W911SG25BA012 Bldg 114 Environmental Review Form.pdf

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 to be used for only requested work as described in the narrative of the Work Order Request and/or supporting documents provided.

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.

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, specifications and/or drawings.

The DPW-Environmental Division's final review approval and concurrence is contingent on the project Work order request, Scope of Work, any and all supporting documentation not changing, work must be 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: 4/24/2025 NEPA LOG#:25-0483 Review Expiration Date: 05/23/2026

65% Design Review

Remove the existing asphalt shingle roofing system at building 114 and provide a new metal shingles roof. Project includes some wood plank deck replacement, new self-adhering underlayment, new metal roof shingles, existing wood soffit and fascia repair and paint, the reinforcement of rafters exposed at soffit, new prefinished drip edge, gutters, and downspouts. Provide a six-nail pattern at each shingle installation. Install in accordance with roofing manufacturers details required to meet manufacturer’s 30-year roof warranty 120 mph wind speed coverage. Building 114 is a historical building and the Cultural Resource Manager approval coordinated through the COR is required for all new materials and paint colors.

Previously reviewed under NEPA LOG 24-0251.

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.

• Building 114 is listed on the National Register of Historic Places

• *** LEAD PRESENT ON PROJECT AREA **

DPW-ED concurrence is contingent upon meeting all, but not limited to, the conditions and/or criteria as detailed below.

SECTION BELOW PROVIDES THE ENVIRONMENTAL REVIEW. FOR DPW-ED SUBJECT MATTER EXPERT USE

POC FOR THIS ACTION: Candice Reyes candice.v.reyes.civ@army.mil

PROGRAM: Cultural Resources-Archeology REVIEWER: Elia Perez CONCURRENCE: YES- WITH REQUIREMENTS

ATTACHMENT: NA FINALIZED DATE: 4/24/2025

Defer to the Historic Preservation Program since this is a historic property. The pictures showing are for Bldg 115.

PROGRAM: Cultural Resources-Historic PreservationREVIEWER: Donald J. Sevigny CONCURRENCE: YES- WITH REQUIREMENTS

ATTACHMENT: NA FINALIZED DATE: 4/25/2025

PROPONENT SHALL FOLLOW THESE REQUIREMENTS:

1. The DPW-ED Historic Preservation Program is required to review all phases of design, development, and implementation of this project.

2. Point of contact is D.J. Sevigny, Historic Preservation Specialist, (915) 568-3782 or donald.j.sevigny.civ@army.mil.

FOR ENVIRONMENTAL STAFF ONLY:

Appendix B, Paragraph F (Roofs), Item 1. Building 114 is listed into the National Register of Historic Places as outlined in the National

BLUF:

PROJECT DESCRIPTION:

mailto:candice.v.reyes.civ@army.mil

DPW-ED ENVIRONMENTAL REVIEW NEPA LOG #25-0483

SCLMR#: NA WO#: FE 10091 4J Doc TYPE#: 65% Review Location/Building: 114

Register nomination form dated 7 May, 1998. Building 114 is a contributing resource to the Fort Bliss Main Post Historic District as part of the First Expansion Period Group from 1913 to 1917.

PROGRAM: Natural Resources REVIEWER: Gabriel Ramirez CONCURRENCE: YES- WITH COMMENTS

ATTACHMENT: NA FINALIZED DATE: 4/24/2025

No Issues, roof replacement.

PROGRAM: Drinking Water REVIEWER: Paola Soto-Montero CONCURRENCE: YES- WITH REQUIREMENTS

ATTACHMENT: NA FINALIZED DATE: 4/29/2025

The proponent shall ensure compliance with section 2.7.4.3 & 2.7.4.4. Proponent shall update “2.7.4.3. Texas Environmental Control Quality

(TECQ)” to “Texas Commission on Environmental Quality (TCEQ).” Additionally, please note that Chapter 290 is from the Texas

Administrative Code (TAC) title 30.

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 CONCURRENCE: YES- WITH REQUIREMENTS

ATTACHMENT: NA FINALIZED DATE: 4/29/2025

Proponent shall ensure compliance with sections 2.7.6.1 & 2.7.6.2:

Dispose of the construction related wastewater off of 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: Rebecca Navarrete CONCURRENCE: YES- WITH COMMENTS

ATTACHMENT: NA FINALIZED DATE: 4/28/2025

Project intends to disturb less than an acre of land in accordance to description, therefore no additional documentation is required for the stormwater program. Proponent shall continue to ensure that no contaminants shall enter the stormwater system including sediment, oil and grease from vehicles, mud from tires, paint/stain, soaps/solvents, stucco, cement, sediment from disturbed soil.

Contact Rebecca Navarrette at rebecca.d.navarrette.civ@army.mil or (915)568-3472 to provide acreage or for guidance.

PROGRAM D.E.R.A REVIEWER: Cynthia Hernandez CONCURRENCE: YES WITH NO COMMENTS

No comment.

PROGRAM: Solid Waste REVIEWER: Cynthia Hernandez CONCURRENCE: YES- WITH COMMENTS

vii. 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 Click to enter comment. Section can be used as a communication log 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 contractors according to Fort Bliss requirements and regulations

The contractor and its subcontractors are responsible for disposal of excess soil, earth, rock or spoils, and any construction materials in

SCLMR#: NA WO#: FE 10091 4J Doc TYPE#: 65% Review Location/Building: 114 excess. The Environmental Division is not responsible for providing location, sites, and operational limits and logistics for disposal of spoils.

Any solid waste generated (non-hazardous or construction debris related) shall be disposed of and by the contractor, its subcontractor or the project proponent. All solid waste that cannot be recycled shall be disposed of at a permitted landfill or other authorized facility. Burning or burying (land disposal) is strictly prohibited by state laws, and any evidence of such will be addressed properly, and the contractor, its subcontractors and the proponent will be responsible for cleaning and removing all debris, trash and contaminated soils, water or other impacted materials, and replacing the materials, equipment or other infrastructure at the proponents, contractors and its subcontractors costs.

RECORDS & DATA REPORTING REQUIREMENT: All weight tickets and manifests for waste and diverted or recycled materials shall be submitted to the government project manager (PM) or contracting officer representative (COR). The government PM or COR will provide to DPW Environmental Division, Pollution Prevention Branch the diversion records

PROGRAM: Toxic Substances Control Act REVIEWER: Victor Garcia CONCURRENCE: YES- WITH REQUIREMENTS

ATTACHMENT: ASBESTOS/LEAD SURVEYS FINALIZED DATE: 5/22/2025

*** LEAD PRESENT ON PROJECT AREA ***

5/22/2025 – DPW-ED conducted limited asbestos and lead surveys on the project area of Building 115 (attached). No asbestos were identified, however, lead was detected on materials adjacent to the roof.

Review the attached surveys for all asbestos and lead-containing materials to verify if they will be impacted by this project. If the project scope includes disturbing asbestos and/or lead-containing materials, work must be conducted by a Licensed Abatement Company.

If additional materials, not tested in these surveys, need to be disturbed, they must first be tested for asbestos and lead. 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.

DPW-ED CONTACT: Victor Garcia at victor.h.garcia22.civ@army.mil or at (915) 568-0794.

Requirements in the case Asbestos and/or Lead Constraining Materials need to be removed:

**If disturbance of asbestos-containing materials (ACM) or LBP is anticipated, these materials shall be removed prior to performing any demolition or renovation activities**

PROPONENT SHALL FOLLOW THESE REQUIREMENTS: (Language shall be incorporated into Scope of Work)

1. ASBESTOS CONTAINING MATERIALS (ACM): Shall be removed by licensed and trained individuals (25 TAC 296.41 - 296.62) according to methodology and requirements specified by Texas Administrative Code Title 25, Part 1, Chapter 296, Sub-chapter L (§296.211

- §296.213) OR HANDLING IN PLACE: If project disturbs 10 square feet or less of ACBM for each small project or task - proponent shall follow 25TAC§296.233 for Alternative Asbestos Practices and Procedures for Small Projects and Repetitive Tasks in a Public Building. A registered asbestos abatement worker may perform a small project or repetitive task that disturbs ACBM. Written notification must be provided, as required in 25TAC§296.251. The clearance-level assessment must be conducted as required in 25TAC§296.213.

2. LEAD-BASED PAINT (LBP): Lead abatement is defined as the complete removal of the hazardous substance from the building substrate.

For lead-related work which only involves stabilizing and encapsulating lead-containing materials, e.g. peeling paint, drilling into painted walls, the customer shall provide DPW-ED the start date of the lead-related work, and the licensed lead contractor information. The customer can obtain additional guidance from DPW-ED on lead-related work to include engineering controls, personnel safety and work practices. According to methodology and requirements specified by Texas Administrative Code Title 25, Part 1, Chapter 295, Sub-chapter I

(§295.201 - §295.220) OR HANDLING Lead-based paint activities, as defined in §295.202 of this title (relating to Definitions) shall only be conducted according to the procedures and standards contained in §295.212 of this title (relating to Standards for Conducting Lead-

Based Paint Activities). However, the standards contained in §295.212 of this title do not apply when treating paint-lead hazards less than:(1) two square feet of deteriorated lead-based paint per room or equivalent;(2) 20 square feet of deteriorated paint on the exterior building, or (3) 10% of the total surface area of deteriorated paint on an interior or exterior type of component with a small surface area.

3. NOTIFICATIONS: A proper notification shall be submitted to the State of Jurisdiction (25 TAC 296.251) no less than 10 working days prior to commencement of abatement activity and a copy shall be provided to DPW-ED. If the amounts of ACM are less than the notification thresholds, the customer shall notify DPW-ED of the start date of the small-scale abatement, and provide a plan containing the licensed abatement company information, abatement methodologies, and the anticipated amounts of materials to be removed.

4. FEES & WASTE MANIFEST: The customer shall also provide DPW-ED with a copy of the waste manifest and clearance report, i.e., air

SCLMR#: NA WO#: FE 10091 4J Doc TYPE#: 65% Review Location/Building: 114 sampling, if applicable. The contractor will also be responsible for all State Asbestos Abatement/Demolition Notification fees. DPW-ED personnel must sign the waste manifest. The manifest return address must be DPW-ED

5. RIGHT-TO-KNOW: It is recommended that prior to conducting any activities which could disturb building materials present at the site that this study be reviewed to ensure that current site conditions are reflected by the report and that additional materials have not been installed. Contractors who are tasked with housekeeping activities, conducting repairs, renovations or demolition of the structure should be provided a copy of this in order to provide OSHA Right to Know communication to their workforce and for use in determining whether any special handling is required by their company policy or OSHA compliance personnel. (OSHA 1910.1001)

6. FOR NEW BUILDING MATERIALS: The Project Engineer, Architect or authorized persons shall submit to the Environmental Division, Toxic Substances Program Manager or alternate government program manager a letter verifying and certifying that all building materials used in the construction, renovation or remodeling contains no toxic substances, i.e. asbestos, lead, or other regulated toxic substances.

7.SUSPECT MATERIALS/INCIDENTAL ENCOUNTER: Should any suspect ACM be encountered/disturbed as part of the renovation project these materials will need to be sampled prior renovations or suspect material could be presumed to be ACM and managed accordingly. Upon discovery, the government representative or contracting officer representative (COR), once notified by the contractor

PM shall contact DPW‐ED.

8. Asbestos & Lead Waste

If upgrade, 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.

Generator’s address for waste manifest:

Fort Bliss DPW-Environmental Division

624 Taylor Rd.

Fort Bliss, TX 79916

915-568-3782

If additional materials, not tested in these surveys, need to be disturbed, they must first be tested for asbestos and lead. 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.

DPW-ED CONTACT: Victor Garcia at victor.h.garcia22.civ@army.mil or at (915) 568-0794

Lead present on project area and asbestos survey to be conducted by DPW-ED.

PROGRAM: Air REVIEWER: Victor Garcia CONCURRENCE: YES- WITH REQUIREMENTS

ATTACHMENT: NA FINALIZED DATE: 4/30/2025

HVAC REQUIREMENTS as applicable:

Technicians that work on refrigerant-containing appliances must be certified by an EPA-approved training provider for the type of equipment on which they work [40 CFR 82.161(a)(1)].

Technicians contracted to install new HVAC/R equipment and/or service existing equipment are also responsible to follow Fort Bliss

Refrigerant Management Plan and are subject to the same certification requirements.

No person maintaining, servicing, repairing, or disposing of appliances may knowingly vent or otherwise release into the environment any refrigerant [40 CFR 82.154(a)(1)].

New purchases of HVAC/R equipment shall use an EPA Significant New Alternatives Policy Program (SNAP) approved refrigerant with an ODS of zero-www.epa.gov/snap.

Provide specifications of new/old unit to Victor Garcia at victor.h.garcia22.civ@army.mil

Failure to report any of the emissions generating equipment listed above may cause regulatory violations and fines.

mailto:victor.h.garcia22.civ@army.mil

SCLMR#: NA WO#: FE 10091 4J Doc TYPE#: 65% Review Location/Building: 114

PROGRAM: Hazardous Materials REVIEWER: Samuel Del Toro CONCURRENCE: YES- WITH COMMENTS

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.

PROGRAM: Hazardous Waste REVIEWER: Michelle Brennan CONCURRENCE: YES- WITH COMMENTS

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.

For more information on Hazardous Waste compliance, please call Michelle Brennan @ 915-568-5724 (office) or by email:

michelle.s.brennan.civ@army.mil.

PROGRAM: AST/UST REVIEWER: Isaac Trejo CONCURRENCE: YES WITH NO COMMENTS

PROGRAM: SPCC REVIEWER: Isaac Trejo CONCURRENCE: YES WITH NO COMMENTS

SCLMR#: NA WO#: FE 10091 4J Doc TYPE#: 65% Review Location/Building: 114

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 (CX) that does not require a Record of Environmental Consideration (REC).

(Skip to the “Approved By” section for NEPA Program Manager signature to compete the document.)

REASONING FOR USING CX:

☐ A Record of Environmental Consideration (REC) is required.

REASONING FOR USING REC: This action is Categorically Excluded under the provisions of 32 CFR Part 651, Appendix B, Section II, (g)(1), for routine repair and maintenance of historic buildings, airfields, grounds, equipment, and other facilities and for removal and disposal of asbestos containing material and/or lead-based paint in accordance with applicable regulations for which a

Record of Environmental Consideration is required. There are no extraordinary circumstances as defined in 32 CFR § 651.29

(b), and all screening criteria in 32 CFR § 651.29 (a)(1-3) are satisfied. The survey required for action is covered under an annual

REC # 25-0515. Sampling and Analytical Testing for asbestos containing materials and/or lead based paint on or within all Fort

Bliss Cantonment Buildings from the period of 01 April 2025 through 31 March 2026 (365 days).

Claudia Ramirez Date

NEPA Program Manager

APPROVED BY: (SIGNATORY CONCURRENCE IS CONTINGENT UPON PROPONENT COMPLIANCE WITH GUIDANCE PROVIDED ABOVE)

DETERMINATION:

SCLMR#: NA WO#: FE 10091 4J Doc TYPE#: 65% Review Location/Building: 114

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

Proponent (requestor) Date

Name: Carl Aufdenkampe

Title: Division Chief, DPW-ESD

Environmental Officer Date

Name: Shane Offutt

Title: Division Chief, DPW-ED

CONCURRENCE (As needed for Record of Environmental Consideration):