CX-Log.pdf

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Roof Repair B20187
Solicitation number
W911SG24B0014
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This document is a Record of Environmental Consideration (REC) for a roof repair project at Building 11341 on U.S. Army Garrison-Fort Bliss. The project involves replacing the existing thermoplastic polyolefin (TPO) roof, as well as repairing any exterior/interior damages.

The REC identifies potential environmental issues and provides guidance and contact information for the project. Key details include: an asbestos and lead survey is required prior to construction, any hazardous materials must be properly handled and disposed of, construction waste must be managed according to Fort Bliss requirements, and water/wastewater systems must comply with Texas regulations. The REC also notes that the project qualifies for a Categorical Exclusion under NEPA. The related federal contract opportunity is Solicitation W911SG24B0014 for roof repair at Building 20187, which requires a hazardous materials survey and replacement of the existing TPO roofing system.

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Environmental Review Form U.S. Army Garrison-Fort Bliss, Directorate of Public Works, Environmental Division (DPW-ED)-NEPA Office

RECORD OF ENVIRONMENTAL CONSIDERATION (REC)

This review and its attachments are used for only of the requested work as described in the narrative of the Work Order Request or provided documents.

This review identifies potential environmental issues which may be associated with this work and does not constitute an environmental technical review of subsequent project plans, specification and/or drawings.

The Project Manager (PM) responsible for the final design must address/resolve potential environmental issues prior to award/implementation of the project and concurrence is based on the proponent following the guidance in this document.

The DPW-ED's approval is contingent on the project not changing and work being completed within 365 days from the date of the review; resubmit if project changes OR if not completed by the REVIEW EXPIRATION DATE.

Date Received: 4/22/2024 NEPA LOG#:24-0480 Review Expiration Date:

95% Review Replace roof and Exterior/ interior damages. Replace damaged TPO roof to include any other exterior components such as Soffit, Fascia, Eaves, Gutters, Vents, etc. that are failing/ rotting throughout the building. Inspection conducted on July 2021 and roof seems worn out with some areas showing loose material, flapping, excessive patching and what looks to be a weak roof sheathing.

Other equipment may have to be accounted for when replacing the roof.

NA

PROPONENT: This document provides all relevant information regarding all environmental requirements, guidance and contact information pertaining to this project. All requirements must be met, for questions, clarification, or additional guidance please contact the Reviewer listed under each program.

*** ASBESTOS AND LEAD POTENTIALLY PRESENT AT BUILDING 11341 ***

DPW-ED does not have an asbestos and/or lead survey for B11341.

ENVIRONMENTAL REVIEW AND CONCURRENCES (For DPW ED Subject Matter Experts use ONLY)

PROGRAM: Cultural Resources - Archeology REVIEWER: Fabiola Silva DATE: 4/23/2024

CONCURRENCE: YES ATTACHMENT: NA

No comment.

PROGRAM: Cultural Resources - Historic Preservation REVIEWER: Donald J. Sevigny DATE: 4/24/2024

CONCURRENCE: YES ATTACHMENT: NA

No comment.

PROGRAM: Natural Resources REVIEWER: Claudia Ramirez DATE: 5/2/2024

CONCURRENCE: YES ATTACHMENT: NA

No comment

PROGRAM: Drinking Water REVIEWER: Paola Soto-Montero DATE: 4/25/2024

ANTICIPATED DATE AND/OR DURATION OF PROPOSED ACTION:

BLUF:

PROJECT DESCRIPTION:

5/10/25

DPW-ED Environmental Review NEPA Log 24-0480

SCLMR#: NA WO#: FE 10091 2J Doc TYPE#: 95% Review Location/Building: 11341

CONCURRENCE: YES ATTACHMENT: NA

No additional comments as requirements are addressed in section 2.7.11.4. and 2.7.11.4.1 of the Scope of Work. Proponent shall ensure these requirements. For new construction or alterations of a secondary system, it is required to follow the plumbing code for the state of Texas before they can connect to secondary water system. A customer service inspection (CSI) certificate shall be completed prior to providing continuous water service to new construction, on any existing service either when the water purveyor has reason to believe that cross-connections or other potential contaminant hazards exist, or after any material improvement, correction, or addition to the private water distribution facilities. Any customer service inspection certificate form which varies from the format found in commission Form 20699 must be approved by the executive director prior to being placed in use. Individuals with the following credentials shall be recognized as capable of conducting a customer service inspection certification.

For activation, modification or deactivation of water systems, please coordinate with the water utility provider American States Utility Services, Inc. (ASUS) Fort Bliss Water Services Company (FBWS), which provides the operation and maintenance on the Installation.

PLUMBING: The maximum allowable flow rates for plumbing fixtures by the Texas Commission of Environmental Quality (REFER to 30TAC§290.252) -

• Sink / lavatory faucet or a faucet aerator - 2.20 gpm at 60 pounds per square inch pressure

• Shower head - 2.5 gpm at 80 pounds per square inch pressure

• Commercial pre-rinse spray valve - 1.6 gpm

• All drinking water fountains shall be operated by a self-closing valve

• Toilet - 1.28 gpf (dual flush cannot exceed 1.28 gal. for an average flush volume of two reduced flushes & one full flush)

• Urinal - 0.5 gpf

CROSS-CONNECTION/BACK-FLOW PREVENTERS: There shall be no cross-connection, open or potential, between a system furnishing potable water and a system furnishing non-potable water. Responsible authorities must implement, administer, and maintain ongoing back-flow prevention and cross‐connection control programs to prevent back-flow; protect public water systems from the actual or potential hazards originating on the premises of end user building owners or end users; and protect public water systems from temporary connections that may impair or alter the water. The return of any water to the public system after the water has been delivered to the end user at the point of connection is an unacceptable public health concern and is opposed by AWWA.

CONTACT: Ms. Paola Soto-Montero at paola.i.soto-montero.civ@army.mil or at (915) 568-1051.

PROGRAM: Waste Water REVIEWER: Paola Soto-Montero DATE: 4/25/2024

No additional comments as requirements are addressed in section 2.7.11.4.2 of the Scope of Work. Proponent shall ensure these requirements.

Dispose of the construction related wastewater off Government property in accordance with 40 CFR 403, state, regional, and local laws, and regulations. Water discharges into the sewer system as a result of this project shall abide by the conditions and requirements of El Paso Water (EPW) Rules 9 and 15. No foreign items, construction debris, chemicals, nor oils shall be introduced into the sanitary sewer collection system.

CONTACT: Ms. Paola Soto-Montero at paola.i.soto-montero.civ@army.mil or at (915) 568-1051.

PROGRAM: Stormwater REVIEWER: Danielle Nguyen DATE: 4/24/2024

No comment.

PROGRAM: DERA REVIEWER: Danielle Nguyen DATE: 4/24/2024

No comment.

PROGRAM: Hazardous Materials REVIEWER: Victor Garcia DATE: 4/26/2024

CONCURRENCE: YES- WITH COMMENTS ATTACHMENT: NA

Any construction debris containing hazards or toxic substances such as lead, asbestos, mercury, polychlorinated biphenyls (PCB) or other known, identifiable materials shall not be disposed of in trash and recycling containers, but require special handling and disposal requirements. Hazardous materials or wastes such as oil, fuel, paints, lubricants, cleaning solvents, etc., are prohibited from being disposed of in trash and recycling containers. Violations of these prohibitions can subject the proponent and contractor to clean contaminated facilities and containers, or reimburse the government for cleaning contaminated facilities and containers. Furthermore, burying and burning any trash (hazardous or non-hazardous), chemicals and other disposable materials is prohibited and illegal. The government shall seek reimbursement for the entire costs of cleaning, removing, mitigating contamination, and other actions to restore the area and resource to its near original condition.

Prior to use of hazardous or regulated material, the Contractor shall provide the COR and DPW Environmental Division a list of methods for review and approval, pertaining to regulated/hazardous materials, storage, and disposal of waste generated.

All scrap and debris resulting from work shall be disposed off Post by the Contractor, including associated disposal fees. No material shall be disposed of in the Fort Bliss landfill. Disposal of chemical wastes, oils, bituminous materials, lead base paint material, asbestos materials, and other hazardous/ regulated material shall be in accordance with Federal, State, and local requirements.

PROGRAM: Toxic Substances Control Act REVIEWER: Victor Garcia DATE: 4/26/2024

CONCURRENCE: YES- WITH REQUIREMENTS ATTACHMENT: NA

*** ASBESTOS AND LEAD POTENTIALLY PRESENT AT BUILDING 11341 ***

DPW-ED does not have an asbestos and/or lead survey for B11341.

Per the Statement of Work (SOW) provided, section 1.4.1 includes the implementation of an Asbestos and Lead survey, providing the results to DPW-ED when completed.

Also, the SOW, Section 2.7.1.2, and 2.7.3 through 2.7.10 states that asbestos and lead, if present, will be removed by a Licensed Company. NOTE: SECTIONS 2.7.3.1 AND 2.7.3.2 MUST BE UPDATED IAW THE ASBESTOS AND LEAD SURVEY RESULTS.

The Project Management personnel must review the asbestos and lead surveys to verify if these toxic materials will be impacted by the project scope. If the project scope includes disturbing/removing asbestos/lead-containing materials, it must be done by a Licensed Company. The surveys must be provided to DPW-ED to be filed in the building folder for any future projects.

Note: if additional materials, not tested during the surveys, need to be disturbed/removed, contact DPW-ED for additional testing.

Failure to manage present hazardous materials may expose workers, building occupants, and their families to toxic substances, which include carcinogens.

PROGRAM: Hazardous Waste REVIEWER: Michelle Brennan DATE: 4/24/2024

CONCURRENCE: YES- WITH COMMENTS ATTACHMENT: NA

Upgrades, construction or repair activities will generate asbestos and/or lead waste, disposal shall be coordinated with DPW-ED.

Disposal costs shall be charged to the project or related contract as applicable. A copy of the waste profile issued by the disposal facility should be provided to DPW-ED. Waste manifests must use the Fort Bliss Environmental Protection Agency Identification Number, and only DPW-ED personnel appointed in writing by the Garrison Commander are authorized to sign the manifests on behalf of Fort Bliss.

The original manifests signed by the disposal facilities shall be provided to DPW-ED.

PROGRAM: Solid Waste REVIEWER: Michelle Brennan DATE: 4/24/2024

CONCURRENCE: YES- WITH COMMENTS ATTACHMENT: NA

Waste & Recyclables Management.

(a). Construction Waste Management. The DoD Strategic Sustainability Performance Plan (SSPP) (reference 1.q) requires that at least 60% of construction and demolition debris be diverted from the waste stream by FY2015. However, it is the Army’s intent to manage waste with the goal of Net Zero waste disposal in landfills. Therefore, projects that involve the removal of existing buildings or structures will evaluate the feasibility of deconstruction and salvage rather than conventional demolition, and will implement deconstruction wherever markets or on-site reuse opportunities exist or are anticipated.

CONSTRUCTION WASTES REQUIREMENTS: All project generated waste must be disposed of by contractor according to the following Fort Bliss requirements and regulations.

PROGRAM: AST/UST REVIEWER: Isaac Trejo DATE: 4/24/2024

CONCURRENCE: YES ATTACHMENT: NA

No comment.

PROGRAM: SPCC REVIEWER: Isaac Trejo DATE: 4/24/2024

CONCURRENCE: YES ATTACHMENT: NA

No comment.

PROGRAM: Air REVIEWER: Rita Crites DATE: 4/25/2024

CONCURRENCE: YES- WITH COMMENTS ATTACHMENT: NA

The EPA - Under the Clean Air Act-establishes National Emission Standards for Hazardous Air Pollutants (NESHAP) which includes asbestos (40 CFR Part 61, Subpart M). These regulations specify work practices for asbestos to be followed during demolitions and renovations of all facilities. To avoid duplication of efforts, Fort Bliss’ Air Program Manager relies on TSCA program manager for compliance of these NESHAP requirements as well as any documentation (manifests) originating from these projects.

Potential impacts on the quality of the environment have been considered and are documented within the attached environmental checklist. It has been concluded that this action is not segmented, and no extraordinary circumstances exist that would preclude the use of the applicable categorical exclusion identified in paragraph below.

This document does not relieve the proponent from compliance with other applicable federal, state and local environmental laws and regulations.

On the basis of this evaluation the following is appropriate:

In accordance with 32CFR 651 Appendix B, the proposed action qualifies for a CATEGORICAL EXCLUSION that does not require a Record of Environmental Consideration. (Skip to the “Approved By” section for NEPA Program Manager signature to compete the document.)

A Record of Environmental Consideration is required.

REASON FOR USING RECORD OF ENVIRONMENTAL CONSIDERATION:

NEPA Program Manager Date

Signatures below indicate agreement with the sections above including but not limited to all conditions or requirements.

Proponent (requestor) Date

Name: Adrian Trejo

Title: Division Chief: DPW-ESD

Environmental Officer Date

Name: Yvette Waychus

Title: Acting Division Chief: DPW-ED

DETERMINATION:

APPROVED BY (Concurrence is contingent upon compliance with comments provided.):

CONCURRENCE (As needed for Record of Environmental Consideration):

GUERRERO.MY

RA.1542698744

Digitally signed by

GUERRERO.MYRA.1542698744

Date: 2024.05.08 15:11:34 -06'00' 5/8/24

OFFUTT.SHANE.PA

TRICK.1104875986

Digitally signed by

OFFUTT.SHANE.PATRICK.11048

75986 Date: 2024.05.10 16:15:13 -06'00' 5/10/24

For

2024-05-21T11:51:36-0600
TREJO.ADRIAN.ALONSO.1295131639

Date11_af_date: 5/21/24

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