20170810_DPW12-056_NEPA_Requirements.pdf

RECORD OF ENVIRONMENTAL CONSIDERATION

NEPA / PROJECT #

/ 2016-441df DPW12-056

DATE

9/1/2016

PREPARED BY

DIANE FROST 719.526.0896

SECTION I – PROPONENT INFORMATION

1. TO (Proponent Name) Joe Wyka

2. ORGANIZATION

DPW

2a. TELEPHONE # 719-526-9211

3. TITLE OF PROPOSED ACTION

Butts Road Expansion/Renovation

4. NEED FOR ACTION

To improve traffic conditions.

5. BRIEF DESCRIPTION OF PROPOSED ACTION

The proposed action is to recondition the large portions of Butts Road between the southern terminus of the 4th ID CAB Vehicle Bridge and Road project, south to the intersection of Warfighter Road near Butts Army Airfield. The project would widen Butts Road in three locations, at each of the intersections of Skyraider Drive, Route 5A, and Frank Baldwin Road, where left and right turn lanes would be added. The designs would produce three separate packages for the work just described.

SECTION II – ENVIRONMENTAL SURVEY

(Checked boxes indicate potential environmental effects, including cumulative effects, and have mitigation / legal requirements).*

*See attached Mitigation / Legal Requirements for details Mitigation Required Coordination Required

6. Air (emissions, attainment status, etc)

7. Asbestos/Lead/Toxics

8. AST/UST/Spill

9. Cultural Resources

10. Forestry & Urban Forestry

11. IRP

12. Invasive Plants & Pest Management

13. RCRA

14. Stormwater (soil erosion, detention ponds, etc.)

15. Water Resources (watersheds, wetlands, Sec 404)

16. Wastewater

17. Wildlife

18. Other (see block 37)

Updated 11/30/16

SECTION III – PRELIMINARY PROJECT DATA

(NEPA Checklist for Record of Environmental Consideration)

THE PROPOSED ACTION: YES NO If yes, list mitigation options (if applicable)

19. Is adjacent or near a waterway (ditch, stream, wetland, etc.)

20. Is over 1 acre in size (include entire footprint and/or ground disturbance)

21. Is over 5 acres in size (include entire footprint and/or ground disturbance)

22. Is site on undisturbed ground

23. Has trees within the area

24. Has noxious weeds/invasive species in the vicinity

25. Has prairie dog colonies or other known wildlife habitat

26. Requires additional use of airspace

27. Affects traffic on-post or off-post

28. Involves construction and/or demolition of facilities

29. Has the potential to generate fugitive dust

30. Will generate hazardous waste

31. Is sited within a floodplain

32. Has potential for a high level of public controversy

33. Will cause a change in land use

SECTION IV - ENVIRONMENTAL ANALYSIS DETERMINATION

34. The action conforms to Categorical Exclusion (CX) screening criteria and 32 CFR 651.29, and to the following CX(s) from 32 CFR 651 Appendix B:

OR

Proposed action previously reviewed in an EA or EIS (see block 35 for reference) c(1) Construction of an addition to an existing structure or new construction on a previously undisturbed site if the area to be disturbed has no more than 5.0 cumulative acres of new surface disturbance. This does not include construction of facilities for the transportation, distribution, use, storage, treatment, and disposal of solid waste, medical waste, and hazardous waste.

35. TITLE AND DATE OF THE EA OR EIS REFERENCED:

36. Proposed action does not qualify for a CX; further environmental analysis is required

SECTION IV – ENVIRONMENTAL ANALYSIS DETERMINATION

AD :

PROPONENT (Name and Title)

ENVIRONMENTAL DIVISION

CERTIFICATION (Name and Title)

A S L AR

E IRONMENTAL DIVISION CHIEF,

DIRECTORATE OF PUBLIC WORKS

Package 1 would include reconditioning and improving Butts Rd from the project start in the north to the intersection of either Route 5A or Frank Baldwin Road. Package 2 would continue south from the Package 1 terminus to just north of the roundabout at the intersection of Butts Road and Wilderness Road, where newer pavement starts in the approach to the roundabout. Package 3 would include the “bypass” lane around the roundabout for northbound Butts Road traffic.

Any changes to the scope, location, size will require follow up NEPA documentation. The project proponent is responsible to ensure monitoring and mitigation requirements listed in the NEPA document are followed.

JOE WYKA

ENGINEERING DIVISION CHIEF,

DIRECTORATE OF PUBLIC WORKS

05-Mar-17

WYKA.JOSEPH

.EDWARD.107

8727531

Digitally signed by

WYKA.JOSEPH.EDWARD.1078727531

DN: c=US, o=U.S. Government, ou=DoD, ou=PKI, ou=USA, cn=WYKA.JOSEPH.EDWARD.1078727 Date: 2016.09.21 15:11:21 -06'00'

LESSARD.J

AMES.A.12

28494492

Digitally signed by

LESSARD.JAMES.A.1228494492

DN: c=US, o=U.S. Government, ou=DoD, ou=PKI, ou=USA, cn=LESSARD.JAMES.A.1228494 Date: 2016.09.22 06:50:47 -06'00'

MITIGATION MEASURES / REQUIREMENTS TABLE

Proponent Name:

Robert Schanke & Warren Wade Project Number:

DPW12-056

POC Phone:

719-524-0954 & 719-526-9211 NEPA Number:

2016-441df Title:

Butts Road Expansion/Renovation

Description:

The proposed action is to recondition the large portions of Butts Road between the southern terminus of the 4th ID CAB Vehicle Bridge and Road project, south to the intersection of Warfighter Road near Butts Army Airfield. The project would widen Butts Road in three locations, at each of the intersections of Skyraider Drive, Route 5A, and Frank Baldwin Road, where left and right turn lanes would be added. The designs would produce three separate packages for the work just described.

AIR

John Wachter 719-526-1694

Any agent engaged in overlotting, excavating, grading, filling, or other construction activities is required to comply with the requirements listed below and shall obtain a Land Disturbance/ Construction Activity Permit from either El Paso County Public Health or Colorado Department of Public Health & Environment.

1. Application for the Construction Activity Permit shall be made to El Paso County Public Health when: a.

Construction activities will not exceed six (6) months in duration, and; b. Land development is equal to or greater than one (1) acre, but less than twenty-five (25) acres. http://www.elpasocountyhealth.org/service/air-quality/construction-activity-application.

2. Application for the Construction Activity Permit shall be made to the Colorado Department of Public Health and Environment, Air Pollution Control Division when: a. Construction activities may exceed six (6) months in duration, and; b. Land development is equal to or greater than twenty-five (25) acres.

https://www.colorado.gov/pacific/cdphe/general-air-permits.

Proposed activity has the potential to stir up dust so please review and follow dust recommendations set forth in the Fort Carson Fugitive Dust Plan.

WASTEWATER/DRINKING WATER

Harold Noonan 719-526-1730

Emma Buccambuso 719-526-2022

STORMWATER

Chip Hahn 719-526-1697

The total disturbed area (including final developed site, laydown area, staging area, etc.) for the construction site exceeds one acre, a Notice of Intent (NOI) must be submitted to be covered under EPAs Construction General Permit (CGP). A Stormwater Pollution Prevention Plan (SWPPP) will also be required and must be reviewed and approved by the Fort Carson's Stormwater Program PRIOR to filing the NOI with the EPA. The SWPPP must be developed in accordance with Fort Carson's Stormwater Management Plan (SWMP) which can be found at (http://www.carson.army.mil/DPW/environmental/stormwater/index2.html). Additionally, all disturbed areas must be stabilized (i.e. landscaping, seed, gravel, etc.) in order to provide established uniform vegetation (e.g., evenly distributed without large bare areas), which provides 70 percent or more of the density of coverage that was provided by vegetation prior to commencing earth-disturbing activities. Vegetative stabilization will be done by either sod or by drill seeding of native perennial grass mixes. Irrigation and maintenance including weed mowing may be required until seeded area is stabilized. Coordination with the Stormwater Program Office must be made prior to terminating Construction General Permit coverage (filing the NOT) in order to verify stabilization is sufficient and all permit conditions have been met.

Any projects (development or redevelopment) with a footprint greater than or equal to 5,000 sq feet are required to comply with Section 438 of the Energy Independence and Security Act (EISA) by properly designing and installing permanent Low Impact Development (LID)/ Best Management Practice (BMP) features that allow for the pre-development hydrology of the area to be maintained after construction. The attached form entitled "Maintaining Hydrology on Army Construction Projects" will be completed by the USACE or AE LID Designer of Record and submitted to the Fort Carson Stormwater Program Office once final design drawings are issued. The form will be revised, as necessary, by the Designer of Record to reflect as built conditions if they differ from the final design drawings. If the project does not fully comply with EISA, a technical infeasibility report will be created by the Designer of Record and must be attached to this form. The designer will use Option 1 of the EPA's EISA 438 technical guidance for these calculations. If another method is necessary due to site-specific requirements, the method must be approved by the Fort Carson Stormwater Program Office prior to use. Due to water rights issues in the State of Colorado, all LID/BMP features must be designed to ensure that all water is released from the feature within 72 hours of the end of the precipitation event.

ASBESTOS/LEAD/TOXICS

David Martin 719-526-1725

No concerns.

IRP

Joe Gallegos 719-526-8001 Eric Dunker 719-526-8004

Julia Simmons 719-526-1682 SWMU 13, a groundwater plume, is in/near the proposed project.

Groundwater monitoring wells are located within the area (see attached map) The wells are government property and are currently used for compliance monitoring in accordance with Fort Carson's hazardous waste permit. If these wells are damaged, a replacement well must be installed using a contractor and scope of work to be approved by DPW's Environmental Division. Damaged wells must be abandoned by the contractor in accordance with Colorado Code of Regulations 402-2. Alternatively, plans may be modified to ensure that the wells are not damaged.

Monitoring wells in the area need to be avoided and replaced if the work interferes with the wells (well maps attached).

Also, the wells cannot be abandoned until replacement locations are identified and approved by CDPHE. There are specific well abandonment regulations per the Colorado Division of Water Resources and Fort Carson has specific requirements for monitoring well installation should a well be damaged and needs to be replaced.

In the event that contaminated or saturated soil and/or groundwater are encountered the contractor must:

a) Report the contaminated media to DPW's Environmental Division as soon as it is encountered.

b) Provide a work crew with appropriate OSHA HAZWOPER training and appropriate health and safety support.

c) Sample/analyze, manage, and dispose of contaminated media in accordance with the Colorado Department of Health and Environment requirements.

d) Coordinate signing of any waste manifest with DPW Environmental Division personnel.

e) Provide documentation of the activities listed above to DPW's Environmental Division.

Point of contact for IRP: Julia Simmons and Eric Dunker, 526-1682 and 526-8004, respectively.

AST/UST/SPILL

Terry Eberle 719-526-9411

No concerns.

RCRA

Cheryl Frischkorn 719-526-1686

At this time, it does not appear that hazardous waste will be generated during the project. However if this changes and hazardous waste is/will be generated, immediate coordination with the DPW Environmental Division is required. Under no circumstances can hazardous waste be generated, stored, shipped or otherwise handled without coordination with DPW Environmental Division. Federal, State, Army, and Fort Carson regulations apply. For additional information contact the RCRA program manager (719 526 1686).

INVASIVE PLANTS/PEST MANAGEMENT

Dawn Rodriguez 719-526-1329

Minimize soil disturbances that could cause an increase of weedy vegetation and ensure that any mulches, soils, and/or seed sources used are certified to be weed-free. Utilize native plants for any vegetative restoration work.

CULTURAL RESOURCES

Wayne Thomas 719-526-1852

Jennifer Kolise 719-503-6136 (PCMS) Betty Whiting 719-526-3796

This activity is exempted from further Section 106 consultation under the Built Environment Programmatic Agreement. Inadvertent Discovery of Archaeological, Cultural, or Paleontological Materials Standard Operating Procedure applies. There are no barracks to be demolished within the project area. Please correct Section 10.3 of the Design Analysis (BE I.A1).

FORESTRY/ARBORIST

Dan Gray 719-526-1692 (Main Post)

Jason Zayatz 719-526-1667 (Down Range)

No concerns.

WATERSHEDS/WETLANDS/404

James Kulbeth 719-526-1685

There are watershed concerns. See the attached maps of watershed boundaries showing an additional 250 acres of watershed now contributing to the drainage and required to pass through the twin 36 inch culverts just north of Skyraider road (southeast corner of Inset # 4). The southern land fill area (Pete's Hill) is now diverted along the west side of Tank Trail "D" (aka. TT "C" or GSB Access Road) to the confluence just north of the super climbing tower into K- Ditch Creek drainage. All of the landfill and scabs and 10th SF complex impervious surfaces are increasing the stormwater runoff SIGNIFICANTLY. NOTE: The engineers working the GSB project re-calculated and modified the culvert system along the TT"D" and there still are concerns over volume capacity and stability.

The culvert passage for the Korean Valley drainage is not shown on Inset #13 which should be north of the overhead water point. Is the culvert under Butts Road adequate for the flows of that large watershed plus the extra from the new National Guard complex (See attached map).

Culvert passage is not indicated on Inset #17 for the drainages on the south side of Happy Hollow/Bunker Compound and the roadside ditch from the Wilderness Road round-about. The current culvert may not be adequate.

If culvert replacements are made just north of Skyraider, then there may be some impacts to the Section 404 jurisdictional drainage called K-Ditch. This work would probably be covered under the Fort Carson Regional General Permit 14 if performed according to permit specification. Attached is the RGP 14 specification for culverts and bridges construction and maintenance.

WILDLIFE

Stephanie Smith-Froese 719-526-8006

Bryan Kluever 719-524-5393

To minimize Migratory Bird Treaty Act (MBTA) conflicts, removal of small trees and shrubs, mowing or removal of cattails, disturbance/destruction of riparian areas, and/or grading of prairie grass should occur from 1 November to 15 April. Otherwise, prior coordination with DPW-Wildlife is necessary to survey the project area within 2 weeks of starting construction. The primary nesting season for most birds protected by the MBTA occurs between 15 April -15 Sept, annually. If active MBTA nests are found, a 50ft buffer around each nest would be needed or a US Fish & Wildlife Service (USFWS) permit authorizing removal. If active nest(s) are discovered during project work activities, contact DPW-Wildlife immediately to avoid MBTA violation(s). If the scope or location changes, the proponent needs to coordinate with DPW Wildlife prior to beginning any work. The DPW Wildlife Biologist will conduct all surveys for wildlife.

OTHER

NEPA POCs Deb Benford 719-526-4666 Jack Haflett 719-526-6206

Samuel Saberniak 719-526-0896 The Fort Carson NEPA Office must be notified of any change to the scope, location, or size of the project.

Project proponent is responsible to ensure coordination, monitoring, and mitigation requirements listed in this document are implemented.

Further Coordination May Be Required:

Finalized Date:

Click here to sign this section

Signed by FROST.DIANE.J.1147158200 View details on Thursday, September 01, 2016 9:41 AM (Mountain Daylight Time)

9/1/2016 ** Subject to requirements listed in the Mitigation Measures/Requirements Table. If project is not initiated within 180 days, and/or there is a change in scope of work or location this document becomes null and void. Contact the NEPA Coordinator for re-submittal. Expiration Date:

Any environmental information needed to meet permit requirements (i.e. historic properties, T&E Species, Air Quality.

etc) can be obtained from the Fort Carson Program POCs listed above.

CAUTION: IF THIS FORM IS PROVIDED AS AN ATTACHMENT TO, OR OTHERWISE AS A PART OF, A CONTRACT, THE FOLLOWING APPLIES:

The above information represents assessments from the Fort Carson DPW Environmental Division concerning environmental requirements relating to this project. These assessments are provided for the Contractor’s information only. The Government does not warrant that these assessments are accurate or comprehensive. The Contractor remains responsible to determine and comply with all applicable federal, state, local, and military environmental laws and regulations.

Fort Carson has implemented an Environmental Management System (EMS) as the primary management approach for addressing environmental impacts of its processes, activities, and services. Fort Carson uses the ISO 14001:2004 as the standard for its EMS. All personnel performing work for on behalf of Fort Carson must be aware of and understand Fort Carson's Environmental Policy. For information regarding EMS requirements contact the Fort Carson EMS office at 719- 526-1697.

3/5/2017

Inadvertent Discovery of Archaeological, Cultural, or Paleontological Materials

In the event that a cultural resource, item of cultural material, or vertebrate paleontological resource is encountered during an undertaking, it is Fort Carson’s policy to make reasonable efforts to avoid, minimize, or mitigate adverse effects to those resources until the CRM can make a recommended determination of eligibility for inclusion in the NRHP and/or of the significance of the material. This process applies to newly discovered sites, as well as for a discovery on or near previously recorded properties where additional cultural materials or features may have been exposed. Note: A vertebrate paleontological resource is defined as fossil remnants from aquatic vertebrates (fish) to mammals, including birds.

Inadvertent Discovery of Archaeological Materials: Upon discovery, the following actions will be taken:

1. The project proponent, coordinator, or contractor will notify the Cultural Resources Manager (CRM) immediately, and all project work will cease within 30 meters of the site or discovery until otherwise notified by the CRM.

2. The CRM will inspect the site where archaeological materials have been discovered.

3. Documentation of the disturbance will be made, including notes and photographs.

4. The CRM will investigate to determine if the discovery constitutes a site with the potential to be eligible for inclusion in the National Register of Historic Properties (NRHP). If so, the CRM will initiate the Section 106 consultation process using 36 CFR 800.4 through 800.6, as applicable.

Willful Destruction of Archaeological Materials: The willful destruction, unauthorized excavation, removal, damage, or defacement of archeological materials is a violation of the Archaeological Resources Protection Act of 1979 (ARPA, as amended) and may result in a felony prosecution. The Integrated Natural Resource Management Plan (INRMP) provides for implementation of provisions under these laws. It is Fort Carson’s intent to prosecute anyone who vandalizes archeological sites or removes from federal property cultural materials or Native American remains or cultural items. See Section 4.c. Conservation Law Enforcement of the INRMP for details and enforcement procedures.

Native American Human Remains: In the event the find is or is suspected to be Native American human remains or funerary objects that are or may have been associated with human remains, the CRM will follow the stipulations and guidelines outlined in the Fort Carson NAGPRA policy, found within the Comprehensive Agreement between Fort Carson and 11 federally-recognized Native American Tribes.

Project Monitoring: Monitoring by Cultural Resources Management Program (CRMP) personnel may occur for activities or projects that are planned in areas that are known or suspected to have a greater likelihood for subsurface archaeological materials. The CRM will determine the appropriate level of monitoring and coordinate a schedule with the project proponent.

FRANK BALDWIN

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Landfill 1

SWMU-13

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18 19 520

FORT CARSON ARMY GARRISON & PIÑON CANYON MANEUVER SITE

EROSION CONTROL AND OTHER MINOR ACTIVITIES

Effective Date: October 2, 2014 Expiration Date: October 2, 2019

Purpose of this Regional General Permit: The purpose of this regional general permit (RGP) is to authorize discharges of dredged or fill material for erosion control and other minor activities in waters of the United States on the Fort Carson Army Garrison (Fort Carson) and the Piñon Canyon Maneuver Site (PCMS) that are substantially similar in nature and cause only minimal individual and cumulative environmental impacts. Activities that do not comply with the provisions of this RGP may require an individual permit. Some of the activities authorized by this RGP may be authorized by one or more nationwide permits. Such activities are included in this RGP to simplify the permitting process and improve the consistency of coordination between Fort Carson and the Corps.

Permittee: Department of the Army personnel under the command of Headquarters, Fort Carson, and their contractors or subcontractors.

Permit Area: This RGP is primarily intended for use outside of the Fort Carson Main Post (Cantonment) Area and for PCMS training lands. However, this RGP also authorizes certain activities within the Cantonment Area, as annotated in the Scope of Work section below.

This RGP is applicable to all waters of the United States (WOUS), including wetlands, on federally owned lands and easements associated with or held by Fort Carson in El Paso, Pueblo, and Fremont Counties, and on PCMS located in Las Animas County, Colorado.

Maps depicting the permit areas are attached.

Scope of Work: Activities authorized by this RGP are limited to erosion control activities within the permit area, as described below. Drawings showing typical activities are attached.

Activity #6 Culverts and Bridges. This RGP authorizes the construction and maintenance of culverted crossings and bridges with armoring, as necessary, in order to prevent erosion of the stream bed and banks on perennial streams or where there is perennial or intermittent flooding of MSRs and other roads. Linear transportation crossings must be designed to withstand expected high flows without restricting the capacity of the stream channel. PCN is required for linear transportation crossings that result in greater than 1/3 acre of fill below the OHWM of the stream. This RGP authorizes the construction of linear transportation crossings within the Cantonment Area.

Regional General Permit 14

Document Number:

PWE_CB_AIR 003

FORT CARSON

Environmental Management System

Revision Number:

Document Title:

Fugitive Dust Control Plan

Approved By: Title:

Mark R. Bradbury Chief, Compliance Branch

Issue Date: Revision Date:

21 June 2004 30 March 2012

Directorate of Public Works

Environmental Division

U.S. Army Garrison

Fort Carson, Colorado 80913

FORT CARSON

Environmental Management System

Revision Number:

Document Title:

Fugitive Dust Control Plan

Page i

TABLE OF CONTENTS

Page

SUMMARY OF CHANGES ii

EXECUTIVE SUMMARY E ‐ 1

SECTION 1 – INTRODUCTION 1 ‐ 1

Purpose 1 ‐ 1 Fugitive Dust and Its Health Effects 1 ‐ 1 References 1 ‐ 1 Scope 1 ‐ 2

SECTION 2 – SOURCE CATEGORIES 2 ‐ 1

General 2 ‐ 1 Source Categories 2 ‐ 1

SECTION 3 – CONTROL MEASURES 3 ‐ 1

General 3 ‐ 1 Existing Dust Controls 3 ‐ 1 Recommended Control Measures 3 ‐ 2

SECTION 4 – RESPONSIBILITIES 4 ‐ 1

SECTION 5 – CONCLUSION 5 ‐ 1

APPENDIX A— AIR PERMITTING REQUIREMENTS A ‐ 1

APPENDIX B—MAPS B ‐ 1

FTC B ‐ 2

PCMS B ‐ 3

INFORMATIONAL LINKS

Colorado Air Quality Control Regulation No. 1 Colorado General Permit (GP01) Colorado Land Development Application Guidance Colorado Land Development Application Form El Paso County Air Quality Control FAQ

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Page ii

SUMMARY OF CHANGES

(Excludes general format changes, error corrections, and omissions)

1.) All references to El Paso County Air Quality Regulation and permitting authority have been removed, effective 1/1/2009. An informational link has been added above to reference any frequently asked questions. – 1/10/2011

2.) The appendices were re‐organized to streamline the document. Any external references that are subject to change have been referred to in the informational links above (i.e. State AQCC regulation No. 1). – 1/10/2011

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Page E ‐ 1

EXECUTIVE SUMMARY

TOC

There are a number of technical terms that apply to emissions emitted into the air. However, reduced to laymen’s terms, Fort Carson is required to employ all practical measures to avoid creating visible emissions that are in excess of 20 percent opacity, having any visible emissions go beyond the Installation’s boundaries or creating a nuisance dust problem.

The most common examples of fugitive dust emissions are those associated with storage piles or unpaved roads caused by either wind or human activities, such as vehicle traffic. Construction and demolition sites, paved roadways and disturbed areas are also examples of fugitive dust emission sources.

Many of our fugitive dust sources/activities are required to obtain permits having control measures and operating procedures to minimize emissions and prevent off‐property transport. Regardless of whether or not a permit is required, any activity capable of producing fugitive dust is required to use all available and practical methods that are technologically feasible and economically reasonable in order to minimize such emissions. Per the Colorado Air Quality Control Commission’s Regulation No. 1, this control plan will be enforceable and a copy held on file at the state.

The purpose of this plan is to focus on control measures to implement that will minimize fugitive dust emissions and avoid exceeding the threshold levels dictated by the state regulations. This plan has been developed at the request of the Colorado Department of Public Health and Environment

(CDPHE).

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SECTION 1 – INTRODUCTION

Purpose

Developed at the request of the CDPHE, this plan describes all of the fugitive dust sources and the technologically feasible and economically reasonable control measures and operating procedures that can be used to minimize dust on Fort Carson. Our personnel, contractors, and Soldiers will implement these measures to avoid off‐property transport and to ensure the associated visible emissions do not exceed 20% opacity or create a nuisance problem. Additionally, this plan will serve as a planning tool that can be incorporated into project design and construction phases to help reduce fugitive dust emissions on Fort Carson. If there is a dust incident, the CDPHE can give Fort Carson a Notice of Violation by citing that this plan was not followed. This plan is enforceable.

Fugitive Dust and Its Health Effects

Fugitive dust is a health concern because it can contain particles that may be trapped in the nose or upper respiratory system. Other particles can bring about both chronic and acute health effects, such as persistent coughs, asthma, aggravation of bronchitis, premature death, or heart and lung disease.

Particularly sensitive groups that appear to be at greater risk include the elderly, individuals with cardiopulmonary disease (such as asthma), and children. In addition to health complications, material in fugitive dust can cause impaired vision, physical discomfort and/or property damage.

References

Control of fugitive dust is regulated by the Colorado Air Quality Control Commission (AQCC) Regulation No. 1.

Fort Carson is regulated by the CDPHE for any activities that create fugitive dust emissions. Certain activities, such as sandblasting and land development projects, may require permits and if so, the permits will contain site‐specific fugitive dust control plans. Refer to Colorado Land Development Application Guidance for projects requiring a construction activity/land development permit based on the size or duration of disturbed land. The DPW‐ED Air Program Air Quality Assessment Form and Requirements Guide (AQA) also address fugitive dust control. The applicable state and/or county emission limitation guidelines are listed below:

PM2.5

(2.5 µm)

PM10

(10µm)

PM2.5

(2.5 µm)

PM2.5

(2.5 µm)

PM10

(10µm)

Human Hair (70 µm diameter)

M. Lipsett, California Office of Environmental Health Hazard Assessment

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20% opacity emission limitation guidelines apply to:

Construction activities clearing an area greater than 5 acres (CDPHE)

Storage and handling of materials (CDPHE)

Sandblasting (CDPHE)

No off‐property transport emission limitation guidelines apply to:

Construction activities clearing an area greater than 5 acres (CDPHE)

Demolition activities (CDPHE)

Storage and handling of materials (CDPHE) Haul trucks and on‐site haul roads (CDPHE)

Nuisance emission guidelines apply to:

Unpaved roadways (CDPHE)

Activities depositing material on paved roadways (CDPHE) Off‐site haul roads (CDPHE)

Scope

The most common examples of fugitive dust emissions are those associated with storage piles or unpaved roads caused by either wind or human activities, such as vehicle traffic. Construction, demolition, dismantling, and renovation activities, unpaved roadways, and disturbed areas are other sources of fugitive dust emissions. Importantly, regardless of whether or not a project requires a permit, Fort Carson requires that sources emitting fugitive dust must use applicable control measures to minimize such emissions as much as possible.

This document is a guide for identifying and controlling sources of fugitive dust emissions on Fort Carson. Section 2 defines and describes these fugitive sources, Section 3 describes the appropriate control measures to minimize those emissions, Section 4 outlines responsibilities of involved personnel and Section 5 concludes. For ease of reference, the applicable regulations, as well as other documents are linked in the appendices.

This document is not intended to serve as a state or county guide to permits. For permit requirements or guidance, refer to the regulations or contact the DPW‐ED Air Program (526‐6601 or –1708).

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SECTION 2 – SOURCE CATEGORIES

General

This section defines and describes the fugitive dust emissions sources on Fort Carson. Fugitive emissions are those that cannot be reasonably collected and passed through a stack or other type of opening. When they are caused by sporadic or widespread activities due to wind or vehicle travel, it can often be difficult to quantify such emissions. Fort Carson’s annual emissions inventory includes fugitive dust emissions from unpaved roads. However, this is a rough estimate as it is difficult to track the number and types of vehicles on these roads, located mostly downrange from the cantonment area. Additionally, there are no specific emission factors established for the various types of military vehicles or to account for Colorado’s soil conditions.

Source Categories

Construction/Land Development Activities

Demolition, Dismantling, and Renovation Activities

Storage Yards, Storage Piles

Haul Roads

Unpaved Road Travel

Unpaved Road Wind Erosion

Paved Road Dust Entrainment

Sandblasting

Disturbed Areas

Street Cleaning/Sweeping

Street Sanding

Mining Activities

Construction/Land Development Activities This is a significant windblown fugitive dust category on Fort Carson. This category represents dust generated by soil disturbance due to surface preparation and equipment use. Windy conditions greatly increase emissions from disturbed surfaces. Construction activities include excavations, grading, filling, and other earth moving by mechanical processes that may result in releasing dust into the atmosphere. Projects may include, but are not limited to, constructing gate entrances and buildings, developing parking lots and roads, and excavations of ditches.

Demolition, Dismantling, and Renovation Activities Demolition activities include the destruction or dismantling of a structure by using mechanical equipment, such as bulldozers, front‐end loaders, or cranes. Debris from demolition practices is loaded onto trucks, which can create dust, and transported to an off‐post permitted landfill. Projects

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Page 2 ‐ 2 on Fort Carson primarily consist of demolishing unwanted buildings after reusable materials are deconstructed and salvaged and the appropriate surveys and assessments have been made.

Storage Yards/Storage Piles Temporary or permanent storage yards/piles contain road base material; fill dirt and/or landscaping materials that are used around Fort Carson throughout the year.

The Rocky Mountain Asphalt Yard, LB&B Storage Yard and the Troop Construction Yard are permanent, fenced storage yards on Fort Carson. Also, stockpiles of rock are located just inside Gate 7, off Route 115, which will be the source material for a U.S. Army National Guard’s rock crusher, soon to be located at Fort Carson’s Brown’s Quarry two miles from Gate 7. Once the crusher becomes operational, several smaller rock piles will be placed adjacent to the rock crusher, which will consist of various source material for the crusher, such as clean concrete rubble, the crushed material, and unusable material to be disposed of.

Haul Roads As defined by the AQCC Regulation No. 1, haul roads are used for commercial, industrial or governmental hauling of materials and are roads that the general public does not have a right to use.

Unpaved Road Travel Fort Carson has approximately 250 miles and Pinon Canyon Maneuver Site (PCMS) has approximately 100 miles of unpaved roads. Although the cantonment areas do contain some unpaved roads (i.e., tank trails and construction roads), the majority of them exist downrange. Tactical vehicles travel on these downrange unpaved roads to get to and from their training areas, as well non‐tactical vehicles travel within the downrange area. Although part of training includes driving and maneuvering under dusty conditions, a chemical dust suppressant is used on the unpaved roads when funds are available.

Unpaved Road Wind Erosion Wind erosion may occur when the wind at one foot above the ground surface blows greater than 12 mph. It is a serious fugitive problem in Colorado, as the wind physically removes the lighter, less dense soil constituents such as organic matter, clays, and silts.

Paved Road Dust Entrainment The Fort Carson has approximately 175 miles of paved roads and the PCMS has less than a mile. Dust is generated from this category when mud is tracked out from unpaved roads onto paved roads and then vehicles grind and lift soil off these paved surfaces and into the air. Entrainment also occurs on unpaved shoulders of paved roads from vehicles traveling on the paved road.

Abrasive Blasting Abrasive blasting outdoors is used to remove paint from streets, curbs, and buildings.

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Disturbed Areas This can be a significant windblown fugitive dust category due to increased development on Fort Carson. Windy conditions significantly increase emissions from disturbed soils.

Street Cleaning/Sweeping Mechanical street sweepers are used on a continuous basis on Fort Carson. They clean the debris from paved roadways to maintain the overall appearance of Fort Carson and also as a best management practice for storm water pollution control. However, in dry conditions, the sweeping equipment can create some minor, localized dust emissions.

Street Sanding This is a seasonal source as sand is applied on icy roads in the wintertime to improve driving conditions and to protect public safety. However, the sand left on the roads can become windblown or be disturbed and ground‐up by vehicle traffic, thus contributing relatively small amounts of localized dust emissions.

Mining Activities Mining activities could occur at Brown’s Quarry in the future. Tomahawk mine, near Stone City in Pueblo County on Fort Carson, is mined annually for clay by Robinson Brick Company, which has state‐ owned mineral rights.

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SECTION 3 – CONTROL MEASURES

General

Abatement and control measures, such as watering, can be used to minimize dust at several types of sources, while chemical stabilization (subject to available funding (SAF)) may only be suitable for larger size areas and identified significant sources. All available control measures should be evaluated carefully to determine their suitability for controlling emissions. Continuing evaluation of these control measures should be performed together by the Directorate of Public Works (DPW) to determine their applicability and suitability.

The DPW‐ED Air Program has developed a document, entitled Air Quality Assessment (AQA) Form and Requirements, as an aid for educating personnel working on Fort Carson about regulations and requirements governing the most common types of dust emission sources. In addition, during their environmental training, Environmental Protection Officers (a position required for each directorate and military unit) are made aware of fugitive dust emissions and what control measures Soldiers must take.

Existing Dust Controls

Prior to the development of this plan, Fort Carson has gone to great lengths and efforts for many years to control and minimize fugitive dust from various source categories. For example, a chemical dust suppressant is routinely applied (SAF) to various types of unpaved roads on Fort Carson and the PCMS depending on their location respective to the Installation boundary, quantity of vehicular traffic, and the types of vehicles using them. As well, each project is reviewed by the DPW‐ED and the project proponents and their contractors are made aware of the need for dust controls and any applicable permits. The aforementioned AQA form should help increase that general awareness.

Many activities on Fort Carson are also subject to best management practices under the National Pollutant Discharge Elimination System permitting program for the control of non‐point pollution sources and discharges of sediment and contaminants to Fort Carson's storm water system. Projects one acre or more are required to have a Storm Water Pollution Prevention Plan, which includes a section on dust control. The EPA’s recommended control measures to minimize water erosion and transportation of sediment off site are similar to numerous controls for minimizing dust. For example, control of track‐out onto paved roads, stabilization of site, revegetation, and maintaining the natural topography are control measures used to minimize both dust and sediment transportation.

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Recommended Control Measures

This section identifies the most common, available control measures recommended for implementation, but should not be relied upon as a comprehensive list or the only list. Control measures are often considered best management practices and the DPW‐ED does not want to limit opportunities for using such practices if they are not included in the list below. Per Army Regulation 190‐5 and Colorado Revised Statute 42‐4‐1011(1), there is an installation‐wide speed limit of 30 mph for paved roads, unless otherwise posted, and 20 mph for unpaved roads.

Construction/Land Development Activities

Use water for short‐term surface stabilization (chemical stabilization maybe necessary)

Minimize track‐out onto paved roads

Cover materials in the haul trucks

Wash loaded haul trucks to remove materials from the exterior prior to transporting materials

Wet the load

Limit load size

Stabilize site upon completion of grading (using either chemical, mechanical or vegetation) or when subsequent development is delayed

Restrict speed limits

Rapid cleanup of project‐related track‐out or material spills on paved roads

Maintain natural topography to the greatest extent possible

Construct parking lots and paved roads first (where feasible)

Construct upwind portions of projects first (where feasible)

Restrict activity during periods of high winds

Close roads if necessary

Demolition, Dismantling, and Renovation Activities Control measures shall be used throughout the demolition and cleanup portion of the project, including during loading and transit of materials.

Wet down, including pre‐wetting of work surface

Use of appropriate containment

Minimize track‐out onto paved roads

Cover materials in haul trucks

Wash loaded haul trucks to remove materials from the exterior prior to transporting materials

Wet the load

Limit load size

Rapid cleanup of project‐related track‐out or material spills on paved roads

Restrict activity during periods of high winds

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Storage Yards and Storage Piles

Use of wind breaks

Restrict traffic flow

Restrict speed limits

Provide cover/enclosures

Apply water or soil binder

Compaction

Stabilization

Use of water

Limit size of particles to store

Minimize the slope of the upwind face of the pile, confining as much pile activity as possible to the downwind side of the pile

Limit the pile height

Haul Roads

Chemical stabilization‐ (Note: steep grade terrains limit application of any suppressant.)

Restrict speed limits

Restrict traffic flow

Unpaved Roads/Areas

Appendix B consists of installation maps for the unpaved areas that receive the chemical dust suppressant once to twice a year, subject to available funds.

Use water for short‐term surface stabilization

Alternatively, chemical stabilization is applied on a priority basis for long‐term effectiveness, and it may also be required on longer term construction projects when water is no longer cost effective, cannot be used due to water restrictions, or is not effective with the current weather conditions. Priority 1 roads are unpaved roads/areas in the cantonment area that receive traffic; Priority 2 roads are close to border communities; and Priority 3 roads are located mostly at the PCMS or downrange on Fort Carson that pose limited dust impact to surrounding areas.

Restrict speed limits

Restrict traffic flow

Unpaved Road Wind Erosion

Use water for short‐term surface stabilization

Chemical stabilization

Restrict speed limits

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Restrict traffic flow

Reduce wind velocity at the soil surface. This is done with windbreaks, revegetation, and surface roughness.

Paved Road Dust Entrainment

Minimize track‐out onto paved roads

Cover materials in haul trucks

Limit load size

Rapid cleanup of project‐related track‐out or material spills on paved roads

Employ street cleaning/sweeping

Wash or otherwise treating the exterior of the vehicle

Keep roadway access point free of materials that may be carried onto the roadway

Restrict speed limits

Abrasive blasting This is an occasional source on Fort Carson and must be coordinated with the DPW‐ED prior to implementing such outdoor projects to ensure that the appropriate sampling and analysis is performed on the paint in case it contains lead. (Abrasive blasting of vehicles is performed at Building 8000 and 8004.)

Use enclosures with dust collecting equipment

Use wet blasting methods

Use non‐silica material

Disturbed Areas

Use water for short‐term surface stabilization

Stabilize site upon completion of grading (using either (chemical, mechanical or vegetation) or when subsequent development is delayed

Reseed

Compact disturbed soil

Use wind breaks

Use weed suppression techniques, such as mowing weeds or using goats

Street Cleaning/Sweeping

Use water while equipment is operated

Clean streets on a regular schedule to avoid build up

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Street Sanding

Sand streets by priority for public safety

Thoroughly remove sand as soon as possible after a storm to prevent it from being ground into dust (street cleaning/sweeping)

Use snowplows to remove snow and ice before sanding

Adjust and maintain spreaders for efficient application

Mining Activities

Water or chemical stabilization of unpaved roads

Prompt removal of rock minerals, soil and other dust‐forming debris from paved roads and scraping and compaction of unpaved roads to stabilize road surface

Restrict speed limits/vehicle travel in and around the mining operation

Re‐vegetation, mulch, or otherwise stabilize the surface of all areas adjoining roads and disturbed lands that are a source of fugitive particulate emissions

Enclose, cover, water, or otherwise treat loaded haul trucks and railroad cars, or limiting size of load, to minimize loss of material to wind and spillage

Substitute conveyor systems for haul trucks

Enclose, cover, stabilize, minimize the slope of the upwind face of the pile, confining as much pile activity as possible to the downwind side of the pile

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SECTION 4 – RESPONSIBILITIES

Personnel involved in activities that produce fugitive dust emissions will continue to be made aware of applicable local, state and federal regulations by providing them access to this plan, the DPW‐ED Air Program website, and receiving DPW‐ED Air Program comments on project reviews. Regardless of whether or not a permit is required, sources potentially emitting fugitive dust are required to minimize such emissions so that nuisance conditions are not created, visible emissions are not transported off property, and opacity limits are not exceeded.

The AQA form is available by contacting the Air Program Manager and/or from the DPW‐ED Air Program portal and distributed at the quarterly Installation Environmental Protection Officer’s (EPO) Course to personnel for educational awareness.

Dust issues are addressed during the EPO training course. In addition, the DPW‐ED Air Program will address current particulate matter/dust issues at the Garrison Commanders Environmental Quality Control Committee (EQCC) to raise awareness of dust challenges and consider policy actions. In addition, at the monthly Environmental Protection Officer’s meeting general dust issues are addressed relating to: how to monitor dust on sites, actions to take if a non‐compliance event occurs, and where to find this plan. DPW‐ED efforts to increase education and awareness about dust concerns should minimize the potential for non‐compliance issues concerning dust on Fort Carson.

If a fugitive dust event exceeds the 20% opacity limit, results in off‐property transport or violates the nuisance regulation, actions will be taken to correct the problem and return to compliance as quickly as possible. Project proponents/contractors are responsible for complying with their specific county/state dust control plans, if a permit is required, as well as the Fugitive Dust Control Plan. If the contractor is not implementing sufficient control measures, then the Contracting Officer Representative must take appropriate future actions, e.g., stop awarding projects to that contractor etc.

The following are steps that have been and will continue to be taken if a fugitive dust event is observed by project proponents/contractors:

Stop the activity immediately

Within a reasonable timeframe, notify DPW‐ED Air Program by phone (526‐6601) and if no one is there, contact the DPW‐ED Compliance Branch at 526‐8001.

Proceed with activity in conjunction with DPW‐ED guidance.

Implement more control measures to minimize the fugitive dust non‐compliance event.

Provide DPW‐ED Air Program with situational updates.

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The DPW‐ED Air Program will take the following steps if a fugitive dust non‐compliance event occurs:

Notify the appropriate project personnel/Contracting Officer Representative

Verify that the appropriate actions/control measures have been implemented to minimize fugitive dust

Verbally report incident to CDPHE and local County Health Department within 24 hours of incident and follow up with an email within 48 hours

Report incident on Fort Carson’s Title V Operating Permit Semi‐annual/Annual Compliance Report to CDPHE and EPA

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SECTION 5 – CONCLUSION

This plan should be referred to prior to project initiation to provide additional forethought in the development and implementation of a project to avoid off‐property transport and to ensure the associated visible emissions do not exceed 20% opacity or create a nuisance problem. Personnel involved in activities that produce fugitive dust are responsible for implementing the applicable control measures and operating procedures to minimize dust emissions to the greatest extent possible. Such persons are responsible for complying with all applicable county, state and federal air regulations and will appropriately burden the responsibility of any associated compliance actions if taken by the regulatory authorities.

Personnel will continue to be made aware of the local and state regulations through a variety of ways, primarily by being provided access to this plan, as well as the Fugitive Dust Controls, Permit Requirements and Guidelines brochure. The DPW‐ED Air Program will continue providing appropriate comments when reviewing projects so that personnel will be made aware of fugitive dust issues and requirements for control measures.

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Appendix A— Air Permitting Requirements For State (CDPHE) Land Development…