National Environmental Policy Act by HC111125121442

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									National Environmental Policy Act
                       NEPA

• National Environmental Policy Act of 1969

• Policy in a nut shell – the Federal government
  must consider environmental impacts and
  alternatives in the decision making process




                   ECO Training Feburary 2007      2
          NEPA Requirements

1. Consider environmental impacts of proposed
   actions

2. Evaluate alternative actions

3. Disclose actions/impacts to the public

4. Integrate public participation into the decision
   making process
                   ECO Training Feburary 2007         3
        NEPA Implementation

• US Army implementing regulation is 32
  CFR 651, 29 March 2002

• Not all agencies implement NEPA the same

• Primarily construction and renovation
  projects, reserve training, and real estate
  actions
                 ECO Training Feburary 2007     4
                NEPA Process
                Documentation

• Record of Environmental Consideration (REC) – 1
  page, cost minimal
• Environmental Assessment (EA) – 3-6 month
  process, cost $20K to $200K, requires public
  notification
• Environmental Impact Statement (EIS) – 1-5 year
  process, $200K to $Ms, requires public
  notification
                   ECO Training Feburary 2007    5
       What ECOs Need to Know

1. The NEPA process is a legal requirement
2. Routine minor projects/actions are normally
   covered by a REC signed by the
   Environmental Coordinator
3. Major actions/projects typically require an EA


                  ECO Training Feburary 2007     6
Environmental Compliance Checklist
                           Fort Detrick
                 Environmental Compliance Checklist
                            Fort Detrick Environmental Management Office
                                   Environmental Compliance Checklist
                                                  for
                     Construction, Maintenance and Repair, and Demolition Activities


Project Title: ____________________________________________________________________________________

Brief Project Description: __________________________________________________________________________

________________________________________________________________________________________________

Proponent: ______________________________________________ Tel. No/E-Mail Address: ___________________

           □ Construction Project □ Maintenance Project □ Repair Project   □ Demolition Activity

Estimated Cost: ____________________

EMO Tracking No.: __________________________________ Tracking Start Date: __________________________



                                        ECO Training Feburary 2007                                 8
Compliance            Requirement                          Action Necessary                     Subject Matter
  Area                                                                                 Expert Remarks / Sign-off (See Note 1)
                                                 NEPA Compliance (301-619-3152)
National        Most projects must have          Type of NEPA Document Required:
Environmental   NEPA documentation               □ EIS    □ EA
Policy Act      completed before                 □ REC □ N/A
(NEPA)          groundbreaking can occur.

                                                     Storage Tank (301-619-3196)
Storage Tanks   Installation, modification, or   □   Permit Required
                removal of a storage tank        □   Permit Modification
                may have regulatory              □   State Notification Req.
                constraints in addition to
                permitting and other             □   Potential Contamination Issue
                notification requirements.
                                 Installation Restoration Program Considerations (301-619-3196)
Land Use        Soil-disturbing activities       □ No Land Use Restrictions
Restrictions    may be restricted because of     □ Restrictions Exist, See Remarks
                environmental
                contamination.



                                                 ECO Training Feburary 2007                                          9
Compliance              Requirement                       Action Necessary                       Subject Matter
  Area                                                                                  Expert Remarks / Sign-off (See Note 1)
                                         Natural Resources Compliance (301-619-2033)
Natural        Does the project impact on          □ No Action Required
Resources      wetland areas?                      □ Wetlands Permit Required
               □ Yes     □ No
               If the project exceeds a            □ No Action Required
               disturbance of 40,000 sf,           □ 15% Afforestation Required
               forestation requirements apply.     □ 2-for-1 Reforestation Required
                                         Cultural Resources Compliance (301-619-2033)
Cultural       Does the project impact on          □ No Action Required
Resources      protected archeological sites?      □ SHPO Consultation Required
               □ Yes □ No □ Maybe
               Does the project impact on          □ No Action Required
               historical buildings?               □ SHPO Consultation Required
               □ Yes □ No □ Maybe
                               Landscaping and Pest Management Requirements (301-619-2033)
Landscaping    Review plant list to screen for     □ No Action Required
               invasive species.                   □ Evaluation Required
Pest Control   Pest management to be provided    □ No Action Required
               by Garrison or by contractor?
                                              ECO Training Feburary 2007                                            10
                                                 □ Evaluation Required
Compliance          Requirement                    Action Necessary         Subject Matter   Subject Matter Expert
  Area                                                                      Expert Remarks     Sign-off (See Note 1)
                                            Storm Water Requirements (301-619-3136)
Storm Water   Projects disturbing more         □ No Action Required
Management    than 5,000 sf (or more than      □ Submission to MDE
              100 cy) must be approved         Required
              by MDE for E&SC before
              groundbreaking can occur.
              Projects disturbing more         □ No Action Required
              than 5,000 sf must include       □ Submission to MDE
              SWM. MDE approval is             Required
              required before
              groundbreaking can occur.
              Projects disturbing 1-acre       □ No Action Required
              (or greater) require an          □ Submission to MDE
              NPDES permit before              Required
              groundbreaking can occur.




                                                ECO Training Feburary 2007                                 11
Compliance          Requirement                        Action Necessary                          Subject Matter
  Area                                                                                  Expert Remarks / Sign-off (See Note 1)
                                           Sanitary Sewer Requirements (301-619-3136)
Waste Water   New users of sanitary sewer      □ No Action Required
              system or users with a           □ New User Discharge Form, FD
              significant addition to their    Form 1418
              discharge must submit new
              user form.
                                                      SPCC (301-619-3136)
Petroleum     Certain regulatory               □ No Action Required
              requirements apply if            □ Evaluation Required
              petroleum, oil, lubricants
              will be stored on site in
              excess of 55 gallons.
                                               Noise Requirements (301-619-3136)
Noise         Noise sources in excess of       □ No Action Required
              55 decibels (night) and 65       □ Evaluation Required
              decibels (day) are
              prohibited.




                                                ECO Training Feburary 2007                                           12
Compliance                  Requirement                         Action Necessary                      Subject Matter
  Area                                                                                       Expert Remarks / Sign-off (See Note 1)
                                             Air Emission Requirements (301-619-3906)
Air Emission      New air emission sources and major       □ No Action Required
Permitting        modifications of existing sources        □ Permits to Construct Required
                  require Permits to Construct and/or      □ Title V Permit to Operate
                  Permits to Operate.                      Amendment Required
Installation of   Large emergency generators require       □ No Action Required
Emergency         permits. Before permits can be           □ PSC Concurrence Letter
Generators        requested, proponent must obtain         Required
                  concurrence from the Maryland
                  Public Service Commission (PSC)
                  thru DIS.
New Source        Certain larger-scale new air             □ No Action Required
Review (NSR)      emissions sources and major              □ NSR Evaluation Required
                  modifications of existing sources        □ NSR Permit Required
                  require NSR Permits.
Conformity        New air emission sources and major    □ No Action Required
                  modifications of existing sources that□ Record of Non- Applicability
                  do not require NSR Permits require    and Conformity Evaluation
                  conformity evaluations and perhaps    Required
                  conformity determinations.            □ Conformity Determination
                                                   ECO Training Feburary 2007
                                                        Required                                                        13
Compliance              Requirement                   Action Necessary                 Subject Matter
  Area                                                                        Expert Remarks / Sign-off (See Note 1)
                         Hazardous Materials/Hazardous Waste Requirements (301-619-3441)
Hazardous    Hazardous Material purchases and      □ No Action Required
Materials    usage must be tracked and Hazardous   □ Evaluation Required
             Material storage is regulated.        □ Not Applicable
             Will the construction or demolition   (No regulated HW onsite)
             activity:
             □ Procure, Utilize or Store
             Hazardous Materials on site.
             Will the completed project:
             □ Procure, Utilize or Store
             Hazardous Materials on site.

Hazardous    Hazardous Waste generators are        □ No Action Required
Waste        regulated.                            □ Evaluation Required
             Will the construction or demolition   □ Not Applicable
             activity:                             (No regulated HW onsite)
             □ Generate or Accumulate Hazardous
             Waste on site.
             Will the completed project:
             □ Generate or Accumulate Hazardous
             Waste on site.
                                           ECO Training Feburary 2007                                      14
Compliance                 Requirement                      Action Necessary                 Subject Matter
  Area                                                                              Expert Remarks / Sign-off (See Note 1)
                                       Recycling/Affirmative Procurement Requirements
                                                (301-619-3169 or 301-619-1266)
Affirmative     Per the Fort Detrick Affirmative        □ Evaluation of
Procurement -   Procurement Plan, construction and      Comprehensive Procurement
Buy Recycled    maintenance and repair projects are     Guidelines Required
                required to purchase EPA-designated     □ No Action Required
                products made with recycled materials   □ Justification Required
                unless justification is provided.
Solid Waste     All construction, renovation and        □ No Action Required
Recycling       demolition projects will include        □ Contract Specs will
                contract performance requirements for   include a requirement for
                a 50% minimum diversion of              C & D Waste Management
                construction and demolition (C&D)       Plan
                waste by weight, from landfill
                disposal. (ACSIM Policy Memo,
                Sustainable Management of Waste in
                Military Construction, Renovation,
                and Demolition Activities, 6 Feb
                2006).



                                                ECO Training Feburary 2007                                       15
    Compliance                                  Requirement                                    Action Necessary                                Subject Matter
      Area                                                                                                                            Expert Remarks / Sign-off (See Note 1)
                                                                                        Miscellaneous
   PCBs                      PCBs may be encountered during                              □ No Action Required
                             demolition, or during maintenance and                       □ Evaluation Required
                             repair.
   Lead                      Lead-based paint may be encountered                         □ No Action Required
                             during demolition, or during maintenance                    □ Evaluation Required
                             and repair.
   Mercury                   Mercury may be encountered in drains                        □ No Action Required
                             and thermostats during demolition,                          □ Evaluation Required
                             maintenance or repair.
   Exit Signs &              Exit signs and smoke detectors may                          □ No Action Required
   Smoke                     contain radioactive materials and must be                   □ Evaluation Required
   Detectors                 disposed of properly.
   Forestation               Removal of trees larger than 2.5”                           □ No Action Required
                             diameter requires 2-for-1 replacement.                      □ Evaluation Required
   Demolition                EPA and MDE must be notified.                               □ No Action Required
                                                                                         □ EMO Action Required
   Renovation                If Asbestos will be disturbed, EPA and                □ No Action Required
                             MDE must be notified.                                 □ EMO Action 2007
                                                                           ECO Training FeburaryRequired                                                                         16
*Note 1: Signature of Subject Matter Expert (SME) indicates that all prerequisites to construction have been satisfactorily fulfilled, and/or the SME will work closely with the Project Proponent
to ensure environmental compliance in the SMEs program or media area.
Compliance       Requirement   Action Necessary                        Subject Matter
  Area                                                        Expert Remarks / Sign-off (See Note 1)
                                  Environmental Approvals
Released for                                         This project is approved for   All Environmental, Cultural,
Construction                                         construction. However,         and Natural Resources
                                                     there are compliance           prerequisites to construction
                                                     requirements that need to be   have been
                                                     addressed during the           fulfilled.________________
                                                     construction period.           Environmental Coordinator
                                                     □ Erosion and Sediment         Sign and Date
                                                     Control (E&SC) only.
                                                     □ E&SC plus Additional
                                                     Items.
Final Approval                                                                      All Environmental, Cultural,
                                                                                    and Natural Resources
                                                                                    prerequisites to construction
                                                                                    have been
                                                                                    fulfilled.________________
                                                                                    Environmental Coordinator
                                                                                    Sign and Date




                               ECO Training Feburary 2007                                            17

								
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