting Officer. The Project Design Checklist is provided in Appendix B.
If support is needed in completing the Environmental Design Checklist, the contractor should contact the Environmental Management Office.
Contract Provided Environmental Management Plan
A Construction Environmental Management Plan (CEMP) outlines how construction activities will be managed to avoid or mitigate environmental or nuisance impacts. It details the implementation of environmental management requirements during the construction phase.
CEMP Triggers:
A CEMP is required when construction activities pose a risk of environmental harm or nuisance. Specific triggers for requiring a CEMP include, but are not limited to, the following site characteristics:
Location within the catchment of a water-sensitive region (e.g., a water protection area).
Proximity to surface or underground waters.
Proximity to sensitive receptors (e.g.,nesting or migrating birds, designated wildlife/natural areas).
Potential for site contamination.
Import or removal of waste soils, construction, or demolition waste.
CEMP Content:
The CEMP must include the following information:
Site Description: Detailed description of the site location and the surrounding environment, including the location of sensitive receptors.
Project Details: Description of planned construction works, including timelines and construction hours.
Impact Assessment: Identification and analysis of potential environmental impacts, including environmental hazards and risks, proposed mitigation measures, and any residual risks.
Management Measures: Identification and description of management measures to be implemented
(e.g., stormwater inspections).
Waste Management: Description of procedures for the collection, storage, and disposal of non-regulated wastes, universal wastes, and hazardous wastes.
Fugitive Dust Control Plan: Detailed plan for controlling excessive dust.
Vehicle Wash/Scrape Area Details: Details on measures to minimize the tracking of soil and rocks onto public roads.
Reporting and Verification: Identification of appropriate reporting and verification measures, such as analytical results for materials requiring testing.
Contingency Plans: Description of appropriate contingencies to be implemented if management measures are ineffective or result in environmental nuisance.
Responsible Person(s): Identification of a person or persons responsible for implementing the CEMP, who must:
o Ensure construction activities do not result in noise with an adverse impact on amenity, except as permitted by applicable noise regulations.
o Have the authority to immediately cease works if an environmental issue arises.
o Have the authority to investigate environmental issues.
o Have the authority to authorize the recommencement of works after investigation and mitigation of impacts.
o Be responsible for managing communications and complaints related to environmental impacts.
o Be responsible for notifying the Contracting Officer (CO) or Contracting Officer Representative (COR) immediately if serious or material environmental harm from pollution is caused or threatened by the Contractor's activities.
2 Environmental Compliance Programs
The installation has a broad scope of environmental impacts and works within many disciplines of environmental compliance. This section will outline the requirements in each discipline. It is necessary for contractors to comply with the requirements of each program identified.
PROTECTION OF ENVIRONMENTAL RESOURSES
The environmental resources within the project boundaries and those affected outside the limits of work under this contract shall be protected during the entire period of this contract. The Contractor shall confine his activities to areas defined by the drawings and specifications. The Contractor shall comply with the following requirements of each environmental program identified.
In the event of any environmental nonconformance or noncompliance associated with any of the environmental laws and regulations, the contractor shall take corrective and/or preventative actions and shall immediately notify the COR
2.1 Air Quality
Contractors shall keep construction activities under surveillance as well as practice proper management and control to minimize air pollution. All activities, equipment, processes, and work operated or performed by the contractor in accomplishing the specified construction shall be in accordance with federal, state, and local air emission regulations, laws and standards.
To minimize air pollution, the Contractor shall implement comprehensive surveillance, management, and control measures for all construction activities. All activities, equipment, processes, and work performed under this contract shall strictly comply with all applicable federal emission and performance laws and standards, as well as the regulations of the Puget Sound Clean Air Agency (PSCAA). The Contractor is responsible for determining the need for and obtaining a "Notice of Construction Permit," and for maintaining compliance with the Ambient Air Quality Standards established by the EPA and PSCAA throughout the contract duration. The Contractor shall ensure the availability of sufficient functional equipment to effectively achieve these requirements.
2.1.1 Particulates
Dust particles, aerosols, and gaseous by-products and fumes from all construction activities and the processing and preparing of materials, such as sanding, grinding and abrasive blasting, shall be controlled at all times and kept at a minimum at the construction site. Contractors will identify best management practices (BMPs) that they will use to help minimize fugitive dust.
Particulates Dust particles, aerosols, and gaseous by-products and fumes from all construction activities and the processing and preparing of materials, such as from sanding, grinding and abrasive blasting, shall be controlled at all times and kept at a minimum at the construction site. Contractors will identify best management practices (BMPs) that they will use to help minimize fugitive dust.
Open Burning
The burning of man-made debris or vegetation is prohibited on base.
Construction Site Dust
Fugitive Dust is particulate matter that is suspended in the air by wind or human activities and does not come out of a stack. Air quality regulations require the use of control techniques to minimize Fugitive Dust emissions. The goal is to eliminate visible airborne Fugitive Dust. Therefore, state and local regulatory agencies expect that as many of these control techniques be employed as necessary to achieve this goal.
Contractors will be responsible to keep road dust at the construction site to a minimum. They may be asked to provide a water truck to wet down open ground/dirt worksites and roads.
Grinding, Sanding, or Metal Work
Activity that generates dust or particles will require the use of a tarp or containment area to capture the waste. No waste from these activities shall be left on the ground (soil or hard surface).
2.1.2 Painting
Contractors shall practice pollution prevention and look for opportunities to reduce the opportunity for creating pollution of any kind. Contractors shall reduce air quality pollutants and should use the lowest Volatile Organic Compound (VOC) and/or Hazardous Air Pollutant (HAP) content paint as possible to accomplish work. The contractor is also required to have trained personnel to reduce rework and control overspray. Contractor will be prepared to provide documentation of all training. All hazardous materials used in painting operations must be reviewed and approved by the Environmental Management Office (Please see additional details in the Hazardous Materials Usage section).
Paint Specifications
The federal government caps the VOC content in paint at 250 grams per liter (g/l) for flat finishes and 380 g/l for other finishes (low-luster, semi-gloss, etc.) The Base EMS program requires an active practice of reducing air quality pollutants and encourages the use of the lowest VOC content paint as possible to accomplish the work with a HVLP sprayer. Low VOC is considered to be:
Flat (matte) paints: < 50 grams of VOCs per liter.
Non-flat paints (satin/semi-gloss): < 100 grams of VOCs per liter.
The 194 CEF has an approved list of four latex paints with different colors. These paints have already been through the installation approval process and can be used seeking additional approval except to submit the RFI with the SDS to ensure the same paints are being purchased.
Methods and Cleaning
The contractor is highly discouraged from spray painting outdoors in windy conditions. The contractor shall work with the COR to pre-plan any outdoor spray painting in order to alert members to stay out of the area and to clear out any equipment that may be affected by any overspray.
The cleaning of spray guns, rollers and paint brushes shall be done in a containment area that will capture all of the discharge. The 194WG does not allow decanting the water from these cleaning operations to the ground or to a storm drainage system. Decanting to the wastewater (sewer) may be allowed but the Contractor would need to get permission from the JBLM Wastewater Treatment facility. The contact is from the privatization contractor American Water.
American Water PO Box 331051, Joint Base Lewis-McChord, WA 98433 Joint Base Lewis McChord Office: (253)366-9127
2.1.3 Refrigerants
Any work to be performed on refrigerant-containing equipment whether new or existing shall be performed by EPA-certified technicians using certified equipment.
All excess Class I and Class II ozone depleting substances and R-22 type Freon being removed from equipment associated with chiller retrofits shall remain the property of the USAF (if not contaminated).
Any refrigerant added or removed from equipment must be reported to Civil Engineer Squadron. The installation of any new refrigerant-containing equipment including stationary equipment with 50 pounds or more of refrigerant must also be reported to CE Squadron.
EPA Certified Technicians & Credentials
Only technicians holding valid EPA Section 608 Certification (Type I, II, III, or Universal, as appropriate for the equipment) are authorized to perform maintenance, servicing, repair, or disposal that could release refrigerants into the atmosphere .
Verification Protocol: The contractor must submit copies of all technician EPA certifications to the COR for verification and approval.
Timeline: Certifications must be turned in, reviewed, and approved prior to commencing the evacuation (recovery) or loading (charging) of any refrigerant on site.
Refrigerant Recovery, Ownership, and Cylinders To maintain strict material accountability and support Department environmental goals, the following recovery protocols are in effect:
Ownership: All excess refrigerant removed from HVAC, AC, or chiller equipment during retrofits, modifications, or decommissioning shall remain the property of the USAF/ANG.
Recovery Cylinders:
The USAF/ANG can provide recovery cylinders/containers to the contractor for this purpose.
To obtain government-furnished cylinders, the contractor must provide advance notification to the COR so that logistics, testing, and distribution arrangements can be coordinated.
No venting of refrigerant is permitted under any circumstances.
To meet federal clean air regulations and base-level tracking requirements, precise documentation is mandatory:
Reporting Agency: All refrigerant activities must be reported directly to the base Environmental Management Office (EMO).
Data Requirements: The contractor must log and submit the exact weights (in pounds/ounces) of all refrigerant added to or removed from any system, along with the equipment's serial number, location, and date of service
Deadline: This data must be submitted immediately following the completion of the service event to ensure timely compliance logging.
Photos of the data plates of all newly installed equipment shall be turned into the COR.
Boilers
The EMO requires photos of the data plates of all newly installed boiler equipment. Existing boilers that are being flushed can discharge the flushed waste to the sanitary sewer but will be required to obtain a permit for this discharge. A copy of this permit can be found in Appendix B. As of 2020 the Joint Base Lewis McChord wastewater system is privatized. The current contractor is American Water (November 2022). This permit shall be obtained by the contractor and a copy of the approved permit provided to the COR prior to discharging any waste.
The contact for this permit is:
American Water PO Box 331051, Joint Base Lewis-McChord, WA 98433 Joint Base Lewis McChord Office: (253)366-9127
2.1.4 Vehicle Idling
Contractors must abide by all vehicle idling polices on the installation. At a minimum contractor will strive for a 5 minute idling maximum unless otherwise specified.
2.2 Hazardous Materials
The installation works to identify, authorize, and track hazardous materials with the objective to effectively manage and minimize the Air Force's dependence on hazardous materials. It is necessary for contractors to contribute to this objective by disclosing hazardous materials usage while on the installation and managing hazardous materials in accordance with all applicable laws and regulations.
The Occupational Safety and Health Administration (OSHA) defines hazardous materials as any substance or chemical which is hazardous to people's health or is physically hazardous.
2.2.1 Hazardous Materials Usage
Prior to any chemicals being brought on base, contractors must submit the Contractor Hazardous Materials Usage Tracking Form (Appendix C) attaching all chemical Safety Data Sheets (SDS). This must be submitted to the Contracting Office Representative or Contracting Officer. Any concerns will be addressed with the contractor via the Contracting Office Representative or Contracting Officer.
The Environmental Management Office is available to assist as necessary.
HAZMAT (HM) brought on base
The Contractor shall submit Safety Data Sheets (SDSs) to both the Contracting Officer and the COR. The Environmental, Safety, and Bioenvironmental Offices will review the SDSs to assess potential occupational health and environmental concerns. The COR will then notify the Contractor of any concerns, instructions, or recommendations resulting from this review.
The Contractor is required to track all hazardous materials (hazmat) brought onto the base, including the quantity used and the quantity removed. A sample tracking form is provided in Appendix C. The Contracting Office will provide electronic tracking forms; alternatively, the Contractor may use their own form, provided it contains all required data. The Contractor must submit this tracking form to the COR before introducing any hazmat to the base. The Contractor will submit regular hazmat usage reports to the COR on a monthly or quarterly basis, as determined by project length, and a final report upon project completion. Final payment will not be released until the Contractor provides this required information to the COR.
2.2.2 Hazardous Materials Storage and Containment
Contractors must provide for the proper storage of hazardous materials and take all necessary provisions to meet the National Fire Protection Association (NFPA) codes, the Occupational Safety and Health Act (OSHA) requirements, and the Resource Conservation and Recovery Act (RCRA) requirements.
Liquid hazardous materials in containers of 55 gallons or greater require secondary containment that is capable of holding 110% of the volume of the largest container, or 10% of the total volume for the consolidated location, whichever is greater. Additionally, sufficient materials to clean up spills of hazardous materials should be maintained by the contractor at hazardous materials storage locations.
CONTAINER INSPECTIONS
Liquid containers of HM or HW of 55 gallons or more shall be inspected monthly with the Tank Inspection Checklist provided in Appendix B. An electronic copy of this form can be provided to the contractor if requested.
CONTAINMENT INSPECTIONS
Containment areas located outside will require inspections as a part of the container inspection. In addition, if the containment area fills up with rainwater, the contractor will drain the containment area immediately and document this action. If there is any noticeable oil sheen on the water, the contractor will contact the EMO for instructions prior to releasing the water to the ground. A copy of the decanting sheet inspection form can be found in Appendix B.
CONTAINER LABELS
In the upcoming sections there is a discussion about the several waste streams that may be produced by the contractor. Below are samples of labels that will be applied to containers.
2.2.3 Hazardous Materials Spills
Emergency Response Contact Information and Procedures (Appendix D) provides the installation's relevant contact information and spill response procedures. All spills must be reported in accordance with installation spill reporting procedures. Note that spills of AFFF (Aqueous Film Forming Foam), HEF (High Expansion Foam), and F3 (Fluorine-Free Foam) must be immediately reported to the Environmental Management Office.
Clean up of any spilled materials is the responsibility of the contractor.
The Contractor is responsible for immediately reporting all spills of hazardous or toxic materials to the COR, including vehicle oil or hydraulic leaks. Spill notification protocols vary based on the spill's severity and location.
Immediate Danger (Fire or Human Health): The Contractor's first action for Contractor-caused spills posing an immediate threat is to call the Fire Department at 99-911 (Base phone) or 911 (cell phone).
Immediately following Fire Department notification, contact the COR and the Environmental Office. Consult the Emergency Spill Response Flowchart in Appendix E.
Soil or "Waters of the US" Contamination: For Contractor-caused spills impacting soil or "Waters of the US," immediately contact the COR and the Environmental Office. The COR and Environmental Office will determine if further agency notification is needed and the Environmental Office will assess cleanup requirements.
Regardless of the spill's nature, the person discovering it must immediately alert others, shut down fuel operations (if applicable), and initiate safe steps to control the spill and reduce hazards. The Contractor is responsible for the complete clean-up, storage, and disposal of spilled materials.
Reportable spills include:
Spills of 6 ounces or more.
Any amount reaching a waterway (including Underground Injection Wells).
Any amount reaching bare earth.
The Environmental Office is solely responsible for notifying Federal and State authorities of reportable spills.
The Contractor and its subcontractors are prohibited from contacting these authorities directly
2.3 Hazardous Waste and Regulated Waste
It is necessary that any hazardous or regulated waste be managed in accordance with installation practices to ensure continued compliance. Additionally, the installation strives to minimize waste aligning with the EPA's pollution prevention methodology and expects all work being performed on behalf of the installation to implement this approach to hazardous waste management.
Hazardous Waste cannot be removed from the site. If it was generated on base, it must be stored and disposed of from this installation.
Regulated Waste can be removed from this site and stored at the contractor's yard. Ultimate disposal must be documented and reported back to the Environmental Office.
The Environmental Office will work with the Contractor's Environmental representative to set up waste sites for their regulated and hazardous waste. The contractor will be responsible to purchase the containers and monitor them regularly.
Containment areas for Hazardous Waste or Regulated wastes will be kept under cover. Secondary containment will be required for liquid wastes in containers that are 55 gal or greater and/or any size container holding a liquid HW. This regulation falls under the Stormwater Code of Federal Regulations (CFR)s.
2.3.1 Hazardous Waste Generation and Accumulation
Contractors will work with the Environmental Management Office to correctly identify hazardous waste streams and to establish and maintain any hazardous waste satellite accumulation points. Cost associated with the materials for the satellite accumulation points are the responsibility of the contractor. If the volume of hazardous waste at a satellite accumulation point exceeds regulatory requirements, the Environmental Management Office will be notified immediately to transfer to the installation's Central Accumulation Point.
Any satellite accumulation point containers must remain under the control of the operator of the process generating the waste, be in good condition, be compatible with their contents, and be closed except when adding or removing waste. Hazardous wastes generated by the contractor shall be managed and stored to ensure no spillage on the ground or releases to water or air.
The type and amount of hazardous waste generated onsite must be provided to the Contracting Office Representative or Contracting Officer in a timely manner.
The 194th Wing is currently a Very Small Quantity Generator which means we collect less than 220 lbs. of HW and less than 2.2 lbs. of acute HW per month. According to 40 CFR 262.13 wastes must be tracked monthly to ensure these quantities are not exceeded.
If the Contract generates HW, the weights of the monthly accumulation will need to be reported to the Environmental Office every month.
An example: if you have a barrel of contaminated rags. The first month, you report your container is a 1/4 full and weighs 10 lbs. The next month the container is 1/2 full and now weights 20 lbs. The contractor would report the 10 lb. increase the second month.
A Satellite Accumulation Site (SAP) will be set up for each HW stream. The Contractor may store the HW in an agreed upon, designated SAP until any container reaches 55 gal. and then will turn in this waste to the Environmental Engineer. The other option is for the Contractor to arrange for a certified HW transporter to pick up the waste to be brought to a regulated TSDF within 72 hours.
It is requested that if the contractor knows they will be producing hazardous waste that will account for over 220 lbs. per month, that they contact the Environmental Engineer with this information. This will allow the Environmental Office to apply for an “Episodic" exemption.
2.3.2 Hazardous Waste Disposal
Contractors will properly prepare hazardous waste for shipping and dispose of all contractor-generated hazardous waste. The Environmental Management Office will review, approve, and sign all hazardous waste manifests.
Costs associated with waste laboratory analysis for the satellite accumulation points are the responsibility of the contractor.
The Contractor is authorized to dispose of hazardous waste, as detailed in Department of the Air Force Manual (DAFMAN) 32-7002, paragraph 5.4.1.1. To ensure proper disposal, the following procedures must be followed:
1. Manifest Information: Use the 194WG EPA ID number (WAH000057490) and the WA ANG address (103 41st Division Way, Tacoma WA 98430) on the hazardous waste manifest.
2. Manifest Signature: Under no circumstances is the Contractor authorized to sign the manifest. The
Contractor must coordinate with the Environmental Engineer to obtain their signature.
3. Waste Tracking: The Environmental Engineer will track and report the waste disposal to the WA Dept.
of Ecology.
2.3.3 Hazardous Waste Training
Contractors shall ensure that all employees handling hazardous waste are adequately trained in accordance with the Resource Conservation and Recovery Act (RCRA) in the management of hazardous waste. Training must be conducted, documented, and maintained by the contractors to ensure all onsite personnel are compliant with applicable local, state and federal instructions, rules and regulations.
Records will be maintained by the contractor and made available upon request.
2.3.4 Universal Waste
Contractors shall work with the Environmental Management Office if a Universal Waste collection point must be designated for the storage of universal waste generated during project activities. Contractors will properly prepare universal waste for shipping and disposal of all contractor-generated universal waste.
The Environmental Management Office will review, approve, and sign all universal waste manifests and/or shipping documentation.
Contractors shall provide emergency procedures appropriate to the type(s) of universal waste being managed by the contractor to their employees and manage any resulting waste properly.
Proper handling of Universal Waste (UW), including Batteries (all types) and Lamps (Fluorescent, small vehicle, Mercury Vapor, Sodium, HID, CFLs, etc.), is required to ensure environmental compliance.
UW can be stored on site only with prior approval from the Environmental Office, or removed from base on a daily basis. Adherence to the following guidelines is mandatory:
Lamp Handling Procedures:
Containment: Lamps must be placed in closed containers that are structurally sound, prevent breakage, and are compatible with the lamp materials.
Labeling: Each container must be clearly labeled with one of the following designations: "Universal
Waste – Lamp(s)," "Waste Lamp(s)," or "Used Lamp(s)."
Date Tracking: Mark the container with the date the first lamp is placed inside (accumulation start date).
Broken Lamps: Do not intentionally break lamps. Intentionally broken lamps must be managed as hazardous waste, requiring more stringent handling and disposal.
Battery Handling Procedures:
Terminal Protection: Always tape battery terminals before storage to prevent short circuits.
Segregation: Batteries must be separated by type when dropped off at the designated Universal Waste area.
Lead-Acid Batteries: Expended lead-acid batteries must be placed within secondary containment (such as a locker) and have their terminals taped.
Container Management: Battery containers must be kept closed, and the accumulation start date must be visible. To allow the Environmental Office adequate time for disposal processing, containers must be turned in several months before the one-year expiration deadline
2.3.5 Used Oil
Used oil containers that are 55 gallons or greater in capacity require proper secondary containment.
The Emergency Response Contact Information and Procedures (Appendix D) provides the installation's relevant contact information and spill response procedures. All spills must be reported immediately upon discovery.
The Contractor will be responsible for collecting, storing, and disposing of any used oil. The Contractor shall let the COR know that used oil is being collected, the size of the container and where it is located. The contractor will be responsible to inspect any container over 55 gal on a monthly basis. A copy of the inspection form can be found in Appendix F.
The Contractor is highly encouraged to recycle all non-regulated oils. The quantities of oil recycled or disposed shall be tracked on the Materials tracking form in Appendix C.
2.4 Toxic Substances
Contractors must make special provisions if work will include toxic substances as listed.
Asbestos Lead-based Paints Polychlorinated Biphenyls (PCBs) Radon
This will include any applicable certifications, management, and disposal in accordance with applicable federal, state, local, and Air Force regulations and requirements. Additionally, asbestos NESHAP (National Emissions Standards for Hazardous Air Pollution) requires Clean Air Act notification when certain conditions apply.
ACCUMULATION & STORAGE
Each substance referenced above has specific requirements on how long it can be stored and how it will be stored. The Environmental Office must be notified if any toxic, dangerous or hazardous waste is accumulated and stored.
The Contractor shall follow the WA State Dept of Ecology regulations for the storage, labelling and notifications of Asbestos and PCB wastes.
The contractor will be responsible to meet these State and Federal standards.
DISPOSAL
Manifested waste for toxic, dangerous or hazardous waste materials must be signed by the Environmental Engineer. Regular shipping documents (for non-hazardous waste) may be signed by the contractor.
However, copies of these shipping documents must be provided to the Environmental Office.
2.5 Solid Waste
The solid waste program includes municipal solid waste, construction and demolition (C&D) debris, and the management of recyclable commodities through diversion and/or a Qualified Recycling Program.
2.5.1 Solid Waste Disposal and Storage
Contractor will be responsible for non-hazardous waste generated as outlined in job specifications.
If waste is collected in a dumpster or roll-off, the unit will be kept covered when not in use. The area around the container will be kept clean.
The Contractor will be responsible for non-hazardous waste generated as outlined in job specifications.
If waste is collected in a dumpster or roll-off, the unit will be kept covered when not in use. The area around the container will be kept clean. Weights and costs should be recorded on the Solid Waste Disposal Form that is turned in to the COR found in Appendix C.
2.5.2 Recycling and Reuse Program
Contractors are responsible for implementing a program to divert any recyclable or reusable materials.
The 194WG highly encourages recycling, reuse, mulching and waste to energy disposals of solid non-regulated waste.
2.5.3 Solid Waste Reporting
Quantities of any materials removed from the installation for landfill disposal or diversion (e.g., recycling, reuse) shall be documented and reported to the Contracting Office Representative or Contracting Officer.
Weights should be associated with the appropriate categories – landfilled, diverted, incinerated, waste-to-energy, or mulched. Disposal cost should also be provided.
The wastes are tracked on the Solid Waste Disposal form found in Appendix C. The contractor will identify if the waste was disposed of to a landfill, a recycling center or even brought to a site that will reuse it (i.e., sinks, wood, masonry). An associated cost for each disposal must be reported.
2.6 Natural Resources
The Environmental Management Office manages any applicable Natural Resources on the installation.
The Sikes Act Improvement Act of 1997, 16 United States Code (USC) § 670a et seq., as amended (herein referred to as the Sikes Act), requires federal military installations with significant natural resources to develop a long-range Integrated Natural Resources Management Plan (INRMP) and implement cooperative agreements with other agencies. The Sikes Act is implemented through Department of Defense (DoD) and U.S. Air Force (USAF) instructions and manuals. The conservation measures discussed in the INRMP help manage water resources, state protected species, and invasive species and sustain natural resources.
The INRMP is intended to be in support of and consistent with the Sikes Act. This INRMP is the primary guidance document and tool for managing natural resources on Camp Murray Air National Guard Station (Camp Murray ANGS) and supplements the Washington Army National Guard (WAARNG) INRMP.
The WA ANG has a responsibility to protect all natural resources which includes flora and fauna, migratory birds and threatened and endangered (T & E) species. Currently, there are no T & E species on WA ANG property but, according to the Washington Fish and Wildlife Department there is a potential for the list found in Appendix G to be found in the area. If any of these species are identified, the Contractor must contact the EMO immediately to determine a way forward.
Nests of Migratory Bird Treaty Act (MBTA)-protected species may be found in the project vicinity. If the contractor encounters active bird nests during construction, they should leave them intact and contact the Environmental Office immediately prior to any further disturbance.
2.7 Cultural Resources
The Environmental Management Office manages any applicable Cultural Resources on the installation.
Inadvertent discoveries of cultural materials may occur on ANG-controlled property at any time, particularly during ground disturbance activities. If cultural resources are encountered during contractor operations, the contractor shall cease all ground-disturbing activities in the affected area to protect the resources. The Contracting Office Representative or Contracting Officer will be notified immediately; the Contracting Office Representative or Contracting Officer will then notify the base Environmental Management Office. See the full Inadvertent Discovery SOP in Appendix E.
INADVERTENT DISCOVERY PLAN
A. INTRODUCTION
The IDP outlines procedures to perform in the event of a discovery of archaeological materials or human remains, in accordance with applicable state and federal laws. An IDP is required, as part of Agency Terms and Conditions for all grants and loans, for any project that creates disturbance above or below the ground.
An IDP is not a substitute for a formal cultural resource review (Executive 21-02 or Section 106).
Once completed, the IDP shall always be kept at the project site during all project activities. All staff, contractors, and volunteers shall be familiar with its contents and know where to find it.
B. CULTURAL RESOURCE DISCOVERIES
A cultural resource discovery could be prehistoric or historic artifacts. Examples include (see images for further examples):
An accumulation of shell, burned rocks, or other food related materials.
Bones, intact or in small pieces.
An area of charcoal or very dark stained soil with artifacts.
Stone tools or waste flakes (for example, an arrowhead or stone chips).
Modified or stripped trees, often cedar or aspen, or other modified natural features, such as rock drawings.
Agricultural or logging materials that appear older than 50 years. These could include equipment, fencing, canals, spillways, chutes, derelict sawmills, tools, and many other items.
Clusters of tin cans or bottles, or other debris that appear older than 50 years.
Old munitions casings. Always assume these are live and never touch or move.
Buried railroad tracks, decking, foundations, or other industrial materials.
Remnants of homesteading. These could include bricks, nails, household items, toys, food containers, and other items associated with homes or farming sites.
The above list does not cover every possible cultural resource. When in doubt, assume the material is a cultural resource.
C. ON-SITE RESPONSIBILITIES
If any employee, contractor, or subcontractor believes that they have uncovered cultural resources or human remains at any point in the project, take the following steps to Stop-Protect-Notify. If you suspect that the discovery includes human remains, additional steps will be needed as shown on the Department of Ecology website - https://apps.ecology.wa.gov/publications/SummaryPages/ECY070560.html.
https://apps.ecology.wa.gov/publications/SummaryPages/ECY070560.html
See Appendix E for the Inadvertent Discovery Form and more information on the Standard Operating Procedures that need to be followed.
2.8 Water Management
Water management includes the wastewater, stormwater, and drinking water programs.
Note that drinking water is not typically impacted and therefore is not discussed further in this plan.
2.8.1 Wastewater
Industrial wastewater disposal must be coordinated with the Environmental Management Office.
The contractor is responsible for ensuring all applicable permits have been obtained and the requirements are met (to include specific wastewater discharge permits as applicable); documenting and maintaining copies of all permit required information (inspections, tests, etc.); and coordinating and communicating with the Environmental Management Office whenever there is a concern or change in circumstances.
The wastewater system on Camp Murray is managed by Joint Base Lewis McChord's Contractor American Water. The Contractor will be required to gain permits or approvals from American Water for any discharges to the sewer system. Their contact information is:
Environmental Manager American Water PO Box 331051, Joint Base Lewis-McChord, WA 98433 Joint Base Lewis McChord Office: (253)366-9127 Copies of permits or approvals shall be given to the COR.
2.8.2 Stormwater
Stormwater runoff from operations disturbing the land surface shall be controlled to protect water resources.
Control methods include but are not limited to silt fences/basins, berms, and drop/curb inlet protections. It is the responsibility of the contractor to implement best management practices whenever possible and maintain stormwater…
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