W912QR21R0006_Environmental_Assessment-0002.pdf
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This request for proposal from the U.S. Army Corps of Engineers Louisville District seeks a firm-fixed-price contract to replace and construct a Type III hydrant fuel system at Wright-Patterson Air Force Base in Ohio. The project scope includes demolishing an outdated pump house and four underground storage tanks, and constructing a new pump house, two aboveground storage tanks, tanker truck offload connection, and hydrant hose truck checkout station. The magnitude of construction is estimated between $10 million to $25 million. The North American Industry Classification System code is 237120. The procurement is a full and open competition with application of the HUBZone 10% price evaluation preference. Proposals will be evaluated using best value tradeoff, considering past performance, technical, and price factors. Discussions are not planned but may be held at the government's discretion.
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December
W912QR21R0006-0002
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COVER SHEET
FINAL
ENVIRONMENTAL ASSESSMENT
DEFENSE LOGISTICS AGENCY
REPLACE HYDRANT FUELING SYSTEM
CONSTRUCTION PROJECT AT
WRIGHT-PATTERSON AIR FORCE BASE, OHIO
Responsible Agency: 88th Civil Engineer Group (88 CEG), Wright-Patterson Air Force Base (WPAFB/Base), Ohio
Affected Location: WPAFB, Ohio
Proposed Action: Demolish and replace existing Type II fuel hydrant system with a modern Type III fuel hydrant system.
Report Designation: Draft-Final Environmental Assessment (EA)
Written comments and inquiries regarding this document should be directed to 88th Air Base Wing (ABW)/Public Affairs, 5135 Pearson Road, Building 10, Room 252, WPAFB, Ohio, 45433, 88abw.pa@us.af.mil.
Abstract: The purpose and need of this environmental assessment is to provide a safer, more reliable and automated system to deliver jet fuel to the aircraft on the West Ramp of WPAFB in compliance with the 15 July 2015 revisions to 40 CFR 280 underground storage tank (UST) regulations, which became effective 15 July 2018. The original Type II hydrant fuel system that was installed in the early 1960s does not comply with current regulations.
The analysis in the EA considers alternatives and the No-Action Alternative, and will aid in determining whether a Finding of No Significant Impact (FONSI) can be prepared or whether an Environmental Impact Statement (EIS) is needed.
Final EA - DLA Replace Hydrant Fueling System, WPAFB December 2019
Contents
ACRONYMS AND ABBREVIATIONS
LIST OF FIGURES
LIST OF TABLES
SECTION 1 – PURPOSE OF AND NEED FOR ACTION
1.1 INTRODUCTION
1.2 PURPOSE OF THE ACTION
1.3 NEED OF THE ACTION
1.4 DECISION TO BE MADE
1.5 COOPERATING AGENCY AND INTERGOVERNMENTAL
COORDINATION/CONSULTATIONS
1.5.1 Interagency/Intergovernmental Coordination/Consultations
1.5.2 Government to Government Consultation
1.6 PUBLIC AND AGENCY REVIEW OF EA
SECTION 2 – DESCRIPTION OF PROPOSED ACTION AND ALTERNATIVES
2.1 INTRODUCTION
2.2 PROPOSED ACTION
2.3 SELECTION STANDARDS
2.4 NO ACTION ALTERNATIVE
2.5 ALTERNATIVES ELIMINATED from FURTHER STUDY
SECTION 3 – AFFECTED ENVIRONMENT
3.1 SCOPE OF THE ANALYSIS
3.2 LAND USE/NOISE
3.3 AIR QUALITY
3.3.1 Attainment Status
3.3.2 General Conformity Applicability
3.4 WATER RESOURCES
3.4.1 Surface Water
3.4.2 Ground Water………………………………………………………………………………………………………………………...21
3.4.3 Floodplains
3.4.4 Wetlands
3.5 SAFETY AND OCCUPATIONAL HEALTH
3.6 HAZARDOUS MATERIALS/WASTE
3.7 BIOLOGICAL/NATURAL RESOURCES
3.8 CULTURAL RESOURCES
3.9 EARTH RESOURCES
3.10 SOCIOECONOMIC RESOURCES
3.10.1 Affected Environment
3.10.2 Environmental Consequences
3.11 ENVIRONMENTAL JUSTICE
3.11.1 Affected Environment
3.11.2 Environmental Consequences
SECTION 4 – ENVIRONMENTAL CONSEQUENCES AND CUMULATIVE EFFECTS
4.1 SCOPE OF THE ANALYSIS
4.2 LAND USE/NOISE
4.2.1 Land Use Evaluation Criteria
4.2.2 Noise Evaluation Criteria
4.2.3 Proposed Action
4.2.4 No Action Alternative
4.3 AIR QUALITY
4.3.1 Evaluation Criteria
4.3.2 Proposed Action
4.3.3 No Action Alternative
4.4 WATER RESOURCES
4.4.1 Evaluation Criteria
4.4.2 Proposed Action
4.4.3 No Action Alternative
4.5 SAFETY AND OCCUPATIONAL HEALTH
4.5.1 Evaluation Criteria
4.5.2 Proposed Action
4.5.3 No Action Alternative
4.6 HAZARDOUS MATERIALS/WASTE
4.6.1 Evaluation Criteria
4.6.2 Proposed Action
4.6.3 No Action Alternative
4.7 BIOLOGICAL/NATURAL RESOURCES
4.7.1 Evaluation Criteria
4.7.2 Proposed Action
4.7.3 No Action Alternative
4.8 CULTURAL RESOURCES
4.8.1 Evaluation Criteria
4.8.2 Proposed Action
4.8.3 No Action Alternative
4.9 EARTH RESOURCES
4.9.1 Evaluation Criteria
4.9.2 Proposed Action
4.9.3 No Action Alternative
4.10 SOCIOECONOMIC RESOURCES/ENVIRONMENTAL JUSTICE
4.10.1 Evaluation Criteria
4.10.2 Proposed Action
4.10.3 No Action Alternative
4.11 CUMULATIVE EFFECTS
4.11.1 Projects Identified for Potential Cumulative Effects
4.11.2 Analysis of Cumulative Effects
SECTION 5 – LIST OF PERSONS CONTACTED
SECTION 6 – REFERENCES
APPENDICES
ACRONYMS AND ABBREVIATIONS
ACM Asbestos Containing Material AF Air Force AFCEC Air Force Civil Engineer Center AFMC Air Force Material Command AFOSH AF Occupational and Environmental Safety, Fire Protection, and Health AFPD Air Force Policy Directive AICUZ Air Installation Compatible Use Zone AQCR Air Quality Control Region ARPA Archeological Resources Protection Act AST Aboveground Storage Tank BASH Bird/Wildlife Aircraft Strike Hazard BLS Bureau of Labor Statistics CAA Clean Air Act CDC Child Development Center CEG Civil Engineer Group CEQ Council on Environmental Quality CES Civil Engineer Squadron CFR Code of Federal Regulations CGP Construction General Permit CO Carbon Monoxide CWA Clean Water Act dB Decibel DLA Defense Logistics Agency DoD Department of Defense EA Environmental Assessment EIFS Economic Impact Forecast System EIS Environmental Impact Statement EISA Energy Independence and Security Act EO Executive Order EP Environmental Professional ESA Endangered Species Act FME Foreign Material Exploitation FONSI Finding of No Significant Impact FS/RS Fire Structural/Rescue Station GCP General Construction Permit GPM Gallons per Minute HHT Hydrant Hose Truck ICRMP Integrated Cultural Resources Management Plan INRMP Integrated Natural Resources Management Plan LBP Lead Based Paint
MA Metropolitan Area MBTA Migratory Bird Treaty Act MCD Miami Conservancy District MSL Mean Sea Level NAAQS National Ambient Air Quality Standards NEPA National Environmental Policy Act NFPA National Fire Protection Association NHPA National Historic Preservation Act NOAA National Oceanic and Atmospheric Administration NO2 Nitrogen Dioxide NPDES National Pollutant Discharge Elimination System NR National Registry NRHP National Register of Historic Places NRCS Natural Resource Conservation Service O3 Ozone ODNR Ohio Department of Natural Resources OEPA Ohio Environmental Protection Agency OSHA Occupational Safety and Health Act (Administration) OU Operable Unit Pb Lead PM Particulate Matter POL Petroleum, Oil, and Lubricants PPE Personal Protective Equipment RCRA Resource Conservation and Recovery Act ROI Region of Influence SHPO State Historic Preservation Office SO2 Sulfur Dioxide SWMP Storm Water Management Plan SWPPP Storm Water Pollution Prevention Plan TMDL Total Maximum Daily Load TSCA Toxic Substance Control Act UFC Unified Facilities Criteria USACE United States Army Corps of Engineers USAF United States Air Force USDA U.S. Department of Agriculture USC United States Code USEPA United States Environmental Protection Agency USFWS United States Fish and Wildlife Service UST Underground Storage Tank VOC Volatile Organic Compound WPAFB Wright-Patterson Air Force Base
LIST OF FIGURES
Figure Title Page
1 Wright-Patterson Air Force Base 9
2 Project Location 10
3 Existing Fuel Component Layout 11
4 Proposed Action 13
5 Storm Water Flow for Project Location 21
6 Cumulative Effects Locations 43
LIST OF TABLES
Table Title Page
3-1 WPAFB Economic and Demographic Characteristics 30
4-1 Noise Levels of Construction Equipment 34
4-2 Emission Estimates 36
4-3 DoD Past, Present, and Reasonably Foreseeable Actions
SECTION 1 – PURPOSE OF AND NEED FOR ACTION
1.1 INTRODUCTION
The United States Army Corps of Engineers (USACE) has prepared this Environmental Assessment (EA) for the United States Air Force (USAF) in accordance with the National Environmental Policy Act (NEPA) of 1969 (42 U.S. Code [USC] §4321-4370h), as implemented by the Council on Environmental Quality (CEQ) Regulations (40 Code of Federal Regulations [CFR] Parts 1500-1508), and Air Force regulations for implementing NEPA (32 CFR Part 989).
The EA is used when a proposed action is one not usually requiring an Environmental Impact Statement (EIS) but is not categorically excluded. Every EA must lead to a Finding of No Significant Impact (FONSI), a decision to prepare an EIS, or no action on the proposal (32 CFR 989.14)
Figure 1. Wright-Patterson AFB.
WPAFB is located in Greene and Montgomery counties, Ohio, approximately 10 miles east of Dayton, Ohio (Figure 1). WPAFB encompasses 8,145 acres and is classified as non-industrial with mixed development. The physical layout of the installation is divided into two distinct areas, Area A and Area B.
The West Ramp is located northwest of the runway in Area A (Figure 2). The proposed construction site is approximately 3.7 acres along the northwest edge of the aircraft parking apron and is the current petroleum, oil and lubricants (POL) pumphouse and underground storage tank (UST) location (see Figure 3, Section 2.2).
Figure 2. Project Location.
1.2 PURPOSE OF THE ACTION
The purpose of this proposed action would replace the current and antiquated Type II hydrant fuel system installed in 1965 that services the West Ramp at WPAFB with a Type III hydrant system.
This system would provide greater safety, decrease potential environmental consequence and improve fuel receipt, storage, and issue capabilities to enhance the system’s capability to support its mission.
The increased fuel storage with this project, from 200,000 gallons to 420,000 gallons is required to meet mission requirements as well as allow for the increased settling time of the larger capacity tanks before fuel distribution can occur. The 210,000 gallon aboveground storage tank (AST) is standard for the Type III system and this meets the mission requirements. The second AST ensures proper settling of impurities in the fuel from transfer operations before distribution to the aircraft (AF 2016 & DoD 2012). Please note the smallest American Petroleum Institute Standard 650 tank size in DoD Standard Design AW 78-24-27 (Aboveground Vertical Steel Fuel Tanks with Fixed Roofs) is a 5,000 barrel (usable capacity) tank (Burns 2017).
1.3 NEED OF THE ACTION
The need of this action is to replace the current Type II hydrant system that consists of four single-wall USTs each with a single vertical turbine hydrant pump, which provides 600 gallons per minute
(gpm) of jet fuel and requires manual operation of at least two technicians. Fuel flowing at 600 gpm is sufficient for refueling one aircraft at a time, but when two aircraft are refueled (maximum for the Type II system) the flow decreases to 200 gpm per aircraft increasing refueling times. The Type III system will greatly increase the gpm allowing the simultaneous refueling of up to four aircraft.
Figure 3. Existing Fuel Component Layout
The 40 CFR 280 regulations for USTs previously excluded airport hydrant systems from regulation, but the revised document published on 15 July 2015 removes this exclusion.
Regulation of the four 50,000 gallon USTs went effective on 15 July 2018. These revised regulations require the installation to either remove the tanks from service or prepare for the containment and monitoring requirements of the regulations (Burns 2017).
The current hydrant system is restricted to one way it can accept fuel for tank filling operations and that is through a supply line from the bulk fuel storage area on the east side of the base. Any interruption of this fuel supply will require fuel truck refueling of the mission aircraft increasing manpower and servicing time requirements affecting mission effectiveness.
1.4 DECISION TO BE MADE
This EA presents the proposal to construct a Type III Hydrant System at WPAFB. The Type III Hydrant System offers a maximum of 2400 gpm that will allow for the simultaneous refueling of up to four C-17 aircraft with fuel flow at each aircraft of 600 gpm. This system also operates automatically reducing the number of personnel required for operations and operates on a continuous loop eliminating dead spaces where fuel can stagnate over time. The decision to construct a Type III Hydrant System at WPAFB would enable the DLA to safely and efficiently provide fuel to meet the AF flying mission needs.
If the analyses presented in the EA indicate that implementation of the preferred alternative would not result in significant environmental impacts, a FONSI would be prepared. A FONSI briefly presents reasons why a preferred alternative would not have a significant effect on the human environment and why an EIS is unnecessary. If significant environmental issues would result that cannot be mitigated to insignificance, an EIS would be required, or the preferred alternative would be abandoned and no action would be taken.
1.5 COOPERATING AGENCY AND INTERGOVERNMENTAL
COORDINATION/CONSULTATIONS
1.5.1 Interagency/Intergovernmental Coordination/Consultations Federal Agencies
U.S. Fish and Wildlife Service U.S. Environmental Protection Agency U.S. Department of Housing and Urban Development.
State Agencies
Ohio Department of Natural Resources Ohio Department of Transportation Miami Conservancy District Ohio Historic Preservation Office.
1.5.2 Government to Government Consultation
Tribal Governments:
Sac and Fox of the Mississippi in Iowa Saginaw Chippewa Indian Tribe Keweenaw Bay Indian Community Cherokee Nation Seneca Nation of Indians Seneca Cayuga Tribe of Oklahoma.
1.6 PUBLIC AND AGENCY REVIEW OF EA
A Notice of Availability (NOA) for the EA and FONSI was published in the Dayton Daily News and the Fairborn Daily Herald on 26 October 2019, initiating a 30-day public review period. The EA and FONSI was made available in the Greene County Public Library, Fairborn Branch. An electronic copy of the EA was available for review on the WPAFB Environmental Management website at http://www.wpafb.af.mil/units/cev. During this time period, no public comments were received. The NOA and comments received will be included in Appendix F.
SECTION 2 – DESCRIPTION OF PROPOSED ACTION AND
ALTERNATIVES
2.1 INTRODUCTION
Alternatives considered under NEPA must analyze alternatives to the proposed action (Preferred Alternative), and the No-Action alternative. The No-Action alternative is included as a means of comparison to the action alternative to help distinguish the relative merits and disadvantages between alternatives. In order for any alternative to be acceptable for consideration, it must meet the purpose to include need for action.
2.2 PROPOSED ACTION
The proposed project would construct a new Type III Hydrant System with two 5,000 barrel (210,000 gallon) ASTs with secondary containment, a 2,400 gpm pumphouse at the existing West Ramp site, and connect to the existing 12-inch hydrant loop. Also included is the connection to the 8 inch pipeline from bulk fuel storage, installation of a tanker truck offload station and a hydrant hose truck (HHT) checkout station. Finally, the proposed project would include demolishing the current Type II pumphouse and removing the 4 single walled USTs.
(Burns 2017)
Figure 4. Proposed Action
This area is currently used as a POL pumphouse and storage tanks indicating the connections for fuel supply pipeline and the hydrant loop system are nearby as well as connections for utilities, communication, and sewers. The approximately 7,500 foot long 8-inch transfer pipeline is the sole source for receiving F-24 to the Type II system and the majority of the pipeline was constructed in the 1950s, with approximately 900 feet of the transfer pipeline being relocated in approximately 2009/2010. The existing Type II system does not include an emergency truck offload stand as backup to the aging transfer pipeline. The existing system currently serves a 12-inch stainless steel hydrant loop that was constructed in 2001/2002 that is suitable for reuse with the new Type III system (Burns 2017).
2.3 SELECTION STANDARDS
Potential alternatives that meet the purpose and need were evaluated against the following selection criteria:
Within 100 feet of the West Ramp hydrant system loop connection in order to minimize piping lengths for system efficiency and cost considerations, Adequate space (approximately 3.5 acres) for storage tanks, pump-house and tanker truck maneuvering in order to meet Unified Facilities Criteria (UFC) 3-460-01 and National Fire Protection Association (NFPA) 30 clearance criteria, Comply with airfield clearance restrictions in accordance with UFC 3-260-01, Within 100 feet of the existing bulk fuel supply pipeline to minimize pipe lengths for cost considerations.
2.4 NO ACTION ALTERNATIVE
Under the No Action Alternative, the current facilities would be left in place and the following existing conditions would persist. WPAFB would continue to spend unnecessary man-hours refueling the mission aircraft because of the manually controlled pump house and low fuel flow rates. The current system installed in 1965 uses single walled USTs that are susceptible to corrosion and leakage. In order to protect the ground water from contamination, the USEPA requires all USTs have secondary containment (double walled). Interior coating of single walled tanks was allowed by the 1988 UST Regulations to extend the service life and protect the tank from corrosion related leakage. The revised 2015 UST Regulations requires interior lined USTs must be closed and removed from service if the coating fails. Closing the USTs as they fail will seriously affect the time required to refuel the mission aircraft by requiring POL refueler trucks to travel from the east side of the base.
The current hydrant system is restricted to one way it can accept fuel for tank filling operations and that is through a supply line from the bulk fuel storage area on the east side of the base. Any interruption of this fuel supply will require fuel truck refueling of the mission aircraft increasing manpower and servicing time requirements affecting mission effectiveness.
2.5 ALTERNATIVES ELIMINATED from FURTHER STUDY
All existing infrastructure including runway and taxiway access needed to support aircraft refueling currently reside within this location of the West Ramp. The aircraft parking area is directly to the east of the current location. There are two primary factors to consider, these are the proximity to the hydrant system connection and the fuel supply line from the bulk fuel storage facility, ideally within 100 feet. Any relocation of the site would increase the cost of the project due to extra trenching and piping to make the appropriate connections.
Relocating the entire refueling system was not considered because any movement of the project to the west and southwest would be closer to surface waters and the floodplain. Movement of the project to the north is restricted by the base boundary.
Remodeling the current pump house was considered, but the structure is too small for the components of the Type III system. The need for a secondary contingency for fuel supply to the tanks requires the construction of offload stations which requires sufficient space for tanker trucks to maneuver.
Secondary factors to consider are; available space (approximately 3.5 acres) to construct the ASTs with secondary containment, pump house, and have room for tanker trucks to maneuver to offload fuel (UFC 3-460-01). The proposed action and the no action alternative satisfy the standards identified in section 2.3 and are evaluated in this EA.
SECTION 3 – AFFECTED ENVIRONMENT
3.1 SCOPE OF THE ANALYSIS
The following sections present a description of the environmental resources and baseline conditions that could potentially be affected from implementing the Proposed Action. Affected environmental resources are confined to a Region of Influence (ROI) in the immediate area of the proposed project (see figure 3). The analysis was provided by the 88th Civil Engineer Group (CEG), Environmental Branch.
In compliance with NEPA, CEQ regulations, and 32 CFR Part 989, the description of the affected environment focuses on resources and conditions potentially subject to impacts. Analysis of potential environmental effects focuses on resource areas that are appropriate for consideration in light of a proposed action. All resource areas are initially considered, but some may be eliminated from detailed examination because they do not directly apply to a particular proposal. The potentially affected environment is described below.
3.2 LAND USE/NOISE
There is a wide variety of land use classifications on WPAFB. Open Space and Outdoor Recreation represent some of the land constrained from development. Over 2,000 acres of this undeveloped land lies within the natural constraints area, which is composed of areas such as floodplains, lakes, wetlands, or areas with unsuitable soil for building. Also located within the natural constraint area is the 109-acre Huffman Prairie Flying Field containing remnant prairie habitat, which includes several rare plant and animal species.
All proposed work falls within the installation property limits of WPAFB. The property is surrounded by industrial/airport support buildings and is currently used for the same purpose as the proposed action use. While WPAFB is divided into 12 land use categories for installation planning purposes, the parcel is zoned and has a land use as a military installation. The Proposed Action area’s existing and future land use is identified as industrial per the WPAFB General Plan
(WPAFB 2014).
Human-made constraints also restrict development within the WPAFB boundaries. Included in these types of constraints are archaeological sites and historic buildings, which can be identified sites or those that remain undiscovered. Operational restrictions can also impede development.
Noise contours from aircraft operations and explosive safety zones must be considered when looking at developing areas on the Base. Airfield and airspace control surfaces, such as runway approach clear zones, are to remain clear of building obstructions.
The noise environment at WPAFB is dominated by aircraft operations. The location of the Proposed Action is within the 65-70 decibels (dB) noise level contour for the most recent AICUZ study for WPAFB. Land use compatibility guidelines are documented in the AICUZ study for WPAFB, the AICUZ study identifies the noise zones and the operations/activities that are compatible within those noise zones. The location of the proposed action is compatible with the AICUZ noise zone (WPAFB 2014).
3.3 AIR QUALITY
In accordance with the Clean Air Act (CAA) (42 USC 7409) requirements, the air quality in a given region of area is measured by the ambient concentration of criteria pollutants in comparison with established standards. These criteria pollutants are; ozone (O3), carbon monoxide (CO), nitrogen dioxide (NO2), sulfur dioxide (SO2), particulate matter equal to or less than 10 microns (PM10), particulate matter equal to or less than 2.5 microns (PM2.5), and lead (Pb) (40 CFR 50).
The Base is located in Greene and Montgomery counties, which are located in the Metropolitan Dayton Intrastate Air Quality Control Region (AQCR) (40 CFR 81.34). Each AQCR is classified as an attainment area or nonattainment area for each of the criteria pollutants depending on whether it meets or fails to meet the National Ambient Air Quality Standards (NAAQS) for the pollutant.
Ambient air quality for the Metropolitan Dayton Intrastate AQCR was formerly classified as an attainment/maintenance area for the 8-hour O3 (USEPA 2012a); attainment for the NO2 annual standard and unclassifiable/attainment for the new 1-hour standard NO2 (USEPA 2012b);
attainment for the SO2 3-hour standard and unclassifiable/attainment for the new 1-hour standard SO2 established in 2013 (USEPA 2013a); and attainment for the Pb and CO standards. Area designations for the 2015 revised 8-hour O3 NAAQS are anticipated to be finalized by the end of 2017 (USEPA 2015a).
The ambient air quality for PM2.5 is classified as attainment for the 24-hour standard and re-designated to attainment/maintenance for the 1997 annual standard (USEPA 2013b). For the new annual PM2.5 NAAQS, the OEPA submitted a report in December 2013 recommending that Montgomery and Greene counties be designated as “unclassified/attainment” (OEPA 2013). This designation was approved by the USEPA effective April 1, 2015 (USEPA 2015b). The USEPA has also approved Ohio SIP revisions implementing the PM2.5 NAAQS including OAC Rule 3745- 31-01 (WWWW) defining PM2.5 precursors to include sulfur dioxide and nitrogen oxides (USEPA 2015c).
Air quality is typically good in the vicinity of WPAFB, and is generally affected only locally by military and civilian vehicle emissions, particulate pollution from vehicle traffic, emissions from wastewater treatment plants, industrial sources, and construction activities. Mobile sources, such as vehicle and aircraft emissions, are generally not regulated at the local level and are not covered under existing stationary source permitting requirements. Stationary emissions sources at WPAFB include natural gas and coal-fired boilers; research and development sources, such as laboratory fume hoods and test cells; paint spray booths; refueling operations; and emergency power generators.
The Base is under the jurisdiction of USEPA Region 5 and the OEPA. The Regional Air Pollution Control Agency, under the jurisdiction of the OEPA, conducts annual compliance inspections at WPAFB. The Base has long had an aggressive program of internal audits and inspections to ensure continual compliance with all applicable air permit terms and conditions. Detailed records are maintained to demonstrate compliance with emission limits, and reports are submitted in a timely manner to the local regulatory agency.
The WPAFB air emissions inventory includes over 1,400 emissions sources. Of these, approximately 1,050 are included in the Base’s Title V permit application, which was originally submitted to the OEPA in February 1996 in accordance with CAA requirements. Many of the Title V sources are insignificant, including emergency generators, small boilers, and laboratory fume hoods. There were 29 permitted non-insignificant emissions units identified in the original application, most of which were boilers and paint spray booths. The OEPA finalized the Title V Operating Permit for WPAFB in January 2004 with an effective date of February 17, 2004 (OEPA 2004). A Title V renewal permit application was submitted to the OEPA in May 2008 and is currently under review. The Title V renewal application notified OEPA that the number of permitted non-insignificant emission units was reduced from 29 to 26. A revision to the Title N renewal application was submitted to OEPA on September 11, 2013 to include a coal-to-gas fuel conversion project at the Base central heating plants.
3.3.1 Attainment Status
WPAFB is located in both Greene and Montgomery counties in Ohio. According to the Ohio Environmental Protection Agency (OEPA) these counties are in attainment with the NAAQS for PM10, NO2, SO2, CO, and Pb (OEPA 2017a).
3.3.2 General Conformity Applicability
The General Conformity Rule at 40 CFR 93 Subpart B requires that any federal action meet the requirements of a State or Federal Implementation Plan. More specifically, CAA conformity is ensured when a federal action does not cause a new violation of the NAAQS; contribute to an increase in the frequency or severity of violations of NAAQS; or delay the timely attainment of any NAAQS, interim progress milestone, or other milestones toward achieving compliance with the NAAQS. The General Conformity Rule applies only to federal actions in nonattainment or maintenance areas.
WPAFB was located in maintenance areas for O3 and PM2.5. However, USEPA revoked the 1997 O3 standard and the 1997 PM2.5 standard in attainment and maintenance areas on 6 March 2015 (USEPA 2015) and on 24 August 2016 (USEPA 2016), respectively. The General Conformity requirements for the NAAQS end when the NAAQS is revoked. Hence, the Proposed Action under this consideration is not subject to General Conformity. See the Air Conformity Applicability Model report in Appendix F.
3.4 WATER RESOURCES
3.4.1 Surface Water
The Base is in the Mad River Valley. The Mad River originates approximately 40 miles north of Springfield, Ohio, flows south and southwest past WPAFB to its confluence with the Great Miami River in Dayton, Ohio, and flows into the Ohio River. Sustained flow of the Mad River originates from groundwater discharge of glacial deposits upstream of Huffman Dam. The Mad River approaches WPAFB from the north and flows along the western border of Area A. The OEPA has divided the Mad River watershed into five areas: headwaters; Mad River between Kings and Chapman Creeks; Buck Creek; Mad River from Chapman to Mud Creeks; and the lower Mad River (Mud Creek to the Great Miami River). Mud Creek enters the Mad River 2,000 ft north of the SR 235 bridge, near the northwest corner of Area A. The Base lies adjacent to the northernmost portion of the lower Mad River segment.
The OEPA has identified the lower segment of the Mad River, which flows through WPAFB, as an impaired water under Section 303(d) of the Clean Water Act (CWA) for not meeting aquatic life and recreation use standards (OEPA 2010). The USEPA has established the total maximum daily load (TMDL) of effluent for the Mad River in the Mad River Total Maximum Daily Loads for
Sediment and Turbidity (USEPA 2007). A TMDL specifies the maximum amount of a pollutant that a water body can receive and still meet water quality standards, and allocates pollutant loadings among point and nonpoint pollutant sources.
The TMDL for the Mad River watershed has been set at 120 percent of natural sediment loading.
According to the report, the natural sediment loading in the basin is approximately 894 tons/square mile/year based on an annual average.
The WPAFB Storm Water Management Plan (SWMP) and the Storm Water Pollution Prevention Plan (SWPPP) (prepared to comply with the CWA and the Ohio Water Pollution Control Act) provides descriptions of storm drainage areas and their associated outfalls, potential storm water pollution sources, and material management approaches to reduce potential storm water contamination (WPAFB 2011b, 2011c). The SWPPP was last updated in September 2011 while the SWMP was last updated in April 2011. An OEPA industrial permit National Pollutant Discharge Elimination System [NPDES] 1IO00001) and a municipal NPDES General permit (OHQ000002) cover the WPAFB storm water program (WPAFB 2011c).
The SWPPP and SWMP provide specific BMPs to prevent surface water contamination from activities such as construction, storing and transferring of fuels, storage of coal, use of deicing fluids, storage and use of lubrication oils and maintenance fluids, solid and hazardous waste management, and use of deicing chemicals (WPAFB 2001).
There are 20 defined drainage or “Outfall Areas” on Base (WPAFB 2011c). There are 24 NPDES discharge monitoring points on Base that are addressed under the NPDES permit. All storm water from WPAFB flows into the Mad River.
Regionally, the Mad River is located adjacent to the northwestern boundary of Area A and flows northeast to southwest. Surface water in the WPAFB area includes the Mad River, Trout Creek, Hebble Creek, Bass Lake, Twin Lakes, Gravel Lake, and wetland areas. These surface water features are recharged by both precipitation and groundwater. Trout Creek and Hebble Creek provide drainage of surface water runoff at WPAFB.
The majority of the West Ramp (adjacent and east/northeast and southeast/south of Bass Lake, approximately 1,200 ft south of the project area) drains to Bass Lake through Outfall 18 (see figure 5). Drainage from the West Ramp includes an approximate 150-acre aircraft parking area where aircraft deicing, fueling, and minor maintenance occur. Storm water runoff from this area passes through oil-water separator 3-WRAMP prior to discharging to Bass Lake at Outfall 18, located on the southeast corner of Bass Lake. The remainder of the West Ramp area drains to Outfall 19 (discharging to the northeast corner of Bass Lake) with activities in this area being performed primarily indoors. Sampling at Outfalls 18 and 19 is routinely performed for but is not exclusive of the following parameters: volatile organic compounds (VOCs), oil/grease, benzene, toluene, ethylbenzene, xylenes, propylene glycol, and ammonia (WPAFB 2011c).
Trout Creek is located in the western portion of Area A and discharges to the Mad River north of Huffman Dam. Hebble Creek passes through the southwestern portion of Area A and discharges to the Mad River several hundred ft north of Huffman Dam. Gravel Lake, Twin Lake East and Twin Lake Westare located in the southwest portion of Area A in OU5. These lakes were created as a result of gravel quarrying activities at WPAFB. Currently, the lakes are maintained as recreational areas for Base personnel and their families.
Figure 5. Storm Water Flow for Project Location.
3.4.2 Groundwater
The Base is located in the Great Miami River Valley, which is filled with glacial deposits of sand and gravel. The glacial outwash deposits are very permeable and exhibit high transmissivity and hydraulic conductivity. The resulting aquifer system, called the Miami Valley Buried Aquifer, is a highly productive source of water for the people in southwest Ohio. The USEPA designated the Miami Valley Buried Aquifer system as a sole-source aquifer in 1988, requiring USEPA Region 5 approval on all new projects to ensure continued use as a drinking water supply (53 Federal Register 15876). The buried aquifer system provides drinking water for more than 1.6 million people in southwest Ohio (Debrewer et al. 2000).
Groundwater can also be found in large volumes in the Silurian-age (415 to 465 million years ago) limestone and dolomite bedrock underneath the buried valley aquifer system. Private wells and smaller public systems typically use this bedrock aquifer because, though not as productive as the buried aquifer, it is adequate for such uses (MCD 2002). Underneath the limestone and dolomite bedrock is Ordovician-age (465 to 510 million year ago) bedrock shale and limestone of the Richmond Group. The lower bedrock aquifer system generally produces less than 5 gallons per minute (gpm) and is only productive enough for livestock use.
The buried valley aquifers coincide with the present Great Miami River and its tributaries. Water underground generally follows the same flows as surface waters with upland areas serving as recharge areas and groundwater divides (MCD 2002). At WPAFB, the Mad River follows the course of the Mad River Buried Aquifer, part of the Miami Valley Buried Aquifer system. South of Huffman Dam (a flood control dam that is managed by the Miami Conservancy District [MCD]), a till zone divides the Mad River Buried Aquifer into an upper water table unit and a lower confined unit. However, north of the dam and in other parts of the buried valley aquifer, till zones occur less frequently as discontinuous, less-permeable zones within the more permeable outwash deposits (WPAFB 1995b). Most of the wells in the outwash deposits yield between 750 and 1,500 gpm, but can vary from less than 200 to more than 4,000 gpm (WPAFB 1995b). The City of Dayton groundwater production wells at Huffman Dam are screened at depths of over 100 ft below ground surface.
General groundwater flow in the area of the project area is in a radial pattern to the north, east, and west; however, flow is predominantly in a westerly direction toward the Mad River. This flow pattern is most likely due to the proximity of the area to Bass Lake located approximately 600 ft south of the project are. Average depth to groundwater is approximately 10 ft below ground surface within Operable Unit 11 (OU11).
3.4.3 Floodplains
Floodplain management on WPAFB includes floodplain protection (EO 11988, EO13690), floodplain boundary determination, and assessment of proposed actions within floodplains.
Floodplain protection and assessment of proposed actions is the responsibility of the 88 CEG EIAP. Federal actions occurring within flood zones require a finding of no practical alternative (FONPA). Floodplain boundary maps are housed in the WPAFB GIS database.
A large portion of WPAFB and most of Area A lies within the Mad River floodplain. The 10-year floodplain is at 804.7 ft above mean sea level (MSL) and the 100-year floodplain is at 813.4 ft above MSL (North American Vertical Datum [NAVD] 1988). Land surface elevation at the project is approximately 815 ft above MSL, which is above the 10- and 100-year floodplain elevations. In addition, the ASTs are protected by 5 ft high secondary containment berm that would increase the elevation to 820 ft above MSL.
3.4.4 Wetlands
Executive Order 11990, Protection of Wetlands, May 24, 1977, directs federal agencies to consider alternatives to avoid adverse effects on and incompatible development in wetlands. Federal agencies are directed to avoid new construction in wetlands, unless the agency finds there is no practicable alternative to construction in the wetland, and the proposed construction incorporates all possible measures to limit harm to the wetland.
The CWA sets the basic structure for regulating discharges of pollutants to U.S. waters. Section 404 of the CWA establishes a federal program to regulate the discharge of dredge and fill material into waters of the United States, including wetlands. The National Wetlands Inventory, a department within U.S. Fish and Wildlife Service (USFWS); USEPA; and the National Resource Conservation Service (NRCS) help in identifying wetlands.
Forty wetlands covering approximately 19.8 acres were identified at WPAFB in 2009 (WPAFB 2015a). Twenty-three wetlands were identified in Area A and 17 wetlands in Area B. The nearest wetland (C21) to the project area is approximately 2,400 ft south of the project area. Wetland C21 is approximately 0.5 acres in size and is a Category 2, palustrine, aquatic bed, wetland located on the shore of Bass Lake. Wetland C21 provides limited cover for larval and juvenile fish present in
Bass Lake and the dense aquatic vegetation provides habitat for aquatic invertebrates that serve as food for fish as well as for shorebird feeding habitat (WPAFB 2015a).
The total jurisdictional stream length reported on Base in 2010 was 61,358 linear feet and included 13 jurisdictional streams in Area A (6 perennial, 6 intermittent, 1 intermittent/perennial) and 13 jurisdictional streams in Area B (1 perennial, 2 intermittent/perennial, 5 intermittent, 1 ephemeral/intermittent, 4 ephemeral) (WPAFB 2015a).
3.5 SAFETY AND OCCUPATIONAL HEALTH
Contractor Safety
All contractors performing construction activities are responsible for following ground safety regulations and for worker compensation programs, and are required to conduct construction activities in a manner that does not pose any risk to workers or personnel. Industrial hygiene programs address exposure to hazardous materials, use of personal protective equipment, and availability of Safety Data Sheets. Industrial hygiene is the responsibility of contractors, as applicable. Contractor responsibilities are to review potentially hazardous workplace operations; to monitor exposure to workplace chemical (e.g., asbestos, lead, hazardous materials), physical (e.g., noise propagation), and biological (e.g., infectious waste) agents; to recommend and evaluate controls (e.g., ventilation, respirators) to ensure personnel are properly protected or unexposed; and to ensure a medical surveillance program is in place to perform occupational health physicals for those workers subject to any accidental chemical exposures.
Military Personnel Safety
Each branch of the military has its own policies and regulations that act to protect its workers, despite their work location. The AFI 91-301, Air Force Occupational and Environmental Safety, Fire Protection, and Health (AFOSH) Program, which implements Air Force Policy Directive (AFPD) 91-3, Occupational Safety and Health, governs the recognition, evaluation, control, and protection of AF personnel from occupational health and safety hazards. The purpose of the AFOSH Program is to minimize the loss of AF personnel from occupational death, injuries, or illnesses by managing risks.
Public Safety
The 88 CEG Fire Department at WPAFB provides fire, crash, rescue, and structural fire protection at the Base. The emergency services department provides WPAFB with fire suppression, crash response, emergency medical response, hazardous substance protection, and emergency response planning and community health and safety education through the dissemination of public safety information to the installation. The 88 CEG Fire Department abides by a general safety policy relating to the performance of all activities at the Base. Individuals, supervisors, managers, and commanders are expected to give full support to safety efforts and safety awareness and strict compliance with established safety standards are expected.
3.6 HAZARDOUS MATERIALS/WASTE
Hazardous Materials
Air Force Instruction 32-7086, Hazardous Materials Management, establishes procedures and standards that govern management of hazardous materials throughout the USAF. It applies to all
USAF personnel who authorize, procure, issue, use, or dispose of hazardous materials, and to those who manage, monitor, or track any of those activities. The Base utilizes a hazardous material management program through which hazardous materials are tracked and controlled from procurement through storage and issue to disposal.
Hazardous and toxic material procurements at WPAFB is approved and tracked by the Hazardous Material Management Process (HMMP) Team. The HMMP Team is a network of safety, environmental and logistics experts who work with hazardous material Issue Point Managers, Unit Environmental Coordinators, and other hazardous material users to ensure safe and compliant hazardous material management throughout the Base (WPAFB 2006). The Installation Management Division supports and monitors environmental permits, hazardous material and hazardous waste storage, spill prevention and response, and participation on the Base Environmental Protection Committee.
Hazardous Waste
The 88 CEG maintains a Hazardous Waste Management Plan (WPAFB 2019a) as directed by AFI 32-7042, Solid and Hazardous Waste Compliance. This plan prescribes the roles and responsibilities of all members of WPAFB with respect to the waste stream inventory, waste analysis plan, hazardous waste management procedures, training, emergency response, and pollution prevention. The plan establishes the procedures to comply with applicable federal, state, and local standards for solid waste and hazardous waste management.
Wastes generated at WPAFB include waste flammable solvents, contaminated fuels and lubricants, paint/coating, stripping chemicals, waste oils, waste paint-related materials, mixed-solid waste, and other miscellaneous wastes. Management of hazardous waste is the responsibility of each waste-generating organization and the Compliance Division (88 CEG/CEIEC). The Base produces more than 1,000 kilograms of hazardous waste per month and is considered a large quantity hazardous waste generator.
3.7 BIOLOGICAL/NATURAL RESOURCES
Vegetation
The Base contains four general types of natural vegetative communities including forest, old fields, prairie, and wetlands. Areas that may be impacted by the Proposed Action are primarily disturbed areas. These include maintained areas that are frequently mowed such as right-of-ways, lawns, and recreational areas, and have been designated by the Base as turf and landscaped areas.
The Base has been awarded the Arbor Day Foundation’s Tree City USA designation for fourteen years (WPAFB 2012). The Tree City USA award originates from the National Arbor Day Foundation, an organization founded in 1976 dedicated to tree plantings, conservation, and promotion of community forestry. Benefits of being a Tree City designee include creating a framework for action, education, a positive public image, and citizen pride.
Wildlife
The Base is home to a variety of wildlife. Previously conducted surveys documented the presence of 23 mammals, 118 birds, 8 reptiles, 6 amphibians, 36 fishes, 14 mussels, 35 butterflies, 8 moths, 15 odonates (dragonflies/damselflies), 6 carrion beetles, and 3 crayfish on the Base (WPAFB 2015a). The project area is located within a heavily disturbed area on Base and those species occurring in such areas are common species to the Base and surrounding area.
Because birds as well as mammals pose a hazard to airfield and aircraft operations, the Air Force has established bird air strike hazard and wildlife management plans. The Base implements a comprehensive Bird/Wildlife Aircraft Strike Hazard (BASH) plan that involves prevention, monitoring, and reduction of bird/wildlife hazards (WPAFB 2015a).
Threatened and Endangered Species
Endangered and threatened species on the Base are protected under the ESA. In addition, AFPD 32-70 and AFI 32-7064 require all Air Force installations to protect species classified as federally or state endangered or threatened. The Endangered Species Management Plan (BHE Environmental [BHE] 2001), which has been incorporated into the Integrated Natural Resources Management Plan (INRMP), provides species-specific protection and conservation measures to protect known special status species occurring on the Base (WPAFB 2015a).
As stated in the United States Fish and Wildlife Service and Ohio Department of Natural Resources letters in Appendix A, there are no threatened or endangered biological or natural resources on the proposed action property.
3.8 CULTURAL RESOURCES
The Base owns over 250 historic buildings, several that are individually eligible for inclusion on the National Register of Historic Places (NRHP) and most of which are located in one of three NRHP-eligible historic districts. The Integrated Cultural Resources Management Plan (ICRMP) for WPAFB, prepared in consultation with the State Historic Preservation Office (SHPO), indicates the existing pumphouse is not located within a Historic District nor is it individually eligible for listing on the NRHP.
There are no historic or tribal resources on the property as this area has been developed since 1962.
The AF has made a 36 CFR Part 800.5(b) “no adverse effect” finding with SHPO concurrence on 13 March 2019 as stated in letter from Ohio History Connection in Appendix B. In the letter the SHPO adds the upgrades to the fuel hydrant system should not alter the integrity of the Strategic Air Command (SAC) compound in a way that would impact its potential for National Register eligibility in the future. The west ramp area is not eligible for the National Registry (NR) and is not an eligible historic district.
The five Tribes culturally affiliated with WPAFB have said that no properties of religious and cultural significance are present on the installation, and that they only wish to be consulted on a ground-disturbing activity that takes place in a previously undisturbed area as stated in Appendix C.
3.9 EARTH RESOURCES
The surface soil at WPAFB was formed by unconsolidated deposits, primarily alluvium, glacial outwash, glacial till, and loess. Most of the installation is mapped by the Natural Resources Conservation Service as urban land complexes (WPAFB 2015).
The highest land surface elevations on Base are in Area B and occur along a bedrock ridge that extends from the southeast corner of Area B to the Wright Memorial. The majority of the Base is on the broad alluvial plain of the Mad River Valley, which overlies Ordovician-age Richmond shale and limestone bedrock. The land surface elevation Base-wide range from approximately 760 to 980 ft above MSL.
Surface soil at WPAFB formed on unconsolidated deposits, primarily alluvium, glacial outwash, glacial till, and loess (WPAFB 2015). Development and substantial earthmoving activities have altered the natural soil characteristics at WPAFB, making precise classifications difficult. The U.S.
Department of Agriculture (USDA), NRCS mapped most of WPAFB as urban land complexes.
Major soil complexes represented at WPAFB include Warsaw-Fill, Sloan-Fill, Miamian-Urban, Fox-Urban, Linwood Muck, Westland-Urban, and Warsaw-Urban.
The predominant soil type in the vicinity of the proposed site is the Warsaw-Fill land complex.
Warsaw-Fill land complex soils are described as approximately 2 to 5 ft of fill material overlying well-drained soils that formed in loam glacial outwash over sand and gravel at a depth of 24 to 60 inches. Permeability is moderate in the upper portions and high in the underlying sand and gravel
(USDA 1978).
3.10 SOCIOECONOMIC RESOURCES
Socioeconomics is the relationship between economics and social elements such as population levels and economic activity. Factors that describe the socioeconomic environment represent a composite of several interrelated and nonrelated attributes. There are several factors that can be used as indicators of economic conditions for a geographic area, such as demographics, median household income, unemployment rates, percentage of families living below the poverty level, employment, and housing data. Data on employment identify gross numbers of employees, employment by industry or trade, and unemployment trends. Data on industrial, commercial, and other sectors of the economy provide baseline information about the economic health of a region.
3.10.1 Affected Environment
Demographics. Metropolitan statistical areas are geographic entities defined by the Office of Management and Budget for use by federal statistical agencies in collecting, tabulating, and publishing federal statistics. A metro area contains a core urban area of 50,000 or more of a population. Each metro area consists of one or more counties and includes the counties containing the core urban area, as well as any adjacent counties that have a high degree of social and economic integration (as measured by commuting to work) with the urban core (Census 2017).
The Base is located 10 miles outside of Dayton, Ohio. According to the 2010 Census data, the city of Fairborn had a population of 32,352; the city of Dayton had a population of 141,527; and the Dayton Metropolitan Area (MA) (consisting of Clarke, Greene, Miami, Montgomery, and Preble counties) had a population of 979,835…
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