7._Environmental_Supplemental_Conditions.pdf

Environmental Procedures 25 January 2018

1. General

1.1. These Environmental Procedures identify environmental compliance requirements for Ohio Army National Guard (OHARNG) projects. The Environmental Procedures are intentionally broad in scope to ensure contractors have information needed to price and complete work knowing all the requirements. In general these Environmental Procedures are applicable to all OHARNG projects, but some of the conditions are specific to certain types of work such as pest control, renovation, and demolition. Contractors conducting work not specified in these procedures are considered to be in compliance with no specific action required.

1.2. The OHARNG is committed to environmental stewardship at all of our facilities and within our communities as a whole. The Adjutant General’s Department maintains an Environmental Management System (EMS) in accordance with (IAW) ISO 14000 standards.

If implemented accordingly, following the guidelines outlined in the following Environmental Procedures will ensure Contractor compliance with the EMS policy. Through sound environmental management, the OHARNG is committed to:

• Assuring the sustainability and availability of training lands and facilities to enable soldier training and unit readiness.

• Setting and reviewing environmental objectives and target to manage OHARNG significant environmental aspects.

• Establishing the means to enable continual improvement of our environmental program.

• Complying with all relevant environmental legislation and regulations.

• Ensuring soldiers and employees of the OHARNG are informed of environmental program requirements and are able to execute individual and organizational responsibilities.

• Improving upon pollution prevention and reduction strategies through the application of innovative processes and technologies.

• Considering the environmental requirements and impacts in all planning processes relative to training, equipment fielding, and construction.

1.3. The Contractor must comply with all applicable local, state, and federal environmental requirements to include applicable Army and OHARNG regulations. This includes, but is not limited to, the proper characterization, management and disposal of wastes; proper storage, use and transportation of hazardous materials; spill prevention and clean up;

obtaining proper permits and submitting proper notifications as applicable to the work being conducted; and protection of surface water and natural resources.

1.4. The Contractor (to include subcontractors) will not correspond with any regulatory agency regarding an OHARNG project without approval of the OHARNG. This includes meetings, phone calls, emails, permit/application submittals, or other written or verbal communications.

The OHARNG will review and approve all correspondence, to include permit applications and notifications, before they are sent to a regulatory agency to include but not limited to the federal or Ohio Environmental Protection Agency (EPA), the US Fish and Wildlife Service, the Ohio Historic Preservation Office, the US Army Corps of Engineers, County Engineer offices, and local Soil and Water Conservation offices.

1.5. The Contractor is responsible for paying all fees and acquiring all applicable permits or regulatory approvals associated with the work they are performing. Depending upon the permit/notification, it may need to be issued in the OHARNG’s name. Coordination will be done with the OHARNG to determine this and as applicable the Contractor will complete the application/notification for OHARNG signature and submit the application and associated fees. All permit submittals will be coordinated, reviewed and approved by the OHARNG before submittal regardless of who signs the application.

1.6. Executive Order (EO) 13693, Planning for Federal Sustainability in the Next Decade, establishes a federal integrated strategy toward sustainability including efforts to “eliminate waste, recycle, and prevent pollution.” Additionally, EO 13693 establishes targets to divert at least 50% of non-hazardous solid waste, including construction and demolition debris, from the waste stream. The Contractor will utilize the most current waste prevention, waste diversion (salvage, reuse, recycle), and waste minimization guidelines to ensure this target is met.

1.7. Burning of waste, brush, rubbish, and/or any other debris is not permitted. If brush or vegetation burning is desired, a request to do so must be submitted to the OHARNG for review. If the OHARNG concurs that burning is needed, the Contractor is required to submit a burn permit to the Ohio EPA along with any associated fee. If the Ohio EPA approves the application and issues a permit, the contractor is required to comply with all conditions of the permit. Upon receipt of the Ohio EPA burn permit the contractor will obtain any additional permits required by the OHARNG and/or local fire departments/districts, if any.

2. Environmental Work Plan

2.1. The Contractor will develop an Environmental Work Plan that provides details on the work to be performed and how it will be performed to ensure compliance with applicable environmental requirements. The complexity and content of the plan is directly related to work being performed. Topics addressed within the environmental work plan will include as applicable: description and location of the work to be performed; Contractor and OHARNG points of contact; storm water and sediment and erosion controls (may reference a SWP3 if applicable); site stabilization/seeding; hazardous materials to be used; spill prevention, response, and notification; emergency plan and emergency contact information; the qualified personnel responsible for waste management; waste to be generated (hazardous and nonhazardous waste); materials to be recycled; methods to be used to minimize hazardous waste generation; methods and laboratories to be used to characterize the waste; waste haulers and disposal/treatment facilities to be used (Defense Reutilization Management Office (DRMO) approved waste haulers and treatment, storage, and disposal facilities (TSDFs) must be used for hazardous waste); proposed on site waste storage locations; on site waste management and inspection procedures to be implemented to include maximum storage time/proposed waste pickup/transport date; discharges from secondary containment and de-watering activities; and any other information pertinent to environmental compliance associated with the specific work being performed. The Environmental Work Plan will be reviewed by the OHARNG Environmental Office and edited by the Contractor as necessary to correct deficiencies. Work cannot not begin until this work plan has been approved by the OHARNG Environmental Office. A copy of the final work plan will be available at the project site at all times.

2.2. Two (2) hardcopies and two (2) electronic copy each of the draft version of the Environmental Work Plan will be submitted to the OHARNG for review and approval. The draft plan will have the word “Draft” in the title and at the top or across each page. In addition, lines will be numbered in draft reports to facilitate ease of comments. Initial draft work plan submission must be received by the Environmental Office no later than 30 calendar days from issuance of the notice to proceed. The OHARNG will review the draft work plan and return any comments/changes to the Contractor within two weeks of receipt.

The Contractor will have no more than 10 working days to address comments/changes and resubmit the final draft for approval. The Contractor will resolve all comments to the satisfaction of the OHARNG and provide a final Environmental Work Plan to the Environmental Office. The OHARNG reserves the right to re-evaluate the work plan in the event that unforeseen work conditions are encountered.

2.3. The Contractor will provide two (2) hardcopies and two (2) electronic copies each of the final Environmental Work Plan to the OHARNG. The OHARNG will review the final document to make sure all comments/revisions have been incorporated prior to final acceptance and approval.

2.4. Below is a sample outline for an Environmental Work Plan. Not all sections of the work plan may be applicable. If the section is not applicable insert “NOT APPLICABLE” below the section title, but do not remove the section from the table of contents. If a section is needed that is not included, add it at the end before the appendices.

1.0 Introduction, Site Location, and History 2.0 Contractor and Government Points of Contact 3.0 Description of Work to be Accomplished 4.0 Storm Water Management, Sediment, and Erosion Controls 5.0 Cultural and Natural Resources 6.0 Hazardous Materials Inventory and Management 7.0 Spill Prevention, Response, Notification, and Reporting

8.0 Emergency Plan and Points of Contact 9.0 Air Management, Discharges, Permits

10.0 Pesticide Use 11.0 Waste Management

11.1 Waste Management Point of Contact

11.2 Waste Streams/Types

11.3 Waste Characterization Methods and Labs

11.4 Waste Minimization Strategies and Recycling

11.5 Waste Management Procedures and Processes

11.6 Waste Hauler(s)

11.7 Waste Disposal/Treatment Facility/Facilities

12.0 Summary of Identified Environmental Hazards 13.0 Procedures for Environmental Hazards Abatement/Removal

13.1 Asbestos

13.2 Lead-containing Materials

13.3 PCB-containing Materials

13.4 Floor Sweep

13.5 Mercury-containing Materials/Equipment

13.6 Smoke Detectors

13.7 Exit Signs

13.8 Air Conditioners

13.9 Other Environmental Hazards

14.0 Building Demolition/Renovation Procedures/Methodology

14.1 Pre-demolition/renovation Submittals and Notifications

14.2 Pre-demolition/renovation Site Inspection

14.3 Mobilization

14.4 Demolition/Renovation Methodology

14.4.1 Structural Demolition

14.4.2 Utility Decommissioning

14.4.3 Storm Water Management

14.4.4 Dewatering Procedures

14.4.5 Protection of Environmental Resources

14.4.6 Site Restoration

14.5 Demobilization and Project Closeout

14.6 Job-site clearance report with the air monitoring results

Appendices

Appendix A – Site Plan/Aerial Photo Map

Appendix B - OHARNG Environmental Environmental Procedures

Appendix C – OHARNG Waste Management Guidelines

Appendix D – OHARNG Waste Inspection Form

Appendix E – OHARNG Demolition Diversion and Waste Disposal Form

Appendix F – OHARNG Asbestos Abatement Closeout Form

Appendix G – Site-specific Health and Safety Plan

Appendix H – Contractor Licensure

Appendix I – OHARNG Daily Pest Control Summary

Appendix J – OHARNG Supplemental Pesticide Application Report

3. Emergency Spill Response and Petroleum, Oil, and Lubricant (POL) Management

3.1. The Contractor must comply with the local OHARNG Spill Contingency Plan and implement appropriate measure to prevent spills/releases to the environment and to respond, notify, and report when a release occurs. The Contractor is required to inspect equipment, fuel, and hazardous materials storage areas to ensure there are no leaks or releases. The Contractor is responsible for implementing spill response and cleanup of all spills/leaks within the project area immediately upon discovery. Clean up must be satisfactory to the OHARNG and/or the Ohio EPA or other applicable regulatory agency. Wastes will be managed as described in the waste management section of these Environmental Procedures.

3.2. The OHARNG will be notified of all spills/releases. Incidental releases (petroleum product less than 25 gallons, a release that stays of OHARNG property, not in water, and not a reportable quantity) will be responded to by the contractor and the OHARNG notified by telephone within 2-hours. Any spill of petroleum products over 25 gallons, a spill that goes off of OHARNG property, a spill of any amount into a body of water, or a reportable quantity release must be reported to the OHARNG immediately. All spills/releases must be reported in writing on the OHARNG Spill Report Form (Attachment 1) and submitted to the OHARNG within 24 hours. The Contractor will be provided with a copy of the OHARNG Spill Report Form and a point of contact for submitting such reports/notifications.

3.3. The Contractor is required to have a spill kit with appropriate absorbents, plastic bags, drums, shovels, and other supplies and equipment suitable to clean up any releases or spills from their activities.

3.4. Contractor stationary fuel pods must be in/on secondary containment with a storage capacity of 110% of the container. A double walled container is sufficient secondary containment.

Releases of rain water from secondary containment can only be initiated after approval from the OHARNG Environmental Office and after inspection and verification/absorption of all petroleum, oil, and lubricants (POL) and/or other contaminants in the water by the Contractor. Discharge of POL or other contaminants/pollutants from secondary containment is not permitted. At minimum, discharging through an oil only boom/filter or an oil absorption filter bag is required. If the contractor cannot show proof of lack of contaminants, the water will need to be sampled and characterize to determine the proper discharge/disposal method. The contractor will document all discharges/disposal from secondary containments to include name and signature of person conducting discharge/disposal, date of discharge/disposal, volume discharged/disposed, method of discharge/disposal, method of determining water was clean to discharge (analytical result if applicable), and a statement that any discharge did not contain POL or other contaminants. Discharges from secondary containment will be addressed in the Waste Management Section of the Environmental Work Plan.

3.5. Individual fuel/POL cans (5 gallon or less) and hazardous materials used on job sites must be stored in a manner that prevents release to the environment. This will usually involve a covered storage area with appropriate secondary containment that protects them from rain and accidental damage. Chainsaw fuel and bar oil on logging jobs can be left at the tree felling site in the woods or brought out to the log landing each day.

4. Erosion Control, Storm Water and Other Surface Water Management

4.1. For all projects, regardless of the disturbance acreage, the Contractor will use all methods appropriate and required to prevent soil from leaving the project site either by wind, water, or on vehicles and equipment. Silt fence and other temporary soil run off detention methods will be used as needed. Spoil piles and disturbed areas will be managed in accordance with the stipulations outlined in the Ohio EPA General National Pollutant Discharge Elimination system (NPDES) Storm Water Construction Permit and the most current version of the Ohio Department of Natural Resources’ Rainwater and Land Development Manual; Ohio’s Standards for Storm Water Management, Land Development, and Urban Stream Protection (available on-line). The site must be seeded with a temporary seed mix if left idle for the designated period of time. The project site will be closed out by preparing the soil as a seed bed and seeding and mulching with the appropriate seed mix. Temporary erosion control measures (silt fence) will be removed by the contractor once vegetation has been established and soil on the project area is stabilized.

4.2. Post construction permanent storm water / water quality controls must be designed and installed in accordance with Section 438 of the Energy Independence and Security Act of 2007 (EISA) and the Ohio EPA General NPDES Storm Water Construction Permit. The current technical guidance on implementation of the Section 438 storm water runoff requirements is available on-line. The post construction requirements will be incorporated into all designs/plans and implemented/constructed by construction contractors as part of the initial site preparation.

4.3. Native seed mixes will be used where suitable and compatible with maintenance requirements. An appropriate turf grass mix will be used for high traffic and high maintenance areas. Annual ryegrass can be added to mixes to provide quick cover. For late season seeding, winter wheat/rye can be added to provide a quick cover. Contractors will use the approved grass seed mixes listed below or propose alternative seed mixes. The OHARNG Environmental Office must approve all seed mixes. The seed mixes that will be used will be identified in the Storm Water Management, Sediment, and Erosion Controls section of the Environmental Work Plan.

The following seed is approved for establishment of temporary cover. Species can be mixed if/as necessary for specific application.

• Annual Rye Grass (Lolium multiflorum), broadcast @ 40 lbs/acre, drilled at 30 lbs/acre, mulch with a minimum of 3 bales of straw per 1000 square feet. Use mulch netting or fiber mat on slopes greater than 6%. Grows quickly but of short duration. Good growth during hot summer period.

• Winter Rye (Secale cereal) broadcast @ 112 lbs/acre, drilled at 80 lbs/acre, mulch with a minimum of 3 bales of straw per 1000 square feet. Use mulch netting or fiber mat on slopes greater than 6%. Good for fall seeding. Select a hardy variety.

• Oats (Avena sativa) broadcast @ 80 lbs/acre, drilled at 65 lbs/acre, mulch with a minimum of 3 bales of straw per 1000 square feet. Use mulch netting or fiber mat on slopes greater than 6%. Best for spring seeding. Fall seeding will die when winter sets in.

• 40% Nodding Wild Rye (Elymus canadensis), 40% Virginia wild rye (Elymus virginicus), 15% Partridge Pea (Chamaecrista fasciculata), and 5% Black-eyed Susan (Rudbeckia hirta), broadcast @ 35 lbs/acre, drilled at 25 lbs/acre, mulch with a minimum of 3 bales of straw per 1000 square feet. Add 20 lbs/acre of Annual Rye Grass (Lolium multiflorum) to the broadcast mix and 15 lbs/acre to the drilled mix. Good for areas that will remain unfinished indefinitely.

• 23.5% Nodding Wild Rye (Elymus canadensis), 25% Virginia wild rye (Elymus virginicus), 18.75% Partridge Pea (Chamaecrista fasciculata), 1.5% Black-eyed Susan (Rudbeckia hirta), and 31.25% Little Bluestem (Schizachyrium scoparium), broadcast @ 25 lbs/acre, drilled at 18 lbs/acre), mulch with a minimum of 3 bales of straw per 1000 square feet. Add 20 lbs/acre of Annual Rye Grass (Lolium multiflorum) to the broadcast mix and 15 lbs/acre to the drilled mix. Good for late season (after 15 September) quick temporary cover.

The following seed is approved for establishment of permanent cover in areas that are not maintained as turf grass or high foot traffic areas such as range impact areas that are not regularly mowed, roadsides outside of cantonment areas, fence lines outside of cantonment areas, etc. Substitution with similar species is permitted but must be approved by the OHARNG Environmental Office.

• 23.5% Nodding Wild Rye (Elymus canadensis), 25% Virginia wild rye (Elymus virginicus), 22% Little Bluestem (Schizachyrium scoparium), 18.75% Partridge Pea (Chamaecrista fasciculata), 7.75% Thin-leaved Coneflower (Rudbeckia triloba), 1.5% Brown fox sedge (Carex vulpinoidea), 1.5% Black-eyed Susan (Rudbeckia hirta), broadcast @ 18 lbs/acre, drilled at 12 lbs/acre, mulch with a minimum of 3 bales of straw per 1000 square feet. Add 20 lbs/acre of Annual Rye Grass (Lolium multiflorum) to the broadcast mix and 15 lbs/acre to the drilled mix. This mix is for use in open areas that receive good sunlight.

• 31% Deertongue (Dichanthelium clandestinum), 25% Virginia wild rye (Elymus virginicus), 25% Nodding Wild Rye (Elymus canadensis), 10% Big Bluestem (Andropogon gerardii), and 9% Side-Oats Grama (Bouteloua curtipendula), broadcast @ 30 lbs/acre, drilled at 20 lbs/acre), mulch with a minimum of 3 bales of straw per 1000 square feet. Add 20 lbs/acre of Annual Rye Grass (Lolium multiflorum) to the broadcast mix and 15 lbs/acre to the drilled mix. This mix is for use in shaded areas, partial sun, and openings in the forest canopy.

Areas that are maintained with regular mowing during the growing season and receive heavy foot traffic will be seeded with an appropriate turf grass mix. Such areas include lawns in cantonment areas, parade fields, and range operational control areas (ROCAs). Turf grass mixes of Kentucky blue grass, fine fescue, and perennial ryegrass using varieties appropriate for the specific application will be identified by the contractor and reviewed and approved by the OHARNG prior to application. Contractors will provide draught resistant varieties in seed mixes. A potential mix and varieties are as follows.

• 40% Kentucky Bluegrass (applicable varieties), 30% Perennial Ryegrasses (applicable varieties), 20% Hard Fescue (applicable varieties), and 10% Creeping Red Fescue (applicable varieties)

4.4. For projects that disturb one (1) or more acres of ground (or otherwise meet the Ohio EPA criteria for permit coverage), the Prime Contractor will obtain coverage under the Ohio EPA General NPDES Permit for Storm Water Discharges Associated with Construction Activity.

The Contractor will submit a Notice of Intent (NOI) as the Operator and pay the applicable fee. The NOI must be approved by the OHARNG Environmental Office prior to submittal to the Ohio EPA. The Contractor will coordinate the content of the NOI with the OHARNG Environmental Office and will make modifications as directed. The contractor is required to have a Storm Water Pollution Prevention Plan (SWP3) prior to submitting the NOI (see below for SWP3 information). Subcontractors, as applicable, will submit co-permittee NOI’s after the Prime Contractor has obtained authorization and a permit number from the Ohio EPA. All co-permittee NOI’s must be approved by the OHARNG Environmental Office prior to submittal to the Ohio EPA. Copies of all NOI’s and Ohio EPA authorization letters will be provided to the OHARNG project manager and Environmental Office. In situations where the construction permit is in the name of the OHARNG, the Contractor and applicable subcontractors will be co-permittees under the OHARNG’s permit.

4.5. In the absence of an Architect and Engineer (A&E), the Contractor is responsible for the development of Erosion and Storm Water Control (E&S) Plans and Details and the subsequent development of a Storm Water Pollution Prevention Plan (SWP3) in accordance with the requirements contained in the Ohio EPA General NPDES Permit for Storm Water Discharges Associated with Construction Activity. The Contractor will ensure that E&S controls and permanent post construction / water quality controls comply with Section 438 of the Energy Independence and Security Act of 2007 (EISA) and the latest version of the Ohio Department of Natural Resources publication titled "Rainwater and Land Development - Ohio's Standards for Storm Water Management and Land Development and Urban Stream Protection" (available on-line). If A&E E&S and post construction storm water / water quality control designs are available, the Contractor will prepare a SWP3 based on the plans and details provided by the A&E. The Contractor will submit a draft SWP3 to the Environmental Office no later than 30 calendar days from issuance of the notice to proceed.

The OHARNG will review the draft SWP3 and return any comments/changes to the Contractor within two weeks of receipt. The SWP3 will be evaluated using the Ohio EPA Storm Water Pollution Prevention Plan Checklist for Construction Activities (OHC000004) (Attachment 2). The Contractor will have no more than 10 working days to address comments/changes and resubmit the final draft for approval. Once approved by the Environmental Office, the SWP3 will be provided to the local Soil and Water Conservation District (SWCD) and local County Engineer (if required by County or other regulations) by the Contractor for their review and approval. The Contractor will make corrections to the SWP3 based upon OHARNG, SWCD and Engineer comments. The SWP3 will be signed by an authorized representative of the Contractor. The final copy of the SWP3 will be put in a three ring binder and a signed copy of the SWP3 will be given to the OHARNG Environmental Office, the project manager, and a copy will remain at the work site during project execution. If an A&E developed SWP3 is provided, the Contractor will modify it to include missing required project specific information. The OHARNG reserves the right to reevaluate the SWP3 in the event that unforeseen work conditions are encountered.

4.6. When an A&E firm is hired to do a design, the A&E will design post construction permanent storm water/water quality controls in accordance with Section 438 of the Energy Independence and Security Act of 2007 (EISA) and the Ohio EPA General NPDES Storm Water Construction Permit as part of the design. The A&E will also develop Erosion and Storm Water Control (E&S) Plans and Details, notes, and details suitable for inclusion in the project Storm Water Pollution Prevention Plan (SWP3). Post-construction and construction controls will conform to the latest version of the Ohio Department of Natural Resources publication titled "Rainwater and Land Development - Ohio's Standards for Stormwater Management and Land Development and Urban Stream Protection" (available online).

If required in the design scope of work/contract, the A&E will develop a complete SWP3 in compliance with the requirements in the Ohio EPA General National Pollutant Discharge Elimination System (NPDES) Permit for Storm Water Discharges Associated with the Construction Activity. The SWP3 will be evaluated using the Ohio EPA Storm Water Pollution Prevention Plan Checklist for Construction Activities (OHC000004) (Attachment 2). The A&E will submit the draft SWP3 to the Environmental Office no later than 30 calendar days from issuance of the notice to proceed. The OHARNG will review the draft SWP3 and return any comments/changes to the A&E within two weeks of receipt. The A&E will have no more than 10 working days to address comments/changes and resubmit the final draft for approval. After review and approval by the OHARNG Environmental Office the A&E will coordinate review of the E&S plans and SWP3 with the local County Engineer and local Soil and Water Conservation District as applicable and make required revisions based on agency reviews. The final copy of the SWP3 will be put in a three ring binder. A signed copy of the SWP3 will be given to the OHARNG Environmental Office and the project manager. A copy of the SWP3 will made for and kept at the work site. The A&E will complete a draft NOI. The General Contractor will add any required project specific information to the E&S plans, SWP3, and draft NOI as applicable. Upon approval by the OHARNG, the General Contractor will submit the NOI and payment to the Ohio EPA. The OHARNG reserves the right to re-evaluate the SWP3 in the event that unforeseen work conditions are encountered.

4.7. The Contractor will implement the SWP3 and conduct all inspections and maintain storm water/erosion controls in accordance with the SWP3. The Contractor will use the inspection checklist for storm water controls in the SWP3 and will complete and maintain signed inspections on site in the SWP3 binder. Copies of weekly/post storm event inspections will be provided to the OHARNG project manager and Environmental Office monthly. The Contractor will notify the OHARNG project manager and Environmental Office immediately if there is a storm water control failure and off site discharge from the project area. Any proposed changes to the SWP3 must be coordinated with and approved by the OHARNG.

4.8. The Contractor will notify the OHARNG project manager and Environmental Office within 45 days of final site stabilization. The OHARNG Environmental Office will inspect the site to determine if adequate site stabilization has been achieved. Once adequate stabilization has been achieved the Contractor will submit a Notice of Termination (NOT). The NOT must be approved by the OHARNG Environmental Office prior to submittal to the Ohio EPA. The Contractor will provide the OHARNG project manager and Environmental Office with copies of the NOT. The site is considered to have reached final stabilization when the terms identified in the Ohio EPA Permit are met.

4.9. The Contractor will use best management practices or whatever means necessary to prevent contamination of storm water due to runoff from wastes, debris piles, fuel tanks, materials, equipment, and other storage/materials on the project site.

4.10. The Contractor is not permitted to disturb or fill any wetlands, streams, or other surface waters while performing tasks within the scope of work unless such disturbance or fill is specifically identified as a task in the scope and applicable permits and authorizations have been obtained. The Contractor will maintain a 30 foot undisturbed buffer around wetlands and depressional areas that hold water and will keep all equipment, materials, vehicles, debris, waste, and personnel out of this buffer and prevent discharges of any type (chemical or soil) from entering such areas.

4.11. The OHARNG Environmental Office must approve all dewatering activities. Dewatering will be addressed in the waste management section or the demolition dewatering section of the Environmental Work Plan if applicable to the project. Standing water must be characterized to determine if it is regulated before dewatering procedures are implemented.

Characterization may be possible by generator knowledge or may require sampling and analysis. For demolition projects the water may contain asbestos, lead, PCBs or other contaminants and will have to be sampled. Construction dewater would most likely only contain suspended solids but could contain contaminated groundwater depending upon where the project is located. At minimum, discharges must meet water quality standards identified in Ohio Administrative Code 3745-1. At locations with known contaminated groundwater the OHARNG Environmental Office will provide specific guidance on containerization, sampling, and disposal/discharge requirements. At minimum, water must go through an oil absorption and/or an activated charcoal, and/or a sediment filter bag as appropriate, prior to being discharged. Discharge will be done in a vegetated upland area that drains away from the work site unless otherwise specified in the scope of work or authorized by the OHARNG Environmental Office. Discharge will be done so as to allow the discharge to filter through dense groundcover vegetation. The discharge hose will be set on a piece of plywood or rubber mat to disperse the water and prevent a concentrated discharge that can cut and erode soil. Direct discharge to a stream, pond, wetland, ditch or other body of water or conveyance is not permitted.

5. Sanitary Sewer

5.1 For projects that include new, expanded or modified wastewater systems, the Contractor must obtain a permit-to-install (PTI) from the Ohio EPA. The PTI permit must be approved by the OHARNG Environmental Office prior to submittal to the Ohio EPA. The final PTI permit should be submitted approximately 35 business days prior to initiation of construction activities. A Fact Sheet regarding Wastewater PTI Applications describes in detail when a PTI is or is not required (Attachment 3)

6. Waste, Recycling and Hazardous Waste

6.1. Hazardous waste generated by any Contractor working on OHARNG projects counts toward the OHARNG monthly generation total and is an OHARNG waste. The Contractor is responsible for minimizing all waste generation from OHARNG projects and for properly managing all wastes generated from OHARNG projects in accordance with the Ohio Army National Guard Waste Management Guidelines (Attachment 4). Waste generated from OHARNG projects conducted at Camp Ravenna must be managed in accordance with the Camp Ravenna Waste Management Guidelines (Attachment 5). Waste will be managed in accordance with all applicable Federal, States, U.S. Army, NGB and OHARNG regulations and requirements. OHARNG sites may have specific hazardous waste information / management guidelines that must be followed to ensure compliance with applicable regulations and requirements. The contractor must include hazardous waste management in their Environmental Work Plan and coordinate all hazardous waste generation and management activities with the OHARNG Environmental Office prior to beginning work.

6.2. The Contractor is responsible for characterizing all waste generated from a project and notifying the OHARNG of all waste streams, management methodology, and disposal methods prior to beginning work. If an alternative practice is available that will eliminate or minimize hazardous waste generation, the contractor is required to implement such practice (e.g. using dry ice instead of sand to sand blast lead based paint and minimize lead waste).

6.3. The Contractor is responsible for properly labeling, storing, and inspecting non-hazardous and hazardous waste stored at the project site pending disposal. All containers on the project site will be labeled as to the contents, whether waste or otherwise. All waste stored on site must be inspected weekly using the Ohio Army National Guard Weekly Non-Hazardous and Hazardous Waste Inspection/Inventory Sheet (Attachment 6).

6.4. The Contractor is responsible for properly completing all waste profiles, waste manifests, and shipping documents (hazardous and non-hazardous waste). Such documents will be reviewed, approved, and signed by the OHARNG Environmental Office. No waste will leave the site until the shipping documents are reviewed, approved and signed by the OHARNG Environmental Office. The Contractor is responsible for weighing and documenting all waste material (regulated, diverted, landfilled) leaving the site. The Contractor will complete a Construction/Demolition Diversion and Waste Disposal Form (Attachment 7) and provide supporting documentation (weight tickets, manifests etc.) to the OHARNG prior to final payment.

6.5. The Contractor must manage used lamps (incandescent, fluorescent, mercury vapor, neon, high pressure sodium and metal halide) and other applicable wastes as universal waste in accordance with Ohio Administrative Code 3745-273-13(D) and the Ohio Environmental Protection Agency’s August 2011 Universal Waste Guidelines. Fluorescent light ballasts containing PCBs only in an intact and non-leaking capacitor must be disposed of in accordance with 40 CFR Part 761.60(b)(2)(ii). Fluorescent light ballasts containing PCBs in the potting material must be disposed of in accordance with 40 CFR Part 761.62.

Fluorescent light ballasts that are not marked specifically as “Non PCB Containing” must be treated as PCB containing ballasts. Disposition of used lamps and ballasts must be noted on the Construction/Demolition Diversion and Waste Disposal Form (Attachment 7) as noted in paragraph 4.4 above.

6.6. The Contractor is required to recycle materials when possible and practicable. Recycled materials must be tracked using the Construction/Demolition Diversion and Waste Disposal Form (Attachment 7). Materials that cannot be recycled or repurposed must be properly disposed of as solid waste at an appropriate waste handling facility. All solid waste must also be tracked using the Construction/Demolition Diversion and Waste Disposal Form (Attachment 7).

6.7. The Contractor is required to utilize qualified Defense Logistics Agency (DLA), Defense Marketing and Reutilization Organization (DRMO) waste haulers and Treatment, Storage, and Disposal Facilities (TSDFs) for hazardous waste. The current qualified waste hauler and TSDF list can be viewed by following the “Qualified Facilities” and “Qualified Transporters” links found on the DLA Disposition Services’ Hazardous Waste Disposal Homepage, http://www.dla.mil/DispositionServices/Offers/Disposal/HazardousWaste/HazWasteDisposal .aspx.

6.8. Gray water, vehicle wash water, and other liquid wastes (to include extracted groundwater and water from dewatering) generated by the Contractor will be managed in accordance with the waste management guidance in this section and applicable federal, state, and local regulations. Liquid waste will not be discharged to the land surface, surface water, storm drain/ditch, or a sanitary sewer unless properly characterized and done in accordance with applicable laws and applicable permit conditions. Liquid waste will be characterized and proper management and disposal methods identified and implemented. Guidance on construction site dewatering is provided in the section on Erosion Control, Storm Water and Other Surface Water Management.

7. Asbestos

7.1. Asbestos Identification: The asbestos content of all building materials to be impacted or disturbed during renovation, demolition, or project activities must be determined. Asbestos content can be determined by the following methods: 1) The Contractor can reference an existing asbestos survey for the building if one that meets the required Ohio EPA and Asbestos Hazard Emergency Response Act (AHERA) standards is available; or 2) If a building survey is not available, the Contractor must retain a licensed Certified Asbestos Hazard Evaluation Specialist (CAHES) to collect bulk samples for asbestos in accordance with the AHERA 40 CFR Part 763.86 {OAC 3745-22} and prepare a detailed comprehensive AHERA type report for each site where bulk samples are collected. If the Contractor conducts an asbestos survey, the report must be reviewed and approved by the OHARNG before it is final.

7.2. Asbestos Work Activities: All asbestos activities, including any disturbance or removal, must be conducted in accordance with applicable Federal, State, and local regulations.

Asbestos must be properly handled, removed, containerized, and disposed of in accordance with applicable Federal, State, and local regulations. The Contractor will complete a Construction/Demolition Diversion and Waste Disposal Form (Attachment 7) and provide supporting documentation (weight tickets, manifests etc.) for all wastes generated to the OHARNG prior to final payment. Asbestos removal methods and disposal operations will be detailed in the Environmental Work Plan to be reviewed and approved by the OHARNG Environmental Office prior to the start of work activities. All abatement activities will be conducted by a licensed abatement contractor in accordance with applicable Federal, State, and local regulations and guidance. All asbestos wastes generated as part of the building renovation or demolition activities and/or abatement activities must be disposed of in a licensed asbestos landfill. Disposal manifests and Regulated Asbestos Material Waste Shipment Records for all asbestos waste must also be signed and approved by an OHARNG Environmental Office representative or a representative designated by the Environmental Office prior to shipment from the project site or OHARNG facility.

7.2.1. Facility Demolition – No ACM Present

The Contractor is required to submit a completed Ohio Environmental Protection Agency (EPA) Notification of Demolition and Renovation Form to the OHARNG for review and approval 30 days prior to commencement of demolition. Upon receipt of written approval from the OHARNG Environmental Office, the approved notification and associated fee must be submitted to the Ohio EPA 10 business days prior to commencement of demolition. Under no circumstances is the Contractor to submit any correspondence to the Ohio EPA or any other regulatory agency without written approval from the OHARNG. Copies of all correspondence from the Ohio EPA or any other regulatory agency must be submitted to the OHARNG Environmental Office upon receipt. If suspected ACM not identified in the survey is discovered during the course of demolition, the Contractor must cease work immediately and notify the OHARNG project manager and Environmental Office.

7.2.2. Facility Demolition – ACM Present

The Contractor is required to submit a completed Ohio Environmental Protection Agency (EPA) Notification of Demolition and Renovation Form to the OHARNG for review and approval 30 days prior to commencement of demolition. Upon receipt of written approval from the OHARNG Environmental Office, the approved notification and associated notification fee must be submitted to the Ohio EPA at least 10 business days prior to commencement of demolition. Under no circumstances is the Contractor to submit any correspondence to the Ohio EPA or any other regulatory agency without written approval from the OHARNG. Copies of all correspondence from the Ohio EPA or any other regulatory agency must be submitted to the OHARNG Environmental Office upon receipt. If requested, the Contractor must provide a copy of the asbestos survey to the regulatory agency.

Previously completed asbestos surveys must be kept on the job site until the demolition activities are completed. If suspected ACM not identified in the survey is discovered during the course of demolition, the Contractor must cease work immediately and notify the OHARNG project manager and Environmental Office.

The Contractor is required to develop and submit an Environmental Work Plan that includes asbestos abatement to the OHARNG for review and approval prior to the commencement of work. The work plan will specify the procedures to be utilized by the contractor to ensure compliance with all applicable State and Federal asbestos regulations. The work plan will address the abatement techniques to be used, the safety precautions to be taken, and emergency procedures to be implemented in the event of inadvertent exposure. Proof/copies of proper and current contractor licensure must also be included in the work plan. The work plan will also address how the asbestos waste is to be handled, stored, transported, and disposed of in accordance with all applicable regulations. Site clearance procedures must be addressed in the plan. The plan must contain a detailed description of the project activities, including the amount (indicated in linear or square feet) of asbestos to be abated, the exact location and type of asbestos, and whether or not a contained work site will be established as required by 29 CFR Part 1926.1101.

Asbestos contractors must be properly licensed in accordance with applicable local, State, and Federal regulations. Only licensed contractors approved and licensed through the Ohio EPA will be utilized on OHARNG asbestos abatement projects.

The contractor will show proof of license and will maintain appropriate paperwork on the work site at all times. Work is to be performed in accordance with 29 CFR

1926.1101 (OSHA Asbestos Construction Standard) and 40 CFR Part 61 (Asbestos NESHAPS) in addition to accepted industry work procedures and other applicable local, State, and Federal regulations. The onsite Superintendent must be a ‘competent person’ as defined in 29 CFR 1926.1101(b) and must be onsite full time during the project.

An asbestos hazard abatement air-monitoring technician, or asbestos hazard evaluation specialist certified by the Ohio EPA, or a certified industrial hygienist or industrial hygienist in training as certified by the American Board of Industrial

Hygiene will clear the abatement job site using approved air sampling techniques.

Air sampling to be analyzed by phase contrast microscopy (PCM) will be conducted in accordance with National Institute of Occupational Safety and Health (NIOSH) method 7400 entitled “Fibers” published in the NIOSH manual of analytical methods, 3rd edition, second supplement, August 1987. A minimum of three samples will be taken. The samples must show that the concentration of fibers for each sample is less than or equal to a limit of concentration for PCM of

0.01 fibers/cm3 of air. Air sampling to be analyzed by transmission electron microscopy (TEM) must be conducted in accordance with the regulations established by the United State Environmental Protection Agency (U.S. EPA), 40 CFR Part 763, Subpart E, Appendix A. The Contractor will prepare a job-site clearance report that summarizes the air monitoring results. The report will include copies of the analytical results and the licenses/certifications of the individuals conducting the air-monitoring and the lab performing the PCM or TEM. Upon completion of abatement activities the Contractor must also prepare and submit an OHARNG Asbestos Abatement Project Management Closeout Form (Attachment 8).

The Contractor is responsible for managing all asbestos waste generated during the demolition of the facility. Any asbestos removed from an OHARNG facility must be properly abated, containerized, managed, labeled and disposed of as an asbestos waste in accordance with applicable local, State, and Federal regulations. Asbestos waste must be properly transported to an approved, licensed asbestos disposal facility. Waste shipment records must be maintained during transport. A final copy of the waste shipment record will be forwarded to the OHARNG within 30 days for recordkeeping. A representative from the OHARNG Environmental Department, or a representative designated by the Environmental Department, will review and sign all waste profiles and manifests generated as the result of any asbestos abatement activities prior to the shipment of the waste from an OHARNG facility to a disposal facility.

7.2.3. Facility Renovation – No ACM Present

If no ACM are identified in the survey, the Contractor does not need to submit an Ohio EPA Notification of Demolition and Renovation/Abatement Form.

However, the Contractor is required to develop and submit an Environmental Work Plan. If suspected ACM not identified in the survey is discovered during the course of demolition, the Contractor must cease work immediately and notify the OHARNG project manager and Environmental Office.

7.2.4. Facility Renovation – ACM Present

If the combined amount of regulated ACM is at least 260 linear feet on pipes or at least 160 square feet on other facility components or at least 35 cubic feet off facility components where length or area could not be measured previously, the Contractor will be required to submit a completed Ohio EPA Notification of Demolition and Renovation/Abatement Form to the OHARNG for review and approval 30 days prior to commencement of renovation. The approved notification and associated notification fees must be submitted to the Ohio EPA at least 10 business days prior to commencement of renovation. Under no circumstances is the Contractor to submit any correspondence to the Ohio EPA or any other regulatory agency without written approval from the OHARNG. Copies of any correspondence from the Ohio EPA or any other regulatory agency concerning the renovation of this facility must be submitted to the OHARNG Environmental Office upon receipt. Previously conducted asbestos surveys must be kept on the job site until the renovation activities are completed. If suspected ACM not identified in the survey is discovered during the course of renovation, the Contractor must cease work immediately and notify the OHARNG project manager and Environmental Office.

The Contractor is required to develop and submit an Environmental Work Plan that includes asbestos abatement procedures to the OHARNG, regardless of the amount of ACM abated, for review and approval prior to the commencement of work. The work plan will specify the procedures to be utilized by the contractor to ensure compliance with all applicable State and Federal asbestos regulations. The work plan will address the abatement techniques to be used, the safety precautions to be taken, and emergency procedures to be implemented in the event of inadvertent exposure. Proof/copies of proper and current contractor licensure must also be included in the work plan. The work plan will also address how the asbestos waste is to be handled, stored, transported, and disposed of in accordance with all applicable regulations. Site clearance procedures must be addressed in the plan. The plan must contain a detailed description of the project activities, including the amount (indicated in linear or square feet) of ACM to be abated, the exact location and type of ACM, and whether or not a contained work site will be established as required by 29 CFR Part 1926.1101.

Asbestos contractors must be properly licensed in accordance with applicable local, State, and Federal regulations. Only licensed contractors approved and licensed through the Ohio EPA will be utilized on OHARNG asbestos abatement projects.

The contractor will show proof of license and will maintain appropriate paperwork on the work site at all times. Work is to be performed in accordance with 29 CFR

1926.1101 (OSHA Asbestos Construction Standard) and 40 CFR Part 61 (Asbestos NESHAPS) in addition to accepted industry work procedures and other applicable local, State, and Federal regulations. The onsite Superintendent must be a ‘competent person’ as defined in 29 CFR 1926.1101(b) and must be onsite full time during the project.

An asbestos hazard abatement air-monitoring technician, or asbestos hazard evaluation specialist certified by the Ohio EPA, or a certified industrial hygienist or industrial hygienist in training as certified by the American Board of Industrial Hygiene will clear the abatement job site using approved air sampling techniques.

Air sampling to be analyzed by phase contrast microscopy (PCM) will be conducted in accordance with National Institute of Occupational Safety and Health (NIOSH) method 7400 entitled “Fibers” published in the NIOSH manual of analytical methods, 3rd edition, second supplement, August 1987. A minimum of three samples will be taken. The samples must show that the concentration of fibers for each sample is less than or equal to a limit of concentration for PCM of

0.01 fibers/cm3 of air. Air sampling to be analyzed by transmission electron microscopy (TEM) must be conducted in accordance with the regulations established by the United State Environmental Protection Agency (U.S.