J-02_00_000-13_Record_of_Environmental_Consideration_(REC).pdf

RECORD OF ENVIRONMENTAL CONSIDERATION (REC)

Directorate of Public Works, Environmental Division (ENV)

REC # 17-0118

1. Project Title

USACE Preventative Maintenance and Repair Contract

2. Organization/POC Name, address, phone number, and email address

USACE

3. How is the project going to be executed?

DPW In House U.S. Army Corps of Engineers

Contractor Self Help Project

Other

4. Approval of REC required by date:

5. Repair/Maintenance & Small Construction Activities. Check all that apply:

Tree Removal/Pruning. If so, how many trees to be removed:

New Construction

Interior building repairs/improvements. If so, specify Building and Room #

Replacement of Utilities

Roofing Materials Disturbance

Replacing Floor Tile and/or Carpet

Soil/Land Disturbance. If so, how many acres?

Karla York Mew

RECORD OF ENVIRONMENTAL CONSIDERATION (REC)

Directorate of Public Works, Environmental Division (ENV)

6. Detailed description. Include Scope of Work (SOW), if available. Please explain any checked boxes.

Perform preventative maintenance activities and repairs to all buildings referenced in the attached FJ PMS spreadsheet. Work also includes maintenance of generators, USTs, ASTs, oil/water separators, and washracks (see optional_equipment_inventory.xls for list)

7. If applicable, attach a site specific map of the project area that shows the location relative to a prominent landmark such as a road or building. (Attach map to email.)

Submit REC

REC: 17-0118

8. The Environmental Division (ENV) has reviewed the proposed project. The project must be completed as described above or a new REC must be submitted if this project is modified or expanded in a manner that was not considered in this review or has not been initiated within one year. This REC is not an approval to begin the project, it only outlines the environmental and natural resource requirements as follows:

a. Numerous buildings on Fort Jackson were constructed prior to 1990 and have asbestos containing material (ACM). Products such as ceiling tiles, floor tiles, adhesives, cementitious wallboard, joint compound, skim coating, roofing materials, thermal system insulation, fire proofing, etc. are considered suspect ACM and have a high potential for disturbance when performing preventive maintenance activities. South Carolina Department of Health and

Environmental Control (SCDHEC) requires that prior to any renovation or demolition activities, a current (within 3 years) building survey or scope specific analysis of suspect ACM be conducted. The most recent surveys are maintained by the Environmental Management Branch within the Directorate of Public Works (DPW) and can be reviewed at any time.

b. In order to safely perform the duties that are required under this contact, any personnel with the potential to disturb ACM shall attend an Environmental Protection Agency (EPA) certified

Asbestos Operation and Maintenance (O&M) Workers Course and obtain SCDHEC group licensing. This training will assist the technician(s) in recognizing materials that are suspect asbestos containing. It will allow the technician to perform activities when the amount of regulated ACM (RACM) disturbed does not exceed that which may fit in a 6 mil polyethylene bag measuring no greater than 60 inches, or one asbestos glove bag. The training will also give insight to notification requirements, worker's protection, proper work practices, clean-up procedures, and disposal requirements. It is the responsibility of the contractor to ensure that all technicians that attend the EPA Asbestos O&M Workers Course maintain certification for the life of this contract. The contractor has sole responsibility in identifying and assessing all potential asbestos disturbances for its employees prior to performing any maintenance or repair activities. The contractor shall notify the Toxic Substance Program Manager prior to disturbing any RACM. For additional information, contact LaVaughn Berry, Toxic Substance Program

Manager, at 751-3838.

c. Pre-Abatement Requirement: Four (4) days prior to starting any asbestos abatement work activities, the Contractor’s Project Manager or government COR shall hand carry or email (to lavaughn.a.berry.civ@mail.mil) a copy of the approved SCDHEC asbestos notification to the

Toxic Substance Program Manager in Bldg. 2563, Rm 106.

Pre-Abatement Requirements: The Contractor shall provide the Contracting Office

Representative (COR) a copy of the asbestos abatement plan for review by the Environmental

Management Branch at least one week prior to starting any abatement work activities. The plan shall identify specific work practices that will be used to abate the ACM. Four (4) days prior to starting any abatement work activities, the Contractor’s Project Manager or government COR shall hand carry or email (to lavaughn.a.berry.civ@mail.mil) a copy of the approved SCDHEC asbestos notification to the Toxic Substance Program Manager in Bldg. 2563, Rm 106.

Post-Abatement Requirements: Within 45 days of completion of the abatement phase of the project, the Contractor shall submit the following documentation to the government COR for project records retention:

- Copy of State Asbestos Project Licenses

- Copy of the Certificate of Liability Insurance coverage documentation

- Copy of EPA training certificates and DHEC Licenses for individuals on the job site.

- Copy of the abatement activity log, and sign in/out sheets (for multi-day projects)

- Copy of third-party air monitoring and final clearance results (if required)

- Copy of the Asbestos Waste Shipment Record and Landfill Disposal Weight Tickets

d. The contractor shall manage hazardous substances, including lamps (light bulbs), rechargeable batteries, and mercury containing equipment, in accordance with Federal, State, local, and military regulations. The Fort Jackson Hazardous Substance Management Plan

(HSMP), dated September 2014, may be used for guidance. The HSMP is located at:

http://jackson.armylive.dodlive.mil/files/2014/05/HSMP-2014.pdf. The contractor is responsible for hazardous substance spill prevention, training, clean up, and reporting, and must comply with the Fort Jackson Spill Response Plan (page 16 of the HSMP). For additional information, contact the Hazardous Substance Program Manager at 751-4231.

e. The Contractor shall properly dispose of any and all contaminated debris and waste generated during the project in accordance with State environmental regulations. Hazardous waste manifests, non-hazardous waste manifests, bills of lading, and any other documentation requiring a generator’s signature must be signed by the primary or secondary Fort Jackson Hazardous

Substance Program Manager. The documentation must be provided to the Hazardous Substance

Program Manager at least one week prior to shipment. The Generator ID Number, name, mailing address, and phone number are shown below.

SC3210020449

US ARMY GARRISON, FORT JACKSON

ENVIRONMENTAL DIVISION

2562 ESSAYONS WAY

FORT JACKSON SC 29207-5608

803-751-4231

f. The contractor shall divert (i.e. reuse, recycle, or compost) at least 50% of municipal solid waste and 60% of construction and demolition waste from landfills. All reused materials, recyclables, yard waste, and trash that are transported off-post must be reported to the COR by the tenth day of the following month and upon completion of the project. The report must identify the amount, by weight, of waste reused, recycled, composted, or disposed, and the name of the receiving facility. The COR shall provide a copy of this report to the Environmental

Division within 10 days of receipt. A tracking form is located at http://jackson.armylive.dodlive.mil/files/2014/05/Construction-and-Demolition-Waste-

Management-Form.pdf. Exception: Carpet that has asbestos containing carpet mastic cannot be recycled. For additional information, contact Lisa McKnight, Solid Waste Program Manager, at

751-5971 or lisa.a.mcknight11.ctr@mail.mil.

http://jackson.armylive.dodlive.mil/files/2014/05/HSMP-2014.pdf http://jackson.armylive.dodlive.mil/files/2014/05/Construction-and-Demolition-Waste-Management-Form.pdf http://jackson.armylive.dodlive.mil/files/2014/05/Construction-and-Demolition-Waste-Management-Form.pdf mailto:lisa.a.mcknight11.ctr@mail.mil

g. The proposed USACE Preventative Maintenance and Repair Contract is not anticipated to adversely impact any known SMWU, AOC, MMRP or ORAP Investigation Project Areas within the Installation Restoration Program. While conducting the Fort Jackson Oil Water Separator

(OWS) inspections and maintenance (as denoted in the document entitled

J_1502000_03_Optional_equipment_Inventory), any indication(s) of broken piping, OWS compromised structure, etc. which may have potentially released material to the soil, subsurface soil, or groundwater will require notification to the ENV Division within 24 hours. For additional information, contact Zachary Tice, IRP Program Manager, at 803-751-7332 or at

Zachary.A.Tice.ctr@mail.mil.

h. The contractor shall ensure the addition and removal of any type of refrigerant is performed by a mechanic certified to US Environmental Protection Agency, Title VI standards. Refrigerant must be handled, stored and disposed IAW Federal regulations. Use of Class I Ozone Depleting

Chemicals is prohibited. If the refrigerant removed from the unit is R-22, the contractor shall collect the R-22 in an approved, properly labeled container and turn it in to DPW-ENV.

Information pertaining to the newly installed unit(s) must be submitted to Christy Pollock. This information is to include (but not limited to) unit location, installation date, manufacturer, model, serial number, fuel source (if applicable) and manufacturers suggested maintenance schedule.

For additional information, contact Christy Pollock, Air Quality Program Manager, at 803-751-

6629 or Christina.b.pollock.civ@mail.mil.

i. If the proposed project includes the addition of an air emissions source(s) and/or the modification of an existing source(s) which results in an increase of air emissions, a construction permit or a construction permit exemption must be obtained from the South Carolina Department of Health and Environmental Control (DHEC), Bureau of Air Quality (BAQ). The construction permit or permit exemption must be received from BAQ prior to the initiation of this project.

The permitting process may take as many as 180 days to complete. Coordinate with Christy

Pollock, Air Quality Program Manager, at 751-6629 or christina.b.pollock.civ@mail.mil.

j. The proponent must meet the requirements of federal regulations 40 CFR Part 60 IIII, JJJJ or

40 CFR Part 63 ZZZZ when performing preventive maintenance on stationary generators. All maintenance documentation for the generators must be provided to Christy Pollock. For additional information, contact Christy Pollock, Air Quality Program Manager, at 751-6629 or christina.b.pollock.civ@mail.mil.

k. When cleaning out Oil Water Separators (OWS) and Washracks, the contractor shall coordinate with DPW ENV. All disposal documentation must be signed by DPW ENV and copies of final disposal disposition must be provided. For additional information, contact Patrick

Green, Wastewater Program Manager, at 803-751-5904 or Patrick.l.green.civ@mail.mil.

l. The contractor shall perform tightness testing and leak detector function checks on UST systems in accordance with state and federal regulations within 365 days of the last test. The contractor shall perform cathodic protection system testing in accordance with state and federal regulations within 3 years of the last test. Copies of the final report for all UST testing must be submitted to DPW ENV. For additional information, contact Mark Merritt, SPCC Program

Manager, at 803-751-9511 or mark.d.merritt6.civ@mail.mil.

mailto:Zachary.A.Tice.ctr@mail.mil mailto:Christina.b.pollock.civ@mail.mil mailto:christina.b.pollock.civ@mail.mil mailto:christina.b.pollock.civ@mail.mil mailto:Patrick.l.green.civ@mail.mil mailto:mark.d.merritt6.civ@mail.mil

m. Backflow Prevention Devices must be inspected annually by a certified backflow prevention tester. Results of the test, including failures, repairs made to devices failing inspection, and subsequent testing of repaired devices shall be reported to ENV. Reporting should also include building number and device location. Any device that is taken out of service, either permanently or for replacement, shall be reported to ENV. For additional information, contact the Drinking

Water Program Manager at 751-4231.

9. SUBMITTALS DUE TO THE DPW ENVIRONMENTAL DIVISION:

NON-HAZARDOUS, UNIVERSAL WASTE (UW), HAZARDOUS WASTE (HW):

At least one week prior to shipment:

- Waste Profile Form and all supporting documents (Safety Data Sheet, laboratory analysis).

- Shipping document (such as Bill of Lading or Manifest).

- Land Disposal Restriction Form (must accompany HW manifest).

AIR QUALITY

Within one week of completion:

- Information on newly installed unit(s), including: location, install date, manufacturer, model, serial number, fuel source, and maintenance schedule.

- Generator maintenance documentation.

ASBESTOS

Pre-Abatement (at least 1 week prior to the start of the project)

- Asbestos Abatement Plan

Pre-Abatement (4 days prior to the start of the project)

- SCDHEC approved Asbestos Abatement Project License

Post-Abatement (Within 45 days of completion)

- Copy of State Asbestos Project Licenses

- Copy of the Certificate of Liability Insurance coverage documentation

- Copy of EPA training certificates and DHEC Licenses for individuals on the job site.

- Copy of the abatement activity log, and sign in/out sheets (for multi-day projects)

- Copy of third-party air monitoring and final clearance results (if required)

- Copy of the Asbestos Waste Shipment Record and Landfill Disposal Weight Tickets

IRP

Within 24 Hours:

- Any indication(s) of broken piping, OWS compromised structure, etc. which may have potentially released material to the soil, subsurface soil, or groundwater

CONSTRUCTION AND DEMOLITION (C&D)

By the tenth day of the following month and upon completion of the project:

- C&D Waste Management Form -

(http://jackson.armylive.dodlive.mil/files/2014/05/Construction-and-Demolition-Waste-

Management-Form.pdf)

UNDERGROUND STORAGE TANKS

- Annual UST tightness testing reports

- Annual UST leak detector function check reports

- Cathodic protection system testing reports

DRINKING WATER

- Backflow prevention inspector certifications

- Annual backflow prevention device inspection report

- Notification of backflow prevention devices taken out of service

10. NEPA Review

a. The proposed project is adequately covered in an EA/EIS entitled:

b. The proposed project is categorically excluded under the provisions of CX g(1), 32 CFR Part

651: Routine repair and maintenance of buildings, airfields, grounds, equipment, and other facilities. Examples include, but are not limited to: Removal and disposal of asbestos-containing material (for example, roof material and floor tile) or lead-based paint in accordance with applicable regulations; removal of dead, diseased, or damaged trees; and repair of roofs, doors, windows, or fixtures (REC required for removal and disposal of asbestos-containing material and lead-based paint or work on historic structures).

11. For additional information, contact Matt Holstein, ENV, at 803-751-4078 or matthew.s.holstein.ctr@mail.mil.

3/21/2017

X Matthew Holstein

Matthew S Holstein

Signed by: HOLSTEIN.MATTHEW.S.1297038008

Signature: National Environmental Policy Act Coordinator, Environmental Management

Branch

3/21/2017

X Barbara S. Williams

Barbara Williams

Signed by: WILLIAMS.BARBARA.S.1229241784

Signature: Chief, Environmental Management Branch http://jackson.armylive.dodlive.mil/files/2014/05/Construction-and-Demolition-Waste-Management-Form.pdf http://jackson.armylive.dodlive.mil/files/2014/05/Construction-and-Demolition-Waste-Management-Form.pdf mailto:matthew.s.holstein.ctr@mail.mil