DEPARTMENTS OF THE ARMY MASSACHUSETTS ARMY NATIONAL GUARD TRAINING SITE CAMP EDW AROS CAMP EDWARDS, MA 02542-5003 Comma nd er Camp Edwards Lynne A. Jennings U.S. Enviro nmental Protec ti on Agency 5 Post Office Square, Suite 100 Mail Code OSRR07-3 Boston, MA 02 109-39 I 2 12 October 20 I 3 Subject: Supplemental Environmental Project (SEP) Complet io n Report, Consent Agreement and Final Order (CA FO), Docket No. SDW A 0 l- 20 12-002 1 Dear Lynne, As required by the above ref erenced CAFO, please consider this letter to be the Massachusetts Army National Guard's (MAARNG) SEP Completion Report. As il lustrated below, the MAARNG has met the two primary requirements of th e SEP, namely removal of at least 14 ac res of asphalt by the 4 October 20 I 3 dead I in e, and an expend it1.1re of fund s in excess of $1 03, 125 to acco rnpl ish the prqj cc t. The CAFO, Paragraph 53, as modified by a US EPA letter of 5 August 2013, requires th at th e MAARN G submit a SEP Completion Repo rt to the USE PA w it hin 30 days after the completion of th e SEP. That deadline is 12 October 20 13. Paragraph 53 of the CAFO also requires that the SEP Comple ti on Report contain the fo llowing information: (i) a detai led descripti on of the SEP as impl eme nt ed; ( ii ) list of it emized costs for implementing the SEP; ( iii ) a certifica ti on by Respondent that the SEP has been fully im plemented purs ua nt to t he provisions oft hi s CAFO; (iv) a description of any SEP ope rat in g problems encountered and the solutions thereto; a nd (v) a description of th e environmental a nd public hea lth ben e fit s res ult in g !l·om implementation oft he SEP. This information is included below. {i) Detailed desc• ·i ption of the SEP as implemented Work commenced on this project on November 3, 20 12 in comp li ance with the CA FO requireme nt that work beg in within 90 days of the approval (August 29, '2012) of the CAFO, making the d ea dline to sta rt work 29 November 20 12. The attached map (Enclos ur e I, Figure I) indi ca tes the areas designated as SEP impervious surface (aspha lt) areas that were agreed on by USEPA and the MAARNG and subse qu ently removed. Enclosure I, Figure 2 is a photograph of th e area after impervious surface removal. As of 28 Jun e 20 13 approximately 627,264 square feet or 14.4 acres of impervious surface had been re moved. The initial st·a1 iup effo rt lo r t hi s project was conducted 3-4 November 2012 and was performed by the Faci liti es Engineers (FE) at Camp Edwards. Pr ior to the FE effort, th e areas to be removed were delineated, with a ll sensitive infrastructure marked by DigSafe and/ or by AFCEEC (Mo ni toring Wells). FE removed approx im ate ly 0.235 acres of asphal t. T he 1 01 '' Engineer Batta li on oft he MAARNG conducted the work from thi s poi nt forward. Work continued again during the period 26-30 November
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DEPARTMENTS OF THE ARMY MASSACHUSETTS ARMY NATIONAL GUARD TRAINING SITE
CAMP EDW AROS CAMP EDWARDS, MA 02542-5003
Commander Camp Edwards
Lynne A. Jennings U.S. Environmenta l Protecti on Agency 5 Post Office Square, Suite 100 Mail Code OSRR07-3 Boston, MA 02 109-39 I 2
12 October 20 I 3
Subject: Supplemental Environmental Project (SEP) Complet ion Report, Consent Agreement and Final Order (CA FO), Docket No. SDW A 0 l-20 12-002 1
Dear Lynne,
As required by the above referenced CAFO, please consider this letter to be the Massachusetts Army Nat ional Guard' s (MAARNG) SEP Completion Report. As il lustrated below, the MAARNG has met the two primary req uirements of the SEP, namely remova l of at least 14 acres of asphalt by the 4 October 20 I 3 dead I ine, and an expend it1.1re of fund s in excess of $ 1 03, 125 to accornpl ish the prqjcct.
The CAFO, Paragraph 53, as modified by a US EPA letter of 5 August 2013 , requires that th e MAARNG submit a SEP Completion Report to the USE PA within 30 days after the completion of th e SEP. That deadline is 12 October 20 13. Paragraph 53 of the CAFO also requi res that the SEP Completion Report contain the fo llowing information: (i) a detai led descripti on of the SEP as implemented; (ii) list of itemized costs for imp lementing the SEP; ( iii) a certification by Respondent that the SEP has been fully im plemented pursuant to the provisions ofthi s CAFO; (iv) a description of any SEP operating problems encountered and the solutions thereto; and (v) a description of the environmental and public hea lth benefits result ing !l·om implementation ofthe SEP. This information is included below.
{i) Detailed desc•·iption of the SEP as implemented
Work commenced on this project on November 3, 20 12 in compliance with the CA FO requirement that work beg in within 90 days of the approval (August 29, '2012) of the CAFO, making the deadline to start work 29 November 20 12. The attached map (Enclosure I, Figure I) indicates the areas designated as SEP impervious surface (aspha lt) areas that were agreed on by USEPA and the MAARNG and subsequently removed. Enclosure I, Figure 2 is a photograph of th e area after impervious surface removal. As of 28 Jun e 20 13 approx imately 627,264 square feet or 14.4 acres of impervious surface had been removed.
T he initial st·a1iup effort lo r thi s project was conducted 3-4 November 2012 and was performed by the Faci lities Engineers (FE) at Camp Edwards. Pr ior to the FE effort, the areas to be removed were delineated, with a ll sensitive infrastructure marked by DigSafe and/or by AFCEEC (Monitoring Wells). FE removed approx imate ly 0.235 acres of aspha lt. The 101 ' ' Engineer Batta lion ofthe MAARNG conducted the work from thi s poi nt forward. Work continued again during the period 26-30 November
20 12 and during the period 3-7 December 20 12. An additi onal 1.6 acres of materia l was removed at this ti me. following this cffo11, work stopped due to the hol idays and inclement weather. Asphalt removal continued aga in during the period 8-19 April with the remova l o f an add it iona l 4 acres of impervious sutface . As of20 Apri1 20 13 approximately 5.79 acres of impervious surface had been removed. AI this point, as required by the CAFO, Attachment I, Sec\ ion C, the MAARNG conducted a meeting with USEPA proj ect statTto review the SEP implementation lo date .. issues encountered, and issues anticipated with the remaining acres of impervious surface removal. Work began aga in on 6 May 20 13. As of28 June 20 13 approximately 14.4 acres of impervious surface had been removed from the project area. ·rhe excavated material was transported to the Unit Tra ining Equipment Site (UTES) at Ca rnp Edwards where the mate ri al was screened. Most of the screened exca vatecl asphalt materia l was transported ofr-site for rec lamation and recyc ling. The total volume of SEP material transported offsi le was 6024.30 tons. This work was completed on 12 September 20 I 3.
The SEP area wi ll be le ft to seed natural ly fo1m the surrou nding environments. Thi s will allow for native flora \o establ ish itself within the grassland area. The area wi II be monitored for invasive plant species such as bittersweet (Celastrus orbicu/atus), honey suckle (Lonicera sp.), autumn olive (Eiaegnus umbellata). The area wi ll also be managed to contro l the density of native pitch pine that can act like an invasive species by growing into a lllonoculture that is not beneficial to the goa l of grassland restoration.
(ii) List of itemized costs for implementing the SEP
Please see Enclosu re 2 for a list of itemized costs incurred in implementing the SEP. The enclosure includes the cost by each yearly quarter of personnel, fuel, and disposa l. These are the categories of costs that the CAFO prov ides may be inc luded in meet ing the tota l cost requi remen t of$103,125 mentioned above. The costs are as follow: personnel- $83,6 I 6.23, fuel - $ 16,775.45, and reclamation/ recycling$39, I 57 .95. The tota l cost of the SEP in these categories is $ 139,549.62.
(ii i) Certification by Responuent that the SEP has been fully implemented pursuant to the provisions of this CAFO
As per Paragraph 53 of the CAFO, the Massachusetts National Guard certifies that the SEP has been fully impl emented pursuant to the provis ions of the CAFO.
(iv) Description of any SEP operating problems encountered a nd the solutions the•·eto
Three issues were encountered during the project; ( I ) there was a need to have the natura l gas I ine area characterized as "dig safe" (completed througlt Key Span). (2) a certain amount of the asphalt materia l needed to be trncked off s ite for recycling which required a change to the language in the CAFO, Attachment I, Section Cas described below. and (3) a lwo month extension of time for completion of the SEP was req uested as described below and granted by USEPA.
It should be noted tha t a high pressure natural gas ma in passes through the SEP Are<:1. However, il was not necessary to comple te another Dig Safe as the gas main area was avo ided during the SEP effort.
As a result or the potential need to truck material orr si te, the MAARNG requested and US EPA approved in a 29 May 20 I 3 letter a rnoclilicalion to the CAFO so \hat the rele va nt language in Attachment 1, Sect ion C read: ''Respondent shall remove and stockp ile recla imed materia ls at the s ite of the proposed UTES faci lity within MM R. Respondent sltal l have the option of transpo1iing any portion or such rec laimed materia ls off-base to a faci lity to be processed for reuse or recyc li ng. Storage, transportation, or disposal by Respondent of the recla imed materials sha ll be in accordance with any applicable laws or regulations related to storage, transpo11ation, or disposal of the excavated asphalt materia l."
2
A second CAFO change request was submitted by the MAARNG to USEPA on 31 July 2013 and approved by US EPA in a 5 August 2013 letter. This change resu lting in the followi ng specific changes: changing the CAFO SEP completion deadline from 9 months to ll months (from 5 August to 4 October) under Section IV, Paragraph 51, " Implementation'', and changing the SEP period of completion deadline from 275 days to 335 days in Attachment 1, Paragraph G, "Schedu le" of the CAFO. This request was made to allow for letting a contract to remove the excavated material from the UTES site to an offsite, reclamation, and recycling facility. In addition to the above changes, the CAFO was also modi fied with agreement by both pa11ies to require that the SEP Completion Report be submitted to USEPA within 30 days following the completion of the SEP.
v. Description of the environmental a nd public health benefits resulting from implementation of the SEP.
The SEP will increase storm water absorption capacity, increase groundwater recharge and reduce the flow of pollutants in stonn water in impacted areas at the Faci lity. In addition, the SEP will also increase and improve the area of non-fragmented habitat for grassland bird species. By removing the 14 acres or bituminous surface the project indirectly expanded the grassland by a total 20 acres. This was accomplished by the removal of a road, access points, and sidewalk along the northeastern side of the project area. Removal of this road allowed the MANG to expand the grassland towards Richardson Road. Historically tbis area has been kept mowed which was not in keeping wid1 proper grassland management. The area will now be mowed only for keeping a safe shoulder along the road. By doing this an additional 6 acres will be added to the grassland area. The SEP will in particular benefit the following bird species: the upland sandpiper (Bartramia longicauda), the grasshopper sparrow (Ammmodramus savannarum), the vesper sparrow (Pooecetes gramineus), and the northern harrier (Circus cyaneus-). Other grassland flora and fauna will benefil as well. For example, Iepidoptera species (moths and butterflies) such as the state threatened pink streak (Faronla r~tbripennis) wi ll benefit from increasing non-fragmented, grassland habitat that will allow for its host, switch grass (Panicum virgatum) plant to grow and expand. Although there is no public access to Camp Edwards, the public's health will always benefit from increased open space, ecosystem quality and by improving the aquifer through increased volume by creating improved recharge conditions.
Please let us know if you have any questions regarding the presented information.
1 cert!fy under penalty of lmv that this document and all attachments were prepared under my direction or supervision in accordance ·with a system designed to assure that qualified personnel properly gather and evaluafe the information submilled. Based on my inquiry of the person or persons who manage the system, the information is, fo the best of my knowledge and belief true, accurate and complete. I am aware that there are significant penalties for submitting false il?formation including the possibility of fines and imprisonment.
Enclosures: (2)
3
~full/t/IJJ _ ZitS:~ P.~<I?~~
MAJOR Administrative Officer
Enclosure l
Figure I. Impervious surface removal area on Joint Base Cape Cod
Supplemental Environmental Project Impervious Surface Removal Area
Camp Edwards and Otis Air National Guard Base
4
ious surface removal area with surface removed
SEP Aerial View Looking South East June 201 3
5
3-4NOV 12 I rvtANPOWIR
Personnel Manhours
Cost $
EQUIPMENT
Hours Gallons (IP-S}
Cost $
PROOOCTION
5 51
1,048.43
3'2 69
27255
SQFT 10252
ACRES 0235353535
COST/I>.cre S S,612.n
r::nAtS Production L6B%
Con S 1.,320.98
Enclosure 2.
SEP Quarterly Cost
SEP Production Report
lm penrious Surfare Remtwal Projea
I I I I
t\1\an Power tost is derived from Grade and Time-! n-Sernce fTlS). hours worked on the project a:nd P<ry Status (IDT or ADOS)
Equipment Cost is based so 'ey on GaUons of JP-S fueJ consumed.
Production rs &5 a percerrnge against ttle-14 acre requirement
6
ReponPuiod 03-04 NOVEMBER 2012
I
s
s
YTD
5 5
1,04a43
6S
27255
1025 2 0.235353535
s 5,612.73
s 1,320.98
MANPOWER
Pe.-sonJl€1
Ma:nhcurs Cost
EQ:UlPMENT
Hours Gallons (JP-8}
Co;t
PRODUCTION
SQFT
ACRES
COST/Acre
TOTAlS
Prod\Jction
Cost
SEP Production Report
1mp!!f"Vious Surhce Removoll"roject
3~4NOV 12 I 2b-30Nov12. I 0~70e.d2 I I
5 3 3
51 4() 40
$ 1.048.43 $ 1,806.95 $ 1,806.95
32 lOS 105 69 200.5 205.25
$ 272.55 5 79L 9S $ 810.74 s s
10,252 38,000 30,000
02354 o.sn4 0.6887
s 310.% s 2, 267.30 $ 1,800.80 s s
L6S'Iti 6 .23% 4.92'16
s 1,320.98 s 2,5SS.93 s 2,617.69 s $
I
s
s
s
Report P.eritt.d
26November-07December 2012
I YTD
11
:31
$ 4,662.33
242 474.75
s 1,.875.26
78.25<
1.796~
s 4,38l.Of;
12.83'lt
s 6,537.59
M;:n Power cost is d.eri"~ from Gn~de and Time-In-Service (TtS). hours worked on tile project and f>ey Status (IDT or AOOS}
Equipment Cost is based soley on G.allons of JP-8 fuel consumed.
Production is as a perc.entilgE: against me 14 acre requirement
7
MA.NPC\VER
Penonnel M.anhours
Cost $
EQUIPME.NT
Hours
Gallons (JP-8)
Cost s
PRODUCTION
SQFT
ACRES
COST/Acre $
rrOTAlS
Produa ion
Cost $
SEP P'rodu-ctron Report
Impervious Surla<:e Removal l'roj.ect
3-4 Novl2 26 Nov-7 0& 12 8-1.9 Ape 13
5 3 13
51 240 1324.5 1,048_43 s 3,613.90 s 14,408.77
32 210 565.1 69 405.75 lHO
272.55 s 1,602.71 s 4,503.00
10,252 68,()()() 1H,630
0.1354 ~561 4
5,611.64 s 3,341.84 s 4,727.94
1.68~ 11.15~ 2&.579(,
1, 320.98 s 5,.216.61 $ 18,91L77
Report Period
26 N'!WembH-19 April 2013
Tonl.sto~te
2:1
1615-5
s 19.071.10
807.1
1614.75
s 6.,378..26
251,882
5.7!f64
s 4,'560A7
41....4096
$ 25.,449.36
Man Power cost is derived from Grade and rrm!Hn-Service. (TIS), hours wOflutd on the project a.nd Pay S.tatus (IDT or ADOS)
Equipm<!!nt Cost is biltSed sote·v on Gallons of JP-8 fue.l consumed..
ProdltClion is as a percent<l~;e against the 14 ane requirement
8
3-4Nov U
MANPOWER
Personnel 5
Manhours Sl Ccm s. 1,048.43
£QUIPMENT
Hours 32 Gallons {JP-$) 69
Co:s1 s 272.55
PRODUCTION
SQFT 10,252
ACRES 0..2354 CO!ir/A<:re s 5,611.64
TOTAlS
Production 1.&8%
Co~ s 1,320.98
Sa> Production Report
Impervious Surface RE!m()val Project
26 Nov-7 Dec 12 8-19Apr 13 6-19MAY 13
3 13 13
240 ll24.5 1456 s 3,613.90 s 14,4(18.77 S26,270.16
210 565.1 1297.3 405.75 1140 1805.2
s 1 ,602..71 $ 4,503.{)0 s 7,H054
&8,000 173,630 271,379
lSGl 3.986 6.23
s 3,34L84 s 4,744.55 $ 5,361.27
11.15% 28.47% 44.50%
s 5,216.61 $. 1!:,911.77 s 33,400.70
s
s
s
Report Period
03 Nover.-,ber 2012-29 June 2013
16-29JUNB Tol:ill5 10 Date
14 4B
1568 4639.5
526,658.10 s 71.9~.36
312.75 2.417.15
827 42A6.95
3,265.65 s 16,175.45
87,120 610.38.1
2 14 .• 012.4 14,962.:32 s 6,.80&1.33
1.4.29% 100.09Wi
29,924.75 $ 88,774.81
Man Power cost is deri'lled ~from Gr.~de a.nd Trrne-!ln-Service (TIS), hours workEd on the project imd Pay St<ttm {IDT or ADOS)
Equ;pment Cost is based so ley on Gallo!"!S of JP-8 fuel consumed.
Produroon is as a perc:e-nt.~se a~nst the 14 aue requirement
9
Persormel Cost
10
DATE NAME HOURS COST($)
3-Nov-12 SGT David Pina 6 120.52
3-Nov-12 SGT Brian Newcomb 6 120.52 3-Nov-12 SGT Brian Messia 6 120.52
3-Nov-12 SGT Brian Duarte 6 120.52
4-Nov-12 SGT David Pina 7 140.60
4-Nov-12 SGT Brian Newcomb 7 140.60
4-Nov-12 SGT Brian Messiu 7 140.60
4-Nov-12 SGT Brian Duarte 4 80.34 4-Nov-12 SFCJames Costa 2 64.21
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