Record_of_Environmental_Considerations_RFQ_W912C319T0005,_AC_Bldg._183,_30_Jan_2019.pdf

DEPARTMENT OF THE ARMY

US ARMY INSTALLATION MANAGEMENT COMMAND

HEADQUARTERS, UNITED STATES ARMY GARRISON, FORT BUCHANAN

390 DOUBLE EAGLE AVE., SUITE 300

FORT BUCHANAN, PUERTO RICO 00934-4206

RECORD OF ENVIRONMENTAL CONSIDERATION

REC Number: BUC 01-28-2019

DIRECTORATE OF PUBLIC WORKS

ENVIRONMENTAL DIVISION

1. Title: New NC System for Building 183 at Fort Buchanan, Puerto Rico.

2. Description of Proposed Action: Work will include the design and repair works in connection with the "New NC System at Building 183, Fort Buchanan, PR". Work includes selective demolition Chapel AC fascia, supply and return ducts (including diffusers, dampers, insulation, filters, and return air grilles, and plastic screens. New work includes installing two (2) new rooftop package air conditioning units with humidity control, install gypsum board fascia for new ducts, paint all exterior and interior surfaces, and install new plastic screens.

3. Anticipated date of Proposed Action: FY 19

4. It has been determined that this action:

a. Is categorically excluded under the provision of CX 9.:1, Section II, 32 CFR 651, appendix B, and meets the screening criteria in Subpart D-Categorical Exclusions, paragraph 651.29, A-1 through A-3, paragraph B, 81 thru 814, paragraph C, C1 thru C4, paragraph D and paragraph E, E1thru E4. It has been determined that this action does not individually or cumulatively have significant effect on the human environment. No exceptional circumstances exist as defined in paragraph A-2 of 32 CFR Subpart D-Categorical Exclusions. There will be no environmentally controversial changes to existing environmental conditions. There are no circumstances, which would require an environmental assessment (EA) or environmental impact statement (EIS) under the National Environmental Policy Act (NEPA).

5. This document does not relieve the proponent, and/or its contractors, of compliance with applicable Federal and State Laws and Regulations. Note: The Environmental Division requirements for this project are: Sample for Asbestos Containing Materials were all negative (see enclosed negative sample table which includes all interior wall and HVAC ducts). No records for Lead Based Paints were found. The contractor must follow specification of Environmental Protection Work and Procedure Guideline enclosed. Special attention to section 1.7 (Environmental Protection Plan) and section 3.5 0/1/aste Disposal), 3.5.3 (Hazardous Waste, including asbestos & lead based paints).

Date:

Date: / J-/au/4. )<J p:/

IMBC-PWE 28 January, 2019

MEMORANDUM FOR Directorate of Public Works (IMBC-PWE/Ms. Maria A. Lopez, Director), Bldg.34 South Gate Rd., Fort Buchanan, P.R. 00934 ·

SUBJECT: New A/C System for Building 183 at Fort Buchanan, Puerto Rico.

1. References:

a. 32 CFR Part 651, Environmental Analysis of Army Actions.

b. AR 200-1, Environmental Protection and Enhancement.

c. Memorandum, Office of the Assistant Secretary of the Army Installation and Environment Sustainable Management of Waste in Military Construction, Renovation and Demolition Activities, February 06, 2006.

2. On 2.8 January, 2019, the DPW Environmental Division evaluated the subject action. The screening and revision of the proposed action was conducted IAW 32 CFR Part 651.29 (Screening Criteria).

3. Based on the evaluation performed, the proposed action meets the following screening conditions:

a. The proposed action has not been segmented to meet the definition of Categorical Exclusions described in 32 CFR 651 Appendix B

b. No exceptional circumstances exist such as:

1. Reasonable likelihood of significant effects on public health, safety, or environment.

2. Reasonable likelihood of significant environmental effects.

3. Imposition of uncertain or unique environmental risks.

4. Greater scope or size than is normal for this category of action.

5. Releases of POL's except from properly functioning engine or vehicle, application of pesticides and herbicides, or where the proposed action results in the requirement to develop or amend a Spill Prevention, Control, or Countermeasure Plan.

6. When a review of an action that might otherwise quality for a record of Non-applicability reveals that air emissions exceed the minimum levels or otherwise that a formal Clean Air Act conformity determination is required.

7. Reasonable likelihood of violating any federal, state, or local law or requirements imposed for the protection of the environment. Unresolved effect on environmentally sensitive resources such as: (i) federally listed threatened or endangered species and/or their designated critical habitats, (ii) properties listed or eligible for listing on the NatiOnal Register of Historical Places (AR 200-1 , Chapter 6-Cultural Resources), (iii) areas having special designation or recognition such as prime or unique agricultural lands; coastal zone;

8. Designated wilderness study areas; wild and scenic rivers; National Historic Landmarks;

1 OQ years floodplains; wetlands; sole source aquifers; National Wildlife Refuges; National Parks;

areas o.tcritical environmental concern; or other areas of higb ·environm.entc;1I sen~itivity, and (iv) designated cultural resources areas as described in AR 290~.:1. , · ' ·· · ·

SUBJECT: New NC System for Building 183 at Fort Buchanan, Puerto Rico.

9. Involving effects on the quality of the environment that are highly controversial.

10. Involving effects on the environment that are highly uncertain, involve unique or unknown risks, or are scientifically controversial.

11 . Establishes a precedent for future or subsequent actions that are reasonably likely to have a future significant effect.

12. Potential for degradation of already existing poor environmental conditions. · Also, initiation of a degrading influence, activity, or effect in areas not already significantly modified from their natural conditions.

13. Introduction/employment of unproven technology.

c. One or more Categorical Exclusion (CATEX) encompasses the proposed action.

1. Therefore, the proposed project is encompassed by Categorical Exclusion (g-1; Repair) .

Neither an Environmental Assessment (EA) nor an Environmental Impact Statement (EIS) is required . A Record of Environmental Consideration (REC) is enclosed for your approval and signature. However, as required by reference (b), disposal activities that involve EPNDOT regulated hazardous materials shall be coordinated with the DPW Environmental Division. In addition, use, handling, and disposal of non-hazardous and hazardous wastes must be conducted following the applicable Federal, State and local regulations.

2. Provisions:

a. Contractor must follow Environmental Protection Work and Procedure Guideline enclosed.

Special attention to section 1.7 (Environmental Protection Plan) and section 3.5 (Waste Disposal), 3.5.3 (Hazardous Waste).

b. Contractor is responsible for compliance with all Federal, State, County, or local, permits, coordination, certifications or other regulatory authorization requirements under all applicable environme~tal laws and regulations. Contractor shall then prepare and submit in draft all applicable permit applications, coordination , notices, or other required filings, together with all supporting data to the contracting officer for review. Permit applications or notifications or other documents that must be submitted by DPW will be submitted by DPW, and any documents that must be submitted by the contractor will be returned after review to the contractor for submission. No work requiring permit or other written authorization shall proceed before the Contractor has the permit or authorization or a copy.

c. Lead Based Paint (LBP) suNey is not recommended, due to the age of the Building (1988), there is no need for Lead Based Paint abatement. The threshold for lead risk assessment is building built before 1978.

d. All paints, solvent, and bituminous materials used as part of repairs and maintenance actions must be stored within protected areas. They will not be left exposed or over unprotected soils or adjacent to streams or storm water discharge points. Spill prevention measures will be required . Contractor must submit all paints and or hazardous materials product specification and safety data sheets to environmental division review and approval prior to commencing work.

SUBJECT: New A/C System for Building 183 at Fort Buchanan, Puerto Rico.

e. Puerto Rico law requires that all construction/demolition that disturbs greater than 900 square meters (0.22 acres) of land surface, or involves the addition or removal of greater than 40 cubic meters of earth, requires the submission of a Control of Erosion and Sedimentation (CES) plan to the Puerto Rico EQB. During the construction phase of the project the contractor must submit a Spill Control plan that will include procedures, instructions, and reports to be used in the event of an unforeseen spill.

A Puerto Rico Environmental Quality Board Consolidated Environmental Permits will be required. Said plan includes/covers requirements for:

a. Solid Waste Permit

b. CES Plan

c. Dust Control Plan

During the removal of the of the existing air conditioning system, all refrigerant gases must be recovered for recycling by a state certified AC technician.

f. Recommend reviewing the Sustainable Design Guide US Army Garrison Fort Buchanan (February 2016), section 2.4.1 Replacement of HVAC Components and Implementation of Energy Management and Control Systems, and 2.4.2 Right Sizing and Proper Insulation of Air Supply Ducts and of Hot and Cold Water Pipes. ·

3. · The point of contact for this action .is the undersigned

Enclosures

ANIBAL NEGRON, P.G., REM

Chief, Environmental Division