DRAFT ENVIRONMENTAL ASSESSMENT FOR THE …In 2019, a 95% Investment Grade Audit (IGA) report was...

DRAFT ENVIRONMENTAL ASSESSMENT

FOR THE INSTALLATION AND OPERATION OF SOLAR PHOTOVOLTAIC, BOILER PLANT, AND

COMBINED HEAT AND POWER SYSTEMS

CHARLIE NORWOOD VETERANS AFFAIRS MEDICAL CENTER AUGUSTA, GEORGIA

Prepared for: Department of Veterans Affairs

National Energy Business Center

Prepared by:

MAY 2019

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Proposed Solar Photovoltaic, Boiler Plant, and CHP Systems Draft Environmental Assessment Charlie Norwood VAMC

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CONTENTS Purpose and Need for Proposed Action ......................................................................... 1-1 1.0

1.1 Introduction ......................................................................................................... 1-1 1.2 Purpose and Need for Proposed Action ............................................................. 1-1 1.3 Location of Proposed Action .............................................................................. 1-2

Proposed Action and Alternatives .................................................................................. 2-1 2.02.1 Proposed Action ................................................................................................. 2-1

2.1.1 Solar Photovoltaic System and Boiler Plant Replacement – Uptown Campus .................................................................................................. 2-1

2.1.2 Combined Heat and Power System – Downtown Campus .................... 2-2 2.2 No Action Alternative .......................................................................................... 2-3 2.3 Alternatives Considered and Eliminated ............................................................ 2-4

2.3.1 Solar Photovoltaic Systems Screening ................................................... 2-4 2.3.2 CHP System Screening .......................................................................... 2-5

Affected Environment/Environmental Consequences .................................................... 3-1 3.03.1 Introduction ......................................................................................................... 3-1 3.2 Impact Analysis .................................................................................................. 3-3

3.2.1 Types of Impacts .................................................................................... 3-3 3.2.2 Significance Criteria ................................................................................ 3-4

3.3 Air Quality ........................................................................................................... 3-5 3.3.1 Existing Environment .............................................................................. 3-5 3.3.1 Impacts of Proposed Action .................................................................... 3-8

3.4 Cultural and Historic Resources ......................................................................... 3-9 3.4.1 Existing Environment .............................................................................. 3-9 3.4.2 Impacts of Proposed Action .................................................................. 3-10

3.5 Aesthetics/Visual Resources ............................................................................ 3-11 3.5.1 Existing Environment ............................................................................ 3-11 3.5.2 Impacts of Proposed Action .................................................................. 3-11

3.6 Noise ................................................................................................................ 3-12 3.6.1 Existing Environment ............................................................................ 3-12 3.6.2 Impacts of Proposed Action .................................................................. 3-14

3.7 Utilities .............................................................................................................. 3-16 3.7.1 Existing Environment ............................................................................ 3-16 3.7.2 Impacts of Proposed Action .................................................................. 3-17

3.8 Waste Management ......................................................................................... 3-18 3.8.1 Existing Environment ............................................................................ 3-18 3.8.2 Impacts of Proposed Action .................................................................. 3-19

3.9 Environmental Consequences of No Action Alternative ................................... 3-20 3.10 Cumulative Impacts .......................................................................................... 3-20

Persons and Agencies Contacted .................................................................................. 4-1 4.0 References ..................................................................................................................... 5-1 5.0 Glossary ......................................................................................................................... 6-1 6.0 List of Preparers ............................................................................................................. 7-1 7.0


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TABLES: Table 3-1. Resources or Attributes Not Described or Evaluated .............................................. 3-1

Table 3-2. Air Quality Standards and Monitored Data .............................................................. 3-6

Table 3-3. Charlie Norwood VAMC Greenhouse Gas Emissions Inventory (2018) .................. 3-8

Table 3-4. Sound Level and Loudness of Typical Noises .............................................. 3-12

Table 3-5. Typical L90 Sound Levels in Residential Communities ........................................... 3-13

Table 3-6. Noise Levels Associated with Outdoor Construction ............................................. 3-14

FIGURES: Figure 1-1. Location of Charlie Norwood VAMC (Uptown & Downtown Campuses) ............... 1-3

Figure 1-2. Proposed Location of Rooftop PV Arrays and New Boilers – Uptown Campus .... 1-4

Figure 1-3. Proposed Location of CHP System – Downtown Campus ..................................... 1-5

Figure 2-1. Microturbine System ............................................................................................... 2-3


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Acronyms and Abbreviations µg/m3 micrograms per cubic meter

ACM asbestos-containing material

AQCR Air Quality Control Region

BAS building automation system

BMP Best Management Practice

CAA Clean Air Act

CBOC Community Based Outpatient Clinic

CEQ Council on Environmental Quality

CFR Code of Federal Regulations

CHP combined heat and power

CO carbon monoxide

CTG combustion turbine generator

dB decibel

dBA A-weighted decibel

DNL Day-night sound level

EA Environmental Assessment

ECM energy conservation measure

EISA Energy Independence and Security Act

EMCS Energy Management Control System

EO Executive Order

FY fiscal year

GADNR Georgia Department of Natural Resources

GAEPD Georgia Environmental Protection Division

GE General Electric

GHG greenhouse gas

HRSG heat recovery steam generator

HUD Housing and Urban Development

IGA Investment Grade Audit

IPCC Intergovernmental Panel on Climate Change

kW kilowatt

kWh kilowatt hour


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Leq equivalent sound level

MMBtu million British thermal units

MW megawatt

NAAQS National Ambient Air Quality Standards

NANSR Non-attainment New Source Review

NEPA National Environmental Policy Act

NHPA National Historic Preservation Act

NOx nitrogen oxides

NSR New Source Review

O3 ozone

OSHA Occupational Safety and Health Administration

Pb lead

PM10 particulate matter with a diameter of 10 microns or less

PM2.5 particulate matter with a diameter of 2.5 microns or less

ppb parts per billion

ppm parts per million

PSD Prevention of Significant Deterioration

PV photovoltaic

RICE reciprocating internal combustion engine

sf square foot

SIP State Implementation Plan

SO2 sulfur dioxide

USEPA United States Environmental Protection Agency

UST underground storage tank

VA Department of Veterans Affairs

VAMC Veterans Affairs Medical Center

VISN Veterans Integrated Service Network


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1-1 May 2019

PURPOSE AND NEED FOR PROPOSED ACTION 1.01.1 INTRODUCTION The Department of Veterans Affairs (VA) is considering a number of alternatives for reducing the energy intensity at its facilities. Three potential means of energy reduction are the installa-tion of solar photovoltaic (PV) systems, replacement of existing, inefficient boilers, and the in-stallation of combined heat and power (CHP) systems. In 2019, a 95% Investment Grade Audit (IGA) report was completed by Ameresco, Inc. on the installation of rooftop PV systems and replacement of the boiler plant at the VAMC Uptown campus. A separate 95% IGA report (Ameresco) was also completed for the installation of a CHP system at the Downtown campus (Ameresco 2019a and 2019b). The proposed project en-tails the construction and operation of solar PV systems on two buildings (Buildings 95 and 110) at the Uptown campus of the Charlie Norwood VAMC, replacement of the boiler plant at the Up-town campus, and installation of a CHP system at the Downtown campus (Building 802). This action would provide an efficient source of electrical energy for each campus and provide an efficient source of steam heat for the Downtown Division. The proposal to install solar PV systems, new boilers, and a CHP system at the Charlie Nor-wood VAMC in Augusta, Georgia (also referred to as the Augusta VAMC) is a federal action subject to the procedural requirements of the National Environmental Policy Act of 1969 (NEPA) (42 United States Code 4321 et seq.). NEPA requires federal agencies to consider environmen-tal consequences in their decision-making process. The Council on Environmental Quality (CEQ) issued regulations (40 Code of Federal Regulations [CFR] Parts 1500-1508) to imple-ment NEPA that include provisions for both the content and procedural aspects of the required environmental analysis. The VA complies with NEPA and CEQ implementing regulations in ac-cordance with 38 CFR Part 26 (Environmental Effects of the Department of Veterans Affairs Ac-tions). The VA prepared this Environmental Assessment (EA) to analyze potential direct, indirect, and cumulative environmental impacts of the installation and operation of solar PV systems, a new boiler plant, and a CHP system (Proposed Action). For purposes of comparison, this EA also evaluates the impacts of not installing solar PV systems, a new boiler plant, or a CHP system (No Action Alternative). There are no other alternatives analyzed in detail. This EA meets the VA’s compliance requirements under NEPA and provides the necessary information for VA to make an informed decision regarding the proposed installation and use of solar PV systems, a new boiler plant, and a CHP system at the Charlie Norwood VAMC Uptown and Downtown campuses.

1.2 PURPOSE AND NEED FOR PROPOSED ACTION Specific laws and executive orders require federal agencies to reduce energy consumption and improve energy efficiency through the use of alternative fuels and renewable sources. The fed-eral government has passed legislation and provided directives to federal agencies, such as the VA, that require these agencies to reduce energy use, reduce reliance on traditional fossil fuel-based energy sources, and increase the use of renewable energy sources at their facilities. Re-newable energy sources include wind, solar, geothermal, biomass, and other sustainable meth-ods. The National Energy Conservation Policy Act serves as the underlying authority for federal energy management goals and requirements. Signed into law in 1978, it has been regularly up-


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dated and amended by subsequent laws, the most recent being the Energy Independence and Security Act of 2007 (EISA). The following provides a brief summary of the federal requirements to which the VA is subject:

• In 2005, Congress passed the Energy Policy Act. Section 203 of this Act requires that, of the total amount of electric energy the federal government consumes during any fiscal year (FY), specific amounts shall be from renewable energy sources. Section 203 of the Energy Policy Act requires that, for FYs 2013 and beyond, not less than 7.5 percent of the federal agency's consumed energy must be renewable in nature. In addition, the Act specifies that, “For the purposes of determining compliance, the amount of renewable energy saved shall be doubled if: (a) The renewable energy is produced and used onsite at a federal facility; (b) The renewable energy is produced on federal lands and is used at a federal facility; or (c) The renewable energy is produced on Indian land and used at a federal facility.”

• Executive Order (EO) 13834, Regarding Efficient Federal Operations (May 17, 2018), di-rects federal agencies to achieve and maintain annual reductions in building energy use and implement energy efficiency measures that reduce costs; to meet statutory require-ments relating to the consumption of renewable energy and electricity; and to utilize per-formance contracting to achieve energy, water, building modernization, and infrastructure goals.

The VA has a need for reliable energy at its health care facilities while pursuing options for re-ducing energy demand and cost. The VA must also meet the renewable energy goals estab-lished by laws and EOs. The purpose and need for installing and operating new solar PV arrays, a new boiler plant, and a CHP system (Proposed Action) would be to meet the goals of federal energy policy and EO 13834 through installation of renewable and/or more efficient energy sys-tems to reduce the amount of electrical energy needed from commercial sources. Operation of these systems would also reduce the VAMC’s greenhouse gas emissions at both the Uptown and Downtown campuses.

1.3 LOCATION OF PROPOSED ACTION The Charlie Norwood VAMC consists of two facilities in Augusta, Georgia, located approximate-ly three miles apart (Figure 1-1). The Uptown Division is located at 1 Freedom Way, and the Downtown Division is located at 950 15th Street. The VAMC is part of Veterans Integrated Ser-vice Network (VISN) 7, which also includes facilities in South Carolina, Alabama, and other communities in Georgia, and is a two-division, three-Community Based Outpatient Clinic (CBOC) medical center providing tertiary care in medicine, surgery, neurology, psychiatry, re-habilitation medicine, and spinal cord injury. The Downtown Division is authorized 156 beds and the Uptown Division is authorized 93 beds. In addition, a 132-bed Restorative/Nursing Home Care Unit and a 60-bed Domiciliary are located at the Uptown Division. The Uptown Division consists of 23 buildings over 105 acres. The buildings are arranged in a campus-style setting. The Downtown Division is located in an urban area on approximately 20 acres of land, with one 7-story hospital building (Building 801) and an Energy Plant Building (Building 802). The proposed solar PV systems would be installed on the rooftops of Buildings 95 and 110 at the Uptown Campus; the replacement of the boiler plant would occur within Building 81 (Figure 1-2). The CHP system would be installed within and adjacent to the existing Energy Plant Build-


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ing (Building 802) at the Downtown Campus (Figure 1-3). The final design would be determined by the VA.

Figure 1-1. Location of Charlie Norwood VAMC (Uptown & Downtown Campuses)


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Figure 1-2. Proposed Location of Rooftop PV Arrays and New Boilers – Uptown Campus


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Figure 1-3. Proposed Location of CHP System – Downtown Campus


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PROPOSED ACTION AND ALTERNATIVES 2.02.1 PROPOSED ACTION The Proposed Action is to construct and operate roof-mounted solar PV arrays and new boilers at the Uptown Campus of the Charlie Norwood VAMC and to construct and operate a CHP sys-tem at the Downtown Campus. This action would provide an efficient source of electrical energy for both campuses and provide an efficient source of steam heat for the Downtown Division. Georgia Power Company provides electricity to both the Uptown and Downtown campuses of the Charlie Norwood VAMC. Natural gas is supplied via the Atlanta Gas Light Company distribu-tion system. Water and sewer services are purchased from the Augusta Utilities Department (Ameresco 2019a). The proposed solar PV installation, boiler plant replacement, and CHP sys-tem installation are described below in Sections 2.1.1 and 2.1.2.

2.1.1 Solar Photovoltaic System and Boiler Plant Replacement – Uptown Campus

Under the Proposed Action, the Charlie Norwood VAMC would implement two rooftop PV arrays and would replace the existing boiler plant at the Uptown Division. Solar Photovoltaic Arrays: The proposed rooftop PV arrays would be mounted to the roofs of two existing buildings: Building 95, a 42,236-square foot (sf) Laundry Facility and Pharmacy Dis-tribution Center constructed in 1954 and Building 110, the 714,221-sf Main Hospital, construct-ed in 1991. A 160-kilowatt (kW) rooftop system would be installed on Building 95; a 717-kW rooftop system would be installed on Building 110. There is an existing 1.2-megawatt (MW) PV system in place at the VAMC. The additional PV panels would increase the site’s total PV ca-pacity to 2.1 MW. The roofs would be inspected prior to installation to determine their structural integrity and ca-pacity to support the proposed PV arrays. As needed, the roof of each building would be pre-pared with an adequate, engineered foundation to support the units. A standard construction crane or, most likely, a small roof-mounted hoist would be used to lift the solar panels to the rooftop location. A small area adjacent to each building may be temporarily cordoned off and used as a construction staging area. Extended utility outages are not expected as part of the proposed installation. The rooftop arrays installed at the Uptown campus would be capable of supplying up to 1,246,740 kilowatt-hours (kWh) of electricity annually (Ameresco 2019a). Performance of the PV arrays is dependent on the season (highest output in spring and fall), weather conditions (highest output in full sun), and time of day (highest output at mid-day). All of the power produced by the solar PV systems would be consumed by the Charlie Norwood VAMC; there would be no excess power to distribute back to the commercial power grid. In the event of a power failure, the PV arrays would not be equipped to provide backup power to the facility. The Uptown Division would continue to maintain their diesel generators for providing backup power. All relevant building and other municipal codes would be met. The engineering and construction contractors would be responsible for applying for relevant permits. The estimated construction start date for the PV arrays is mid- to late-2020. The expected construction period is 24 months. The estimated cost of the PV arrays is approximately $2.3M (Ameresco 2019a).


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Boiler Plant Replacement: The central heating plant located in Building 81 consists of three natural-gas fired steam boilers. Monthly boiler logs and combustion testing from 2017 indicate that the boiler plant is operating at an average efficiency of 76 percent (Ameresco, 2019a). Un-der the Proposed Action, three new 200 BHP Cleaver Brooks CBEX Elite steam boilers would be installed in the central heating plant along with a new deaeration system, new flues, new economizers, and boiler feedwater pumps. A new feedwater chemical treatment system would also be installed. Flow meters would be provided for steam, feedwater flow, makeup water flow, fuel flow, and any other parameters necessary for verification of project performance. The new boilers would interface with the existing steam distribution system and steam to hot water con-verters and other ancillary equipment in the campus buildings. The three existing boilers and associated equipment would be removed from the central plant. Temporary boilers would be provided to cover the off-peak warm season load while the boilers are being replaced. Natural gas to the central plant would be interrupted during installation. (Ameresco 2019a). Replacement of the existing boilers would save an estimated 1,207,515 kWh in electricity usage and an estimated 1,802 million British thermal units (MMBtu) annually (Ameresco 2019a). In addition to installation of the solar PV arrays and replacement of the boilers, the VA also pro-poses several other Energy Conservation Measures (ECMs) at the Uptown campus. These ECMs include the installation of building automation systems/energy management and control systems (BAS/EMCS) to replace existing pneumatic systems, the installation of LED lighting throughout the facility, the replacement of transformers throughout Buildings 110 and 111, and the replacement of high-flow water fixtures with high performance, low-flow fixtures at the Up-town campus (Ameresco, 2019a).

2.1.2 Combined Heat and Power System – Downtown Campus Under the Proposed Action, the VA would install a 1.4 MW microturbine system in combination with a Heat Recovery Steam Generator (HRSG) to generate electricity onsite and to offset steam produced by the boiler plant. One Capstone C800S modular microturbine consisting of four 200-kW turbine generators and one Capstone C600S modular microturbine consisting of three 200-kW turbine generators would be installed on concrete pads within an existing, paved storage area on the southwest side of Building 802. Within each module the compressor, tur-bine, and combustion turbine generator (CTG) are mounted on a single shaft. The modular de-sign allows for individual turbine units to be serviced while the remaining units continue operating. The natural gas-fired CTG unit would be base-loaded to operate continuously to produce elec-tric power. Exhaust heat from the CTG would be directed through the HRSG. The HRSG would recover waste heat from the combustion turbine exhaust gas and convert it to thermal energy in the form of steam. The steam from the HRSG would be routed to the Energy Building steam header via an overhead connection. The steam generated from the heat recovery system would be used year-round throughout the Downtown campus. Steam piping and HRSG feed water lines would be routed between the microturbines and the existing boilers. The proposed CHP technology would help improve the overall energy efficiency of the facility and thus would contribute to achieving the overall energy reduction goals set by the VA. Installation of the CHP system would provide an estimated 10,822,416 kWh in annual electrical usage (Ameresco, 2019b).


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The CHP system would have the ability to provide some backup power to the facility, in conjunc-tion with existing backup generators. The Downtown campus would continue to maintain its die-sel generators for providing backup power. The CHP system would not be designed such that excess power would be distributed to the commercial power grid. All power produced by the system would be consumed onsite by the VA. A 12-foot-high x 77.3-feet-long x 28.6’-wide reinforced concrete masonry wall would be con-structed around the 2,211-sf microturbine area to reduce noise impacts. The HRSG would be installed within the existing 21,200-sf Energy Plant Building (Building 802), constructed in 1980.

Figure 2-1. Modular Microturbine System

An existing lawn equipment storage shed at the proposed site would be moved to a different location within the parking/laydown area in order to accommodate the microturbines. Mainte-nance area fencing and the existing sidewalk and curb adjacent to the paved lot would also be removed. Approximately seven parking spaces would be relocated during construction. Local air permits would be required for the proposed CHP system; all relevant building and oth-er municipal codes would need to be met. The engineering and construction contractors would be responsible for applying for relevant permits. The estimated construction start date for the CHP system is early 2019. The expected construction period is 24 months. The estimated cost of the CHP system is approximately $7.8M. In addition to the CHP system, the VA proposes several other ECMs at the Downtown campus. These ECMs include the installation of BAS/EMCS to replace existing pneumatic systems, the installation of LED lighting throughout the facility, upgrades to facility transformers, and the in-stallation of high-efficiency fixtures and retrofits for the facility’s water and sewer system (Ameresco, 2019b).

2.2 NO ACTION ALTERNATIVE Under the No Action Alternative, the Proposed Action would not be implemented. The Charlie Norwood VAMC would continue to receive the majority of its electricity from Georgia Power and would retain the current boiler system at the Uptown Division. The Charlie Norwood VAMC


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would not, therefore, be fully able to meet the federal energy-saving and GHG reduction goals and objectives of the Energy Policy Act of 2005, EO 13834, and the EISA. While the No Action Alternative would not satisfy the purpose of or need for the Proposed Ac-tion, this alternative was retained to provide a comparative baseline against which to analyze the effects of the Proposed Action, as required under the CEQ Regulations (40 CFR 1502.14). The No Action Alternative reflects the status quo and serves as a benchmark against which the effects of the Proposed Action can be evaluated.

2.3 ALTERNATIVES CONSIDERED AND ELIMINATED As part of a broad initiative by the VA to assess the potential for installation of renewable energy systems at VA properties across the U.S. to meet the requirements of the Energy Policy Act of 2005, EO 13834, and EISA, the VA conducted evaluations of multiple locations identified as po-tentially feasible to support solar arrays and a CHP system at the Downtown Division. The VA did not consider offsite locations.

2.3.1 Solar Photovoltaic Systems Screening For the installation of solar PV arrays, the VA applied site-specific screening criteria to identify the number of reasonable onsite locations and the size and type of PV arrays that would be suitable at the Charlie Norwood VAMC campuses. The list below summarizes the screening cri-teria that were used by the VA: Structural Support: The structures proposed for rooftop mounting locations should be able to support the weight of a PV system, and should be flat or slightly pitched to facilitate installation. Operation of the Facility: The PV systems should not interfere with the current or future pro-posed operations of the facility, including transportation, parking, infrastructure, and mainte-nance activities or sites. In addition, the proposed PV locations should not conflict with proposed future site development plans or projects. Solar Exposure: In order to maximize potential energy output from each PV system, each sys-tem should be located to maximize the amount of sunlight it receives daily, without shading from adjacent structures or trees. Light and Glare: The location of the systems should minimize the potential for light and glare affects to surrounding properties and land uses; existing and proposed land uses adjacent to the facility should not be taller than the proposed PV locations. This would simultaneously avoid current and future solar exposure limitation issues. Accessibility: The PV location should be readily accessible for construction and maintenance purposes. Aesthetics: The PV location should not detract from the visual aspects of the campus. The PV systems should not result in an adverse effect to the viewshed of any historic properties as de-fined under Section 106 of the National Historic Preservation Act (NHPA). Cost: The PV arrays should be installed in a manner that minimizes costs, such as the poten-tial costs incurred through construction of new infrastructure to support the proposed project. Environmental: Each proposed PV location must have few environmental concerns, such as


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water resources, floodplains and flooding, cultural or biological concerns, or other regulated en-vironmental resource. Through this process, the VA identified several buildings and other areas in the two campuses as viable options for PV arrays. In total, the VA identified four locations at the Uptown Division and one location at the Downtown Division that would be suitable locations for PV arrays. The VA conducted additional evaluations of the locations identified to determine which buildings or locations would ultimately receive solar arrays. The evaluations weighed construction con-straints, cost, and projected PV output from the rooftop and ground-mounted arrays, and also considered future planned construction projects at the facility. Based on these considerations, the facility decided that two rooftop arrays at the Uptown Campus would be analyzed in this EA; the other locations evaluated have been dismissed from detailed analysis.

2.3.2 CHP System Screening The VA undertook a sequential planning and screening process for the location of a CHP sys-tem at either the Uptown or Downtown campus. The screening criteria developed by the VA are listed below:

• The alternative chosen should assist the VA in meeting the requirements of the Energy Policy Act of 2005, the EISA, and EO 13834.

• Minimal area is available for constructing new buildings or infrastructure at the facility since most of the area in the property is being utilized; therefore, the alternative to be carried forward for analysis must have a footprint suitable for limited development space constraints.

• The chosen alternative should have been deemed feasible in terms of size and cost. Based on the results of the screening process and the system’s failure to meet one or more of the required screening criteria, the VA eliminated from consideration a CHP system at the Up-town Division. This alternative is dismissed from further analysis in this EA. The VA determined that the electrical and steam demands of the Downtown Division would make it a better candi-date for a larger CHP system, which would allow for greater net energy savings for the facility, and a greater potential to meet the federal energy requirements described in Section 1.2. The VA also reviewed and dismissed alternative technologies such as ground source heat pumps, carport PV arrays, and wind turbines based on associated site-specific construction constraints, cost, and projected output.


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AFFECTED ENVIRONMENT/ENVIRONMENTAL 3.0CONSEQUENCES

3.1 INTRODUCTION The existing environmental conditions (i.e., affected environment) serve as a baseline from which to identify and evaluate potential changes or impacts attributable to the Proposed Action. Baseline environmental conditions were identified from aerial photos, topographical maps, exist-ing documents, data from planning and resources agencies’ websites, and communications with VA personnel. The intent of NEPA is to focus the analysis on the human (i.e. physical, biological, and social) environment potentially affected by the federal action. Resources and attributes of the human environment that are not present on or in the vicinity of the Charlie Norwood VAMC or that would not be affected by the Proposed Action are not discussed. Table 3-1 lists these resources and provides the rationale for excluding them from further description and from impact analysis.

Table 3-1. Resources or Attributes Not Described or Evaluated

Resource/Attribute Rationale for Excluding from Evaluation Aviation/Radar Neither the solar PV panels, boilers, nor the CHP system would af-

fect flight patterns or radar communication used by aircraft. Community Service The VA anticipates that it would hire two new part-time employees to

maintain the PV arrays at the Uptown campus and operate the CHP system at the Downtown campus. The increase in personnel as a result of the Proposed Action would be negligible compared to the current level. Therefore, there would be no increased demand for community services (e.g., emergency, fire, and police services; schools; libraries; churches).

Economic Activity Installation and operation of the proposed solar PV arrays, boilers, and CHP system is not anticipated to affect the local economy. Alt-hough construction workers may patronize nearby businesses, any short-term beneficial effect to the economy would be minimal.

Environmental Justice The Proposed Action would not have significant adverse impacts, and therefore, any low income or minority populations that may be in the vicinity of the Augusta VAMC Uptown or Downtown Division would not be disproportionately affected.

Environmental Regu-lations

The installation and operation of the solar PV arrays, boilers, and CHP systems would comply with applicable regulations.

Floodplains, Wet-lands, and Coastal Zones

There are no jurisdictional wetlands or 100-year floodplains within the footprint of the Proposed Action. Neither Division of the Augusta VAMC is located within the state coastal zone; the Proposed Action would have no impacts to the coastal environment.

Geology and Soils Soils on the site of the proposed CHP system are already disturbed and covered with impervious surface. The project would follow all appropriate best management practices (BMPs) and regulations for minimizing erosion and runoff. Given the existing disturbed nature of the site, geology and soil impacts would be negligible.


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Resource/Attribute Rationale for Excluding from Evaluation Human Health and Safety

The construction, operation, and maintenance of the solar PV ar-rays, boiler system, and CHP system, including changes to the inte-rior of Building 802, would involve use of machinery and chemicals that pose a hazard to human health and safety. Construction areas would be off limits to visitors. The HRSG component of the CHP sys-tem and the new boilers would be contained within a building; the microturbines would be surrounded by an acoustical enclosure. This would reduce the potential for harm to any visitors, patients, or peo-ple nearby. The construction, operation, and maintenance of the so-lar PV arrays, new boilers, and CHP system would comply with all applicable regulations and BMPs including use of appropriate pro-tective clothing, proper maintenance of all equipment, and standard operating procedures for safety when conducting rooftop work. Im-pacts to human health and safety would be minimal.

Hydrology and Water Quality

The project area for the CHP system and boilers is currently covered with impervious surface (primarily asphalt and concrete) or is within an existing building; the project area for the solar PV arrays is on the rooftops of two existing buildings. Adverse impacts during the con-struction period, including spills, would be avoided or minimized by compliance BMPs. The amount of impervious surface at the site would not change, so there should be no change to runoff as a result of this project. All maintenance and wastes associated with the Pro-posed Action would be handled in a manner compatible with appro-priate regulations. Thus, impacts to hydrology and water quality should be negligible.

Land Use Installation of rooftop solar PV arrays, new boilers, and a CHP sys-tem would not impact existing or planned land use.

Potential for Creating Substantial Contro-versy

Use of updated, efficient or renewable utility systems is generally viewed by the public as favorable. The installation of a solar PV ar-rays, new boilers, and a CHP system would not likely create any negative controversy for the VA.

Real Property The solar PV arrays, new boilers, and CHP system would be within the boundaries of the Augusta VAMC; no change in land ownership, boundaries, or tax values would occur.

Resident Population The installation, operation, and maintenance of the solar PV arrays, new boilers, and CHP system would not cause the resident popula-tion to increase more than negligibly in the short term, if at all.


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Resource/Attribute Rationale for Excluding from Evaluation Transportation and Parking

During construction of the PV arrays and replacement of existing boilers at the Uptown campus, there would be a temporary increase in traffic at the facility due to constructing workers commuting to the site. This increase in traffic would be accommodated by the facility’s existing two entrances, which would allow for flexibility in delivery routes. Adequate parking is available at the Uptown Division to ac-commodate additional vehicles. No impacts to transportation and parking are anticipated from construction and operation of the PV arrays and replacement of existing boilers. During construction of the CHP system, there would be temporary increases in traffic at the facility due to construction workers com-muting to the site. The current transportation infrastructure would be capable of handling this increase in traffic. The Proposed Action would require the relocation of seven parking spaces at the Down-town Division. Impacts are anticipated to be temporary during con-struction and long-term during operation due to the relocation of parking spaces. Impacts would be negligible to minor.

Vegetation and Wild-life

The PV arrays, boilers, and CHP system would be installed in previ-ously disturbed areas (i.e., on an existing, paved lot, within an exist-ing building, and on the rooftops of existing buildings). The project would not result in the removal of any habitat or undisturbed land. During construction, equipment and material staging would either take place in previously disturbed areas adjacent to the construction location, or on paved surfaces.

3.2 IMPACT ANALYSIS The analysis of environmental consequences for each resource area begins by explaining the methodology used to characterize potential impacts, including any assumptions made. The im-pacts analysis considers how the condition of a resource area would change as a result of im-plementing the Proposed Action alternative, as well as the No Action Alternative; and describes the types of impacts that would occur (direct, indirect, beneficial, adverse). The types of impacts are defined in the next section. The significance of impacts is assessed using four parameters: magnitude, duration, extent, and likelihood of occurrence; these are described in Section 3.2.2.

3.2.1 Types of Impacts The terms “impacts” and “effects” are used interchangeably in this chapter. According to the Council on Environmental Quality’s (CEQ) National Environmental Policy Act (NEPA) Regula-tions at 40 Code of Federal Regulations (CFR) 1500-1508, direct and indirect effects are de-fined as: Direct effects: Effects that are caused by the action and occur at the same time and place (1508.8(a)). Indirect effects: Effects that are caused by the action and are later in time or farther removed in distance but are still reasonably foreseeable. Indirect effects also include “induced changes” in the human and natural environments (1508.8(b)).


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In other words, direct impacts are those that are caused directly by the Proposed Action, such as the installation of solar PV arrays that would reduce the electricity consumption at the Up-town campus. Indirect impacts are those follow-on effects induced by the initial impact. For ex-ample, a significant increase in the use of renewable energy at the VAMC would reduce the annual cost of electricity at the site. Identified impacts may be either adverse or beneficial. The CEQ Guidelines that govern NEPA implementation describe the need for identifying and differentiating between adverse and bene-ficial impacts, but do not offer a definition of these terms. For this EA, the following definitions have been used by NEPA analysts: Adverse impacts: Those impacts which, in the judgment of an expert resource area analyst, are regarded by the general population as having a negative and harmful effect on the analyzed resource area. An adverse impact causes a change that moves the resource area away from a desired condition or detracts from its appearance or condition. Beneficial impacts: Those impacts which, in the judgment of an expert resource area analyst, are regarded by the general population as having a positive and supportive effect on the ana-lyzed resource area. A beneficial impact constitutes a positive change in the condition or ap-pearance of the resource area or a change that moves the resource area toward a desired condition.

3.2.2 Significance Criteria The significance of impacts was determined systematically by assessing four parameters of en-vironmental impact: magnitude (how much), duration (how long), and extent (sphere of influ-ence. Each parameter was divided into the following levels: Magnitude:

• Major – Substantial impact or change in a resource area that is easily defined, noticea-ble and measurable, or exceeds a standard.

• Moderate – Noticeable change in a resource area occurs, but the integrity of the re-source area remains intact.

• Minor – Change in a resource area occurs, but no substantial resource area impact re-sults.

• Negligible – The impact is at the lowest levels of detection – barely measurable but with perceptible consequences.

• None – The impact is below the threshold of detection with no perceptible consequenc-es.

Duration:

• Permanent – Impact would last indefinitely.

• Long-term – Impact would likely last the lifetime of the project, or for as long as the pro-posed solar PV arrays and CHP system are utilized.

• Medium-term – Impact would extend past the transition phase, or construction phase, and into the operations phase; eventually merging into the long-term.


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• Short-term – Impact would last the duration of the construction phase.

• Temporary – Impact would be continuous and last for a portion of the construction phase.

• Intermittent – Impact would not be constant or continuous but rather recurring or period-ic. Intermittent impacts could occur temporarily or in the short-, medium-, or long-term.

Extent:

• Large – Impacts would affect the resource area on a county, regional, or state level, ex-tending well past the immediate Project area.

• Medium or localized – Impacts would affect the resource area only in the Project area or its immediate surroundings, and would not extend into the county, region, or state. For example, noise impacts from building construction activities are usually localized as they can be heard from approximately 1,000 feet.

• Small or limited – Impacts would affect the resource area over a portion of the Project area.

3.3 AIR QUALITY

3.3.1 Existing Environment The U.S. Environmental Protection Agency (USEPA) Region 4 and the Georgia Department of Natural Resources (GADNR), Environmental Protection Division (GAEPD), regulate air quality in Georgia. The Clean Air Act (CAA) (42 USC 7401-7671q), as amended, gives the USEPA the responsibility to establish the primary and secondary National Ambient Air Quality Standards (NAAQS) (40 CFR Part 50) that set acceptable concentration levels for seven criteria pollutants: fine particulate matter with a diameter of 10 microns or less (PM10), very fine particulate matter with a diameter of 2.5 microns or less (PM2.5), sulfur dioxide (SO2), carbon monoxide (CO), ni-trogen oxides (NOx), ozone (O3), and lead (Pb). Short-term standards (1-, 8-, and 24-hour peri-ods) have been established for pollutants that contribute to acute health effects, while long-term standards (annual averages) have been established for pollutants that contribute to chronic health effects. Georgia has adopted these federal standards (GADNR 2013). Certain geographic areas, typically defined by county, that are in violation of the NAAQS are classified as nonattainment areas and those in accordance with the NAAQS are classified as attainment areas. Maintenance areas are attainment areas that were formerly designated nonat-tainment, and have implemented plans to maintain their attainment status. States which contain nonattainment areas must adopt a State Implementation Plan (SIP) that is a compilation of goals, strategies, schedules, and enforcement actions designed to lead the state into compli-ance with all NAAQS. The General Conformity Rule (40 CFR Part 51, Subpart W and 40 CFR Part 93) ensures that the actions taken by federal agencies in nonattainment and maintenance areas do not impede the state’s ability to achieve the NAAQS in a timely fashion. The Charlie Norwood VAMC campuses, and therefore all activities associated with the Proposed Action, are within the Augusta (Georgia) – Aiken (South Carolina) Interstate Air Quality Control Region (AQCR) (40 CFR 81.114). USEPA has designated Richmond County (which is contained within the Augusta – Aiken AQCR) as in attainment for all criteria pollutants (USEPA 2019a). Table 3-2 shows the monitored concentrations of criteria pollutants at the monitoring location closest to the Augusta VAMC.


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Table 3-2. Air Quality Standards and Monitored Data

Pollutant Air Quality Standards Monitored Data CO

1-houra (ppm) 35 2.8 8-houra (ppm) 9 1.4 NO2 1-hour (ppb) 100 52

O3 8-hourb (ppm) 0.075 0.061

SO2 1-houra (ppb) 75 68.3 3-houra (ppm) 0.5 <no data>

PM2.5 24-hourc (µg/m3) 35 28.1 Annual arithmetic meand (µg/m3) 15 9.1

PM10 24-Houra (µg/m3) 150 26

Source: 40 CFR 50.1-50.12, USEPA 2018. The ‘Monitored Data’ is outdoor air quality data recorded by monitoring stations located in or near Richmond County, GA. Note: ppm = parts per million, µg/m3 = micrograms per cubic meter, NO2 = Nitrogen dioxide a Not to be exceeded more than once per year b The 3-year average of the fourth highest daily maximum 8-hour average O3 concentrations over each year must not exceed 0.08 ppm. c The 3-year average of the 98th percentile of 24-hour concentrations at each population-oriented monitor must not exceed 35 µg/m3. d The 3-year average of the weighted annual mean PM2.5 concentrations must not exceed 15.0 µg/m3.

Class I federal lands include areas such as national parks, national wilderness areas, and na-tional monuments which are granted special air quality protections under the CAA. According to 40 CFR Part 81, no Class I areas are located within 10 kilometers of the proposed project. The closest Class I area is Shining Rock Wilderness Area in North Carolina, which is approximately 140 miles to the north- northwest of Augusta. Regulatory and Permitting Review. The CAA, as amended in 1990, mandates that state agencies adopt and implement SIPs to eliminate or reduce the severity and number of violations of the NAAQS. Since 1990, Georgia has developed a core of air quality regulations that the USEPA has approved. These approvals signified the development of the general requirements of the SIP. The Georgia program for regulating air emissions affects industrial sources, com-mercial facilities, and residential development activities. Regulation occurs primarily through a process of reviewing engineering documents and other technical information; applying emission standards and regulations in permit issuance, performing field inspections; and assisting indus-tries in determining their compliance status with applicable requirements. As part of these requirements, the GAEPD, Air Protection Branch oversees programs for permit-ting the construction and operation of new or modified stationary source air emissions in Geor-gia. GAEPD air permitting is required for many industries and facilities that emit regulated pollutants. These requirements include Title V permitting of major sources, new source review permits (NSR), prevention of significant deterioration (PSD), New Source Performance Stand-ards for selected categories of industrial sources, and the National Emission Standards for Haz-


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ardous Air Pollutants. The Charlie Norwood VAMC would be required to modify their existing air permits and include the CHP system in their inventory process. Permitting scenarios can vary based on the final design (i.e., types and sizes of new stationary sources), timing of the projects, and the types of controls ultimately selected. These can differ in specific features from the ones described in this EA. However, during the final design stage and the permitting process either (1) the actual equipment, controls, or operating limitations would be selected to reduce the emissions below the major source threshold; (2) the permitting pro-cess would require emissions offsets to be obtained from other previously decommissioned sources within the region, or (3) the PSD permitting process would ensure the NAAQS was not exceeded and the emissions from the project would be included in the regional emissions inven-tory ensuring it would not interfere with the ability of the state to meet the NAAQS. This cap-and-trade-type system is inherent to federal and state air regulations and leads to a forced re-duction in regional emissions. Therefore, regardless of the ultimate permitting scenario, these impacts would be minimal under NEPA. The general requirements for permits and permit revisions are codified under the Georgia SIP Rules of Air Quality Control, Chapter 391-3-1-.03. Installation of new equipment would require a SIP Construction and Operating Permit (SIP Application). The Georgia SIP Application is used to apply for initial air quality permits and for modifications to existing air quality permits. Major NSR air quality construction permitting is divided into PSD permitting for attainment pollu-tants and nonattainment NSR (NANSR) for nonattainment pollutants. PSD permitting would be required if the federal action would cause a net increase in the attainment pollutants such that it would cause or contribute to a violation of any state or NAAQS. As previously discussed, Rich-mond County is designated as attainment area for all criteria pollutants. Major new or modified source construction permits in nonattainment areas (or NANSR Permit) are required for any major new sources or major modifications to existing sources intended to be constructed in an area designated as nonattainment (391-3-1-.02). The major source thresh-old varies from 10 tons per year to 100 tons per year for nonattainment pollutants depending on the severity of the nonattainment classification and the pollutant (40 CFR 51.165). NANSR per-mits are legal documents that specify what construction is allowed; what emission limits must not be exceeded; reporting, recordkeeping, and monitoring requirements; and often how the source may be operated. This is an extensive and public permitting process requiring 18 to 24 months or more to complete. The two campuses of the Charlie Norwood VAMC are currently permitted as synthetic minor sources of air emissions as defined by the CAA. GAEPD issued a synthetic minor air quality permit to the Downtown campus on April 14, 1998, and to the Uptown campus on May 5, 2004. The permits provide federally enforceable limitations on the amount of pollutants emitted from the facilities (i.e., emissions must remain below the Title V operating permit thresholds). Greenhouse Gases and Climate Change. The climate in the Augusta, Georgia region is char-acterized by hot, humid summers and cool winters. Precipitation is fairly evenly distributed throughout the year, the wettest month being March with approximately 4.6 inches of precipita-tion, and the driest month being November with approximately 2.7 inches. January, historically the coldest month, has an average minimum temperature of 33.1 degrees Fahrenheit (°F). In July, historically the warmest month, maximum temperatures average to approximately 92.0°F and can fluctuate by cooling 22°F from day to evening (IDcide 2019).


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GHGs are components of the atmosphere that trap heat near the surface of the earth, and therefore, contribute to the greenhouse effect and climate change. Most GHGs occur naturally in the atmosphere, but increases in their concentration result from human activities such as the burning of fossil fuels. Global temperatures are expected to continue to rise as human activities continue to add CO2, methane, NOx, and other greenhouse (or heat-trapping) gases to the at-mosphere. Some observed impacts from climate change include shrinking of glaciers, thawing of permafrost, later freezing and earlier break-up of ice on rivers and lakes, lengthening of grow-ing seasons, shifts in plant and animal ranges and earlier flowering of trees (USEPA 2007; IPCC 2007). Federal agencies, states, and local communities address climate change by preparing GHG in-ventories and adopting policies that will result in a decrease of GHG emissions. Table 3-3 pre-sents the 2013 inventory of GHG emissions associated with operation of the two Divisions of the Charlie Norwood VAMC.

Table 3-3. Charlie Norwood VAMC Greenhouse Gas Emissions Inventory (2018) Location Total GHGs (tons)

Uptown 12,741 Downtown 19,945

3.3.1 Impacts of Proposed Action Construction. Mobile and stationary construction equipment would be used for the construction and installation of the PV system and replacement of the three existing boilers at the Uptown Campus, and the installation of a new CHP system at the Downtown Campus. The expected construction would occur over a period of 24 months, beginning in early 2020. Some construc-tion equipment would generate emissions due to the combustion of diesel fuel and gasoline. Particulates in the form of fugitive dust may occur during construction activities. Reasonable precautions would be implemented during construction to prevent particulate matter from be-coming airborne. Such precautions may include:

• Use of water for dust control during construction operations;

• Covering open equipment when conveying or transporting material likely to create objec-tionable air pollution when airborne;

• Promptly removing spilled or tracked dirt or other materials from paved streets;

• Construction contractors would protect adjacent buildings from equipment and vehicle emissions by implementing the following actions as necessary: o Protect all active building air intakes from external contaminants (e.g., dust, exhaust,

chemicals, etc.). o Turn off vehicles and equipment when not in use. o Keep internal combustion engines away from building air intakes. o In the event that vehicles or equipment are required to operate in close proximity to

an air intake, coordinate with VA to block or filter potentially contaminated intakes and provide building makeup air from other clean air intakes.

o Use low emission equipment (electrically powered) when feasible.


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Impacts to the environment during construction would be adverse, minimal, localized, and tem-porary. Operations. Long-term beneficial effects would be expected as a result of the Proposed Action due to indirect reductions in the use of fossil-fuel based electricity and an increase in the operat-ing efficiency of the new boilers at the Uptown Campus. The current electricity consumption in the Uptown Campus stands at 13.3 million kWh per year (see Section 3.5, Utilities). The pro-posed PV arrays on Buildings 110 and 95 would save an estimated 1,246,740 kWh of electric energy annually. Additionally, the new boilers would operate at an increased efficiency of 85 percent (compared to the current operating efficiency of 76 percent), resulting in 7 kWh of elec-tric energy savings annually. This overall reduction in site electricity consumption would result in a decrease in air emissions at the site. Long-term adverse effects on air quality could occur as a result of operating the CHP system at the Downtown Campus because operation of the CHP would require the use of an additional 256 million cubic feet per year of natural gas. However, these effects would be minor because the existing steam boilers would be taken off-line. Operation of the CHPs would decrease the electric consumption at the Downtown Campus remarkably, with the potential to reduce peak loads by 81 percent. This reduction in site electricity consumption would result in a decrease in air emissions at the electricity generation site. The VA and its contractors would design and construct a CHP system that meets the environmental control requirements set by USEPA and other local, state, and federal environmental protection agencies. These requirements would include, at a minimum, Best Available Control Technology, and other controls as required, for the facility and its associated equipment. The General Conformity Rule requires federal agencies to determine whether their action(s) would increase emissions of criteria pollutants above preset threshold levels (40 CFR 93.153(b)). These de minimis (i.e., of minimal importance) rates vary depending on the severity of the nonattainment and geographic location. The General Conformity Rule applies only to sig-nificant actions in nonattainment and maintenance areas. Since Richmond County is in attain-ment, the requirements of the General Conformity Rule are not applicable. Greenhouse Gases and Climate Change. The proposed PV arrays for the Uptown Division would reduce the use of fossil fuel-based electricity and associated GHGs, resulting in an esti-mated reduction of 977 tons of CO2-eq per year (USEPA 2019b). Additionally, the new, high-efficiency boilers would utilize ultra-low emission technology to reduce GHG emissions. The CHP system at the Downtown Division would generate and deliver electricity at a greater effi-ciency (i.e., significantly fewer losses in distribution when the power is generated and consumed locally) as compared with the power delivered by the local electric utility. Overall, there would be a reduction of 4,026 tons of GHGs in the Uptown Campus, and 7,435 tons of GHGs in the Downtown Campus as a result of implementing the Proposed Action alternative. Therefore, the Proposed Action would result in a long-term minor decrease to GHGs in the atmosphere, result-ing in a long-term, minor, beneficial impact. Because of this net decrease, the Proposed Action would be consistent with the Energy Policy Act and EISA.

3.4 CULTURAL AND HISTORIC RESOURCES

3.4.1 Existing Environment Under the Proposed Action, the Area of Potential Effect (APE) for the proposed structures is anticipated to be no more than 500 feet beyond the limits of each PV and CHP system location.


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Uptown Division Architectural Resources. Development of the Augusta VAMC Uptown Division began in 1912-1913 with the construction of Buildings 18, 19, and 20 as a Catholic school and convent. These buildings later served as a hotel (Lenwood Hotel), briefly as Officers’ Quarters for nearby Camp Hancock, and finally as a Veterans hospital after purchase by the government in 1921. The VA constructed Buildings 29, 30, 31, and 40 in the mid-1920s and Buildings 32, 33, 65, and 66 in the 1930s. Building 76 was added in 1945 and Building 95 in 1954. Building 110 was construct-ed in 1991; this consolidated the functions of the campus and drew away activity from surround-ing historic buildings. As a result of consultation with the Georgia SHPO in 1991, the VA identified 15 potentially his-toric buildings on the campus. In preparation for the construction of the Fisher House in 2009, New South Associates re-evaluated these buildings. This re-evaluation determined that there were 11 contributing resources to an NRHP-eligible historic district and one individually eligible building on site. The 11 contributing resources included the Quarters buildings and garages (Buildings 29, 30, 31, 32, 33, 40, 65, and 66) and Buildings 18, 19, and 20. The individually eli-gible building was Building 76. Buildings 7, 14, and 95 were re-evaluated as ineligible for the NRHP based upon poor integrity. Since the 2009 re-evaluation by New South Associates, contributing Buildings 29, 30, 31, 32, 33, 40, 65, and 66 were all torn down to build the Fisher House. There are now only four NRHP-eligible buildings remaining on campus. Remaining contributing buildings to the historic district include Buildings 18, 19, 20, and 76 (New South Associates 2009). Archeological Resources. Archeological investigations for the Uptown Division included a sur-vey performed by New South Associates in 2009. This report found one 20th century site (9RI1126) which consisted of sparse scatter of artifacts including glass, iron, and construction related fragments as well as coal and cinders. The artifacts were consistent with known Quar-ters from circa 1910 onsite. The area was determined to be not eligible for the NRHP and no further work was recommended. No other archeological sites have been identified onsite (New South Associates 2009).

Downtown Division Architectural Resources. The Downtown Division is located in a dense urban area. There are no buildings or structures over 50 years of age within the project APE. The Main Hospital Building (801) and the existing Energy Plant Building (802) were both constructed in the 1980s. There are no buildings or structures within the APE of the Downtown Division listed in or eligible for either the NRHP or the Georgia historic register. Archeological Resources. There are no known archeological sites present in the vicinity of the Downtown Division. The Downtown Division is located in an urban area adjacent to modern construction with prior ground disturbance from construction activities.

3.4.2 Impacts of Proposed Action In accordance with the Advisory Council on Historic Preservation’s regulations implementing Section 106 (36 CFR Part 800, Protection of Historic Properties), impacts to historic structures, cultural landscapes, and archeological resources were identified and evaluated by: (1) determin-ing the APE; (2) identifying cultural resources present in the APE that are either listed in or eligi-ble to be listed in the NRHP; (3) applying the criteria of adverse effect to affected cultural


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resources either listed in or eligible to be listed in the NRHP; and (4) considering ways to avoid, minimize, or mitigate adverse effects. Under the Advisory Council’s regulations, a determination of either adverse effect or no adverse effect must be made for affected NRHP-eligible cultural resources. An adverse effect occurs whenever an impact alters, directly or indirectly, any characteristic of a cultural resource that qualifies it for inclusion in the NRHP (e.g., diminishing the integrity of the resource’s location, design, setting, materials, workmanship, feeling, or association). Adverse effects also include reasonably foreseeable effects caused by the Proposed Action that would occur later in time, be farther removed in distance, or be cumulative (36 CFR 800.5, Assessment of Adverse Effects). A determination of no adverse effect means there is an effect, but the effect would not diminish in any way the characteristics of the cultural resource that qualify it for inclusion in the NRHP. Uptown Division. Buildings 95 and 110 at the Uptown campus have flat roofs with parapets such that the proposed systems would not be readily visible from ground level. These buildings are non-contributing resources to the historic district; thus, no adverse effects to cultural resources are expected to occur as a result of implementation of the Proposed Action. Downtown Division. There are no buildings or structures within the APE at the Downtown cam-pus that are eligible or listed on the NRHP. The Proposed Action would involve ground disturb-ance in an urban area adjacent to modern construction and would not impact any archeological resources. Consultation with the SHPO has been initiated to obtain input regarding potential impacts to the historic district at the Uptown Campus. However, no direct or indirect adverse impacts to cultural resources are expected under the Proposed Action. The Proposed Action is not anticipated to introduce significant visual impacts to surrounding properties. Therefore, it is anticipated that the Proposed Action would result in a finding of No Adverse Effect to historic properties to the Up-town Division and No Historic Properties Affected to the Downtown Division.

3.5 AESTHETICS/VISUAL RESOURCES

3.5.1 Existing Environment The Charlie Norwood VAMC Uptown and Downtown Divisions are campuses of buildings and parking lots located in a developed area of Augusta, Georgia. The grounds are maintained in a manner appropriate to the purpose of the facilities. Visually, the people of Augusta are accus-tomed to the appearance of the buildings in the area. At the Uptown Division, the existing view from the homes of nearby residents is of a modern medical facility. The southern boundary of the VAMC is shielded by fencing and landscaping, while the eastern border is partially shielded by landscaping. The facility is equipped with light-ing throughout the parking areas, pedestrian walkways, and access points. The Downtown Division is located in a medical and industrial area, so residential views of the campus are shielded by other buildings. The facility is equipped with lighting throughout the parking areas, pedestrian walkways, and access points.

3.5.2 Impacts of Proposed Action During boiler replacement and construction and installation of the PV arrays, microturbines, and noise-attenuating wall surrounding the microturbines, the visual and aesthetic characteristics of


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areas undergoing development would be temporarily altered by the use of construction equip-ment and the delivery and stockpiling of construction materials. Following completion of con-struction/installation, the PV systems and wall surrounding the microturbines would remain as visual features within the viewshed; however, the principal visual features of the facilities would remain consistent with existing conditions. Buildings 95 and 110 at the Uptown campus have flat roofs with parapets such that the pro-posed systems would not be readily visible from ground level. Since the microturbines would be installed within an existing lot immediately adjacent to an existing building, the change in the visual character of the Downtown Campus is anticipated to be negligible. Overall effects to visu-al resources as a result of implementation of the Proposed Action would be adverse, negligible, and long term.

3.6 NOISE Noise is defined as any sound that is undesirable because it interferes with communication, is intense enough to damage hearing, or is otherwise intrusive. Human response to noise varies depending on the type and characteristics of the noise, the distance between the noise source and the receptor, receptor sensitivity, and time of day.

3.6.1 Existing Environment Sound varies by both intensity and frequency. Sound pressure level, described in decibels (dB), is used to quantify sound intensity. The dB is a logarithmic unit that expresses the ratio of a sound pressure level to a standard reference level. Hertz are used to quantify sound frequency. The human ear responds differently to different frequencies. A-weighing, described in A-weighted decibels (dBA), approximates this frequency response to express accurately the per-ception of sound by humans. Sounds encountered in daily life and their approximate levels in dBA are provided in Table 3-4.

Table 3-4. Sound Level and Loudness of Typical Noises Noise Level

(dBA) Subjective Impression Typical Sources

140 Threshold of pain 125 Uncomfortably Loud Automobile assembly line 120 Uncomfortably Loud Jet aircraft 100 Very Loud Diesel truck 80 Moderately Loud Motor bus 60 Moderate Low conversation 40 Quiet Quiet room 20 Very Quiet Leaves rustling 0-10 Threshold of human hearing

Source: Liu and Liptak, 1997.

The dBA noise metric describes steady noise levels. Very few noises are, in fact, constant, so a noise metric, the day-night sound level (DNL), has been developed. DNL is defined as the aver-age sound energy in a 24-hour period with a 10-dB penalty added to nighttime levels (i.e., 10 p.m. to 7 a.m.). DNL is a useful descriptor for noise because it averages ongoing yet intermittent noise, and it measures total sound energy over a 24-hour period. In addition, equivalent sound


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level (Leq) is often used to describe the overall noise environment. Leq is the average sound level in dB. The Noise Control Act of 1972 (Public Law 92-574) directs federal agencies to comply with ap-plicable federal, state, interstate, and local noise control regulations. In 1974, the USEPA pro-vided information suggesting that continuous and long-term noise levels in excess of DNL 65 dBA are normally unacceptable for noise-sensitive land uses such as residences, schools, churches, and hospitals. The Augusta-Richmond County Code maintains a noise ordinance that regulates construction noise. According to Section 3-6-2 of Chapter 6 of the County Code, the noise restrictions are only applicable between 10:00 p.m. and 7:00 a.m. In addition, the facility must comply with Oc-cupational Safety and Health Administration (OSHA) regulations that require noise levels to be no greater than 85 dBA for an 8-hour day for worker safety (OSHA 2019). This requirement is also reflected in Section 23.05.51 of the VA Master Construction Specifications, which requires noise levels for all pumps, fans, compressors, motors, and steam turbines in boiler plants not to exceed 85 dBA at 3 feet from the source during operations. If sound levels exceed require-ments, the equipment must be modified to achieve the required sound levels (VA 2010). Table 3-5 shows typical sound levels associated with residential communities.

Table 3-5. Typical L90 Sound Levels in Residential Communities

Description Typical Range,

dBA Average,

dBA Very Quiet Rural or Remote Area 26 to 30 28 Very Quiet Suburban or Rural Area 31 to 35 33 Quiet Suburban Residential 36 to 40 38 Normal Suburban Residential 41 to 45 43 Urban Residential 46 to 50 48 Noisy Urban Residential 51 to 55 53 Very Noisy Urban Residential 56 to 60 58

Source: USEPA 1974.

Note: L90 is the level exceeded for 90 percent of the time. For 90 percent of the time, existing noise levels are above this level. It is generally considered to represent the background or am-bient level of a noise environment Uptown Division. The VACM Uptown campus has a noise environment typical of urban residen-tial communities (48 dBA). Noise levels are attributed to local road traffic, high altitude aircraft over- flights, periodic construction activities, and natural noises. The closest offsite sensitive re-ceptors to the Proposed Action at the Uptown campus are homes located along Maryland Av-enue situated approximately 60 feet from Building 95. Due to the operational nature of the Charlie Norwood VAMC, sensitive noise receptors (patients) are present within and throughout the facility itself. Downtown Division. Existing offsite noise levels at the Downtown location are typical of very noisy urban residential communities (58 dBA average). Noise levels are attributed to local road traffic, high altitude aircraft over-flights, periodic construction activities, and natural noises. The Downtown Division has a louder noise environment than the Uptown Division due to its location


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in a more developed and urban setting. Aside from the main hospital, the closest offsite noise sensitive receptor to the Downtown CHP site is a residence approximately 2,000 feet south of the proposed CHP system. Due to the operational nature of the Charlie Norwood VAMC, sensi-tive noise receptors (patients) occur within and throughout the facility itself. The main hospital building at the Downtown location is only approximately 130 feet from the proposed CHP system, but the adjacent area currently serves as a loading dock for the main hospital. Typical noise levels for indoor hospital areas are 45 dBA on average (USEPA 1974). Due to daily operations (i.e., existing boiler and chiller equipment, ventilation systems, truck de-liveries, etc.) at the facility, local noise levels at the CHP project site likely reach levels of a very noisy urban residential (58 dBA average).

3.6.2 Impacts of Proposed Action Minor to moderate effects on the noise environment would be expected from implementing the Proposed Action. Noise levels at the Charlie Norwood VAMC, however, would not exceed am-bient noise level standards as determined by the federal, state, and/or local government. Short-term, moderate increases in noise would be primarily from using heavy equipment during con-struction, which is temporary. Long-term noise impacts from CHP system operations would be negligible to minor and adverse. General construction noise would result from the use of heavy equipment. The maximum aver-age noise levels generated by the construction activities would typically range from 78 to 89 dBA at a distance of 50 feet (Table 3-6). Construction would take place during normal business hours, except for work aspects (i.e., roadwork) that could potentially interfere with the patient care. Although unlikely, such work could be scheduled during off-hours and/or on weekends, as required.

Table 3-6. Noise Levels Associated with Outdoor Construction

Construction phase dBA Leq at 50 feet

from source Ground Clearing 84 Excavation, Grading 89 Foundations 78 Structural 85 Finishing 89

Sources: USEPA 1974; Bolt, Beranek, and Newman 1971.

With multiple items of equipment operating concurrently, noise levels could be relatively high during daytime periods at locations within several hundred feet of active construction sites. Noise from a point source (i.e., construction equipment) generally decreases 6 dBA per dou-bling of distance. Uptown Division. Construction of the PV arrays would most likely utilize standard equipment such as cranes. It is unlikely that heavy earthmoving equipment would be used for a rooftop PV installation. At the Uptown campus, the nearest offsite sensitive receptors to the proposed PV sites are the residential homes located along the perimeter of the property. If the VA installs the rooftop PV array on Building 95, the nearest residents could potentially experience noise levels of approximately 59 to 69 dBA during construction, depending on whether windows are open or


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closed. Construction of the PV array on Building 110 would result in lower impacts to the offsite residences. These impacts would be temporary and last only during the construction period. There would be no noise impacts generated from operation of the PV systems. The sound level from an unenclosed Cleaver Brooks CBEX Elite steam boiler in peak operating mode is 84 dBA (CB 2019). Noise levels for combinations of sounds are added based on a log-arithmic scale (HUD 2009) and since three new boilers are proposed, the combined noise levels could reach approximately 88.8 dBA. The boilers would also be installed within Building 81, which is assumed to have a 12-inch concrete masonry unit wall, similar to other walls onsite that are housing utility equipment. This building enclosure would result in a further reduction of ap-proximately 45 dBA outside the building. Estimated noise levels outside of the enclosure due to boiler operations would approach approximately 43.8 dBA, which is below the urban residential environment surrounding Charlie Norwood VAMC, Uptown Division (48 dBA). Likewise, noise levels from the new boilers experienced by the closest sensitive receptors at the main hospital building and offsite residential dwellings would be well below the ambient sound levels of the surrounding urban environment. Since the new boilers are replacing three existing boilers that are oversized and less efficient, it is also likely that the sound levels from the new boilers are the same as, or more likely less than, sound levels produced by the existing boilers. Downtown Division. Construction of the proposed CHP system would utilize standard equipment such as tractors, backhoes, cranes, and in some cases, trenchers, but would also require addi-tional equipment for foundations and structural construction. At the Downtown campus, which is in a very noisy urban residential environment, the closest offsite residential receptors to the pro-posed CHP system enclosure are located approximately 2,000 feet away. Noise from the pro-posed system would be heavily attenuated by existing structures, such that noise impacts during construction are anticipated to be negligible to minor. Outdoor noise levels at the closest onsite sensitive receptor (i.e., the main hospital building, 130 feet from the source) due to CHP system construction at the Downtown campus would range from approximately 72 dBA to 83 dBA. Additionally, standard building construction (i.e, the main hospital building where receptors may be located) typically provides about 15 dBA of noise re-duction between exterior and interior noise levels with the windows partially open, and as much as 24 dBA with windows closed (USEPA 1978). As a result, interior noise levels for the nearby hospital building would reduce to approximately 57 dBA to 68 dBA with windows partially open, or 48 dBA to 59 dBA if the windows are closed. Although construction-related noise would have an adverse impact on nearby sensitive recep-tors, the effects would be temporary in nature and would end upon completion of construction. To the extent practicable, construction noise impacts would be reduced by avoiding times of day or days of the week when noise exposures would be objectionable (i.e., nights or weekend mornings) Construction equipment would include noise control features such as exhaust muf-flers and engine enclosure panels. It is not expected, therefore, that construction noise would violate state and local noise ordinances. Noise effects on construction personnel would be lim-ited by ensuring all personnel wear adequate personal hearing protection to limit exposure and ensure compliance with federal health and safety regulations, such as OSHA regulations. Given the temporary nature of construction, and the distance to the nearest sensitive offsite receptors, construction noise would have a minor to moderate, short-term adverse impact. Implementation of BMPs would reduce short-term noise effects to patients and staff within the facility.


3-16 May 2019

The sound level from an unenclosed Capstone C600 or C800 microturbine operating at full power is 65 dBA at 33 feet (Capstone 2019a and 2019b). Noise levels for combinations of sounds are added based on a logarithmic scale (HUD 2009) and since both a C600 and C800 microturbine are proposed, the combined noise levels could reach approximately 68 dBA at 33 feet. The microturbines would also be installed within an acoustical enclosure consisting of a 12-inch concrete masonry unit wall, which would result in a further reduction of approximately 45 dBA outside the building. Estimated noise levels outside of the enclosure due to microturbine operations would approach approximately 23 dBA, which is well below the very noisy urban res-idential environment surrounding Charlie Norwood VAMC Downtown Division. Likewise, noise levels from the microturbines experienced by the closest sensitive receptors at the main hospital building would be well below the ambient sound levels of the surrounding urban environment. Overall, noise from the microturbines would be inaudible on the outside of the CHP system en-closure. Long-term noise levels to sensitive receptors from the Proposed Action would be simi-lar to, and likely better than existing conditions. The noise generated by the CHP system would generally be nearly inconsequential compared to other existing noise sources, resulting in a negligible to minor change to the local noise environment. As described above, the VA would implement routine BMPs to minimize noise effects during construction, including:

• To the extent practicable, construction noise impacts would be reduced by avoiding times of day or days of the week when noise exposures would be objectionable (i.e., nights or weekend mornings).

• Construction equipment would include noise control features such as exhaust mufflers and engine enclosure panels.

• Mitigation of operational noise would be provided by sound attenuation from the acoustic enclosure.

The use of heavy equipment such as cranes to install rooftop PVs on Building 95 could result in a louder noise environment than assessed if the equipment accesses the rooftop from the Mary-land Avenue side of the building, as the equipment would then be closer than the assessed 60 feet. The rooftop should instead be accessed from the other side of the building where the build-ing itself would then attenuate noise levels. As no other significant adverse noise effects would be anticipated with implementation of the Proposed Action, no project-specific mitigation measures would be required.

3.7 UTILITIES

3.7.1 Existing Environment Georgia Power Company provides electricity to both the Uptown and Downtown campuses of the Charlie Norwood VAMC. Georgia Power Company uses 18 plants to provide electricity to over 2.4 million customers across the state of Georgia (GA Power 2019). Natural gas is sup-plied via the Atlanta Gas Light Company distribution system (Dynamic Energy Concepts 2010). Uptown Division. In FY 2016, the Uptown Division consumed approximately 13.3 million kWh of electricity and 45.3 million cubic feet of natural gas. The facility’s highest monthly electrical de-mand was 1.4 million kWh in July. Natural gas is used in the facility’s steam boilers. The Uptown Division’s central boiler plant has three natural gas-fueled fire tube boilers, manufactured by Nebraska Boilers. The boilers were installed in the 1980’s and are each rated at 20,000 pounds


3-17 May 2019

per hour capacity. Current annual natural gas consumption for the three existing boilers is 48,211 million British thermal units (MMBtu). The facility also has a few emergency diesel gen-erators serving critical loads. Downtown Division. In FY 2016, the Downtown Division consumed approximately 21.8 million kWh of electricity and 57.7 million cubic feet of natural gas. The facility’s highest monthly electri-cal demand was 2.38 million kWh in July. The Downtown Division contains three natural gas-fueled tube boilers manufactured by Superior Boilers. The boilers were installed in the 1980s and are each rated at 20,000 pounds per hour capacity. The facility also has a few emergency diesel generators serving critical loads.

3.7.2 Impacts of Proposed Action Uptown Division. The Proposed Action would result in a long-term, minor beneficial impact on local utilities by decreasing the Charlie Norwood VAMC’s reliance on the existing electric grid and annual natural gas consumption. The proposed rooftop PV arrays on Building 110 would be designed for a capacity of approximately 735 kW and could generate approximately 1.029 mil-lion kWh of electricity annually. The proposed rooftop PV arrays on Building 95 would be de-signed for a collective system capacity of 159.8 kW and could generate about 224,500 kWh of electricity annually (Ameresco 2018b). Use of solar PV arrays to generate electricity would rep-resent a long-term beneficial impact on local utility infrastructure and would reduce the Charlie Norwood VAMC's demand on Georgia Power. The proposed construction and operation of PV systems at the Charlie Norwood VAMC would not alter its current use. No increase in demand on any utility would result from the installation of the PV systems. No changes in water usage or natural gas supply are anticipated with the in-stallation and operation of the PV systems. The three high-efficiency replacement boilers would save an estimated 1,207,515 kWh in elec-tricity usage and an estimated 1,802 MMBtu annually (Ameresco 2019a). Use of replacement boilers to generate steam would represent a long-term beneficial impact on local utility infra-structure and would reduce the Charlie Norwood VAMC's demand on both Georgia Power and Atlanta Gas Light Company. More modest, but net positive, reductions in impacts to utility demand would result from the im-plementation of other proposed ECMs for installation of BAS/EMCS, installation of LED lighting throughout the facility, replacement of transformers throughout Buildings 110 and 111, and re-placement of high-flow water fixtures with high performance, low-flow fixtures (Ameresco, 2019a). The Proposed Action would not cause substantial population growth in the city of Augusta or increase utility demands; therefore, the Proposed Action would have a net positive impact on the electric demand of the city and on Georgia. Downtown Division. At the Downtown Division, the proposed CHP system could produce up to 3 MW of electricity at peak usage and would be able to meet the steam needs of the campus. The operation of the CHP system would dramatically decrease the electrical demand at the Down-town Division, with the potential to reduce peak loads by 81 percent. The CHP system would become the primary source for base energy for the facility and cover base electric demands to approximately 3 MW. The Downtown Division does not expect to have significant increases in


3-18 May 2019

future electric loads beyond current levels. Additionally, since the CHP system is designed to cover base energy, it is not anticipated to produce a significant amount of excess energy. Any potential excess energy produced by the CHP is not expected to be back-fed into the grid un-less design development results in discussion and agreement with the local utility. However, operation of the CHP system would use up to an additional 256 million cubic feet, or 256,000 MMBtu per year of natural gas. This increase would be partially offset from retrofitting and taking the existing steam boilers offline. Even with this increase in natural gas consumption, implementing the CHP technology at the Downtown Division would result in a long-term reduc-tion in electricity used by the facility. This would reduce demand for electricity within the region. As such, positive, long-term effects to utility systems are anticipated. During construction of the CHP system, a short-term (8 hours or less) power outage could occur at the Downtown Division. In that event, the facility would coordinate and schedule this outage with the utility provides and onsite operations to avoid conflicts. The Proposed Action would not cause substantial population growth in the city of Augusta or otherwise increase utility demands as a result; therefore, the Proposed Action would have a net positive impact on the electric demand of the city and on Georgia. No mitigation measures are required. As described above, the VA would carefully coordinate and conduct construction to avoid or relocate existing utilities, and to minimize operational ef-fects during construction.

3.8 WASTE MANAGEMENT

3.8.1 Existing Environment The GAEPD administers Georgia's hazardous and solid waste programs and enforces the haz-ardous and non-hazardous waste management rules. Hazardous waste activities and solid waste management activities must comply with regulations found in Title 12, Chapter 8 of the Official Code of Georgia Annotated, as well as all applicable federal regulations under 40 CFR 260-268, 273, and 279, and 29 CFR 1910. Underground storage tanks (USTs) are regulated by the GAEPD UST Management Program and 40 CFR 280.20. The UST Management Program is responsible for ensuring operational compliance and cleanup of leaks from registered UST sys-tems. The Charlie Norwood VAMC is located within USEPA Region 4. Hazardous waste at the Charlie Norwood VAMC is managed in satellite accumulation areas across the campuses and stored at the designated hazardous waste storage area. Solid and hazardous waste generated at the Charlie Norwood VAMC may include waste paints, aerosol cleaners, used oil, waste fuel, spent solvents, mercury containing lamps, food wastes, and gen-eral refuse. Regulated medical wastes (biohazardous wastes) and universal wastes are also generated at the facility. The GAEPD also regulates the abatement and removal of asbestos-containing materials (ACM). Federal regulations regarding ACM are managed by the USEPA via the National Emissions Standards for Hazardous Air Pollutants and by the Asbestos Hazard Emergency Response Act; workplace exposures are regulated under Occupational Safety and Health Administration (OSHA) regulations.


3-19 May 2019

Uptown Division. The Uptown Division operates as a conditionally exempt small quantity gener-ator of hazardous waste. Conditionally exempt small quantity generators generate 100 kilo-grams or less per month of hazardous waste, or 1 kilogram or less per month of acutely hazardous waste. There are 17 registered USTs at the Uptown Division, four of which have been closed. None of the USTs are located within the proposed project footprint. Downtown Division. The Downtown Division operates as a small quantity generator of hazard-ous waste. A small quantity generator generates less than 2,200 pounds (approximately 275 gallons) of hazardous waste and/or less than 2.2 pounds (approximately one quart) of extremely hazardous waste each calendar month. There are five USTs located at the Downtown Division. None of the USTs are located within the proposed project footprint.

3.8.2 Impacts of Proposed Action The Proposed Action would potentially generate a short-term increase in the volume of con-struction debris (solid waste) during construction; however, the quantity of waste generated would be minimal and recycling of materials would be performed to the extent possible. At the Uptown and Downtown Divisions, the Proposed Action would result in short-term, minor adverse impacts due to the increased presence and use of construction-related hazardous and toxic materials and wastes. During construction, a small increase in construction vehicle traffic would increase the likelihood for release of vehicle operating fluids (e.g., oil, diesel, gasoline, antifreeze, etc.) and maintenance materials. Also, contaminated non-native fill material may also be encountered during minor excavation activities. Implementation of standard construction BMPs would serve to ensure this impact is further minimized. If any soil contamination is en-countered, the VA would notify the GAEPD and manage and dispose of the contaminated soil in accordance with applicable state regulations. Due to the age of the buildings onsite, the potential exists for ACM and lead-based paint to be encountered during construction, which would require proper management and disposal. Due to the possibility of encountering ACM, the suspect locations would be sampled, and any such waste would be disposed of properly. Uptown Division. During normal operations of the PV systems, no increase in solid waste is ex-pected. In the event of severe damage to any of the PV systems, a small amount of hazardous materials might be released to the environment. PV systems typically contain heavy metals such as Pb (solder), cadmium, and selenium. These materials are a part of any PV array, and are only present in small quantities. As the potential for contamination from these materials is minimal and would only occur during catastrophic events, this is considered an unlikely long-term, minor, adverse impact. During operation, the VA would conduct ongoing and regular maintenance of the PV systems. Following any catastrophic event, the VA would repair any damage to the PV systems and rapidly remediate any minor releases in accordance with feder-al, state, and local requirements. No batteries or generators are proposed for storage or contin-uation of PV system power. At the end of their useful life (estimated to be 20 to 25 years), the PV systems would be de-commissioned. The VA would recycle or dispose of the waste PV systems in compliance with all existing federal, state, and local regulations governing the characterization and disposal of waste; therefore, no significant adverse effects associated with the disposal of the PV systems are expected.


3-20 May 2019

Air emissions from operation of the boilers would be expected due to the combustion of natural gas, as discussed in Section 3.3. No other waste products would be generated. Downtown Division. Operation of the new CHP system at the Downtown Division would gener-ate limited amounts of waste. Natural gas and water entering the system would be converted to steam; air emissions from the unit would be the primary waste generated. Negligible quantities of waste (e.g., cleaners, oil, and grease) would be generated during equipment maintenance. These wastes would be managed in accordance with state and federal regulations. The VA would continue to conduct operations in accordance with all applicable local, state, and federal requirements concerning solid and hazardous waste. The Downtown facility is currently regulated as a small quantity generator; therefore, any haz-ardous waste generated would be managed through their established hazardous waste pro-gram. To avoid impacts to the small quantity generator status, existing facility policies regarding contractor management of solid and hazardous waste would be strictly enforced. Standard Green Environmental Management System requirements would be enforced, including main-taining a hazardous material inventory and material safety data sheets. Similarly, the operation of the CHP system may generate small amounts of non-hazardous waste from maintenance and cleaning of the system. The handling and storage of non-hazardous waste would be similar to current operations, such that the waste would be collected in containers for offsite disposal or for recycling. Operation of the proposed CHP system would include new, more efficient systems for energy and steam generation that would require less maintenance than the existing boiler systems. This would likely result in a decrease in the amount of wastes generated from operation and maintenance activities (i.e., less oil and lubricants, oily rags, etc.) and would be a long-term, beneficial effect.

3.9 ENVIRONMENTAL CONSEQUENCES OF NO ACTION ALTERNATIVE Under the No Action Alternative, current operations would continue at the Augusta VAMC Up-town and Downtown Divisions and energy needs would continue to be provided by the local utility companies. Taking no action would mean that the visual appearance of the site would not change, the provision of utilities would not change, and no additional wastes would be created or discarded. There would be no increased impacts to air quality or from noise given the ab-sence of new activities. There would be no potential impacts to cultural and historic resources. Under the No Action Alternative, the existing utility systems at the VAMC’s Uptown and Down-town campuses would continue to be fully utilized. The No Action Alternative would not satisfy the purpose and need for the Proposed Action. The VA would still need to seek ways to address specific laws and executive orders requiring federal agencies to reduce energy consumption and improve energy efficiency.

3.10 CUMULATIVE IMPACTS This section describes the impacts to the environment that may potentially occur because of the interactive (i.e. cumulative) effects of implementing the proposed action with other past, present, and reasonably foreseeable future actions. Cumulative impacts can result from individually mi-nor but collectively significant actions taking place over a period of time.


3-21 May 2019

The VA plans to replace the existing roof of the Main Hospital Building (Building 110) in late 2019/early 2020. Roof replacement would be completed prior to installation of the proposed so-lar PV arrays. Impacts associated with this project are anticipated to be localized; there should not be any interactive impacts with offsite activities. Estimated air emissions generated by the Proposed Action, namely installation of the CHP sys-tem, would be de minimis. Therefore, the Proposed Action would not contribute significantly to adverse cumulative effects to air quality. The Augusta VAMC Uptown and Downtown campuses are already a collection of buildings for different functions. The installation of renewable or efficient utility systems would not substan-tively alter the visual quality of either campus. Thus, the cumulative impact would be less than significant. The Proposed Action would introduce short- and long-term increases in the noise environment at the Downtown campus. The noise increase would have a minor cumulative effect. No large-scale projects or proposals have been identified that when combined with the Proposed Action would have greater than significant effects. The installation of additional solar panel systems and replacement of the existing boilers at the Uptown Division would help with utility demand at the campus and would change the utility sys-tem to cleaner, more efficient sources. The installation of the CHP system at the Downtown Di-vision would also provide a more efficient source of energy. However, these changes would only occur at the Augusta VAMC and would not substantially change offsite demands. Therefore, the cumulative impacts are less than significant. The wastes generated by installation of the solar PV arrays, replacement of existing boilers, and installation of the CHP system would be similar to the types of wastes currently generated at the facilities. They would not cause the need for new permits or contracts. Construction contractors would be responsible for disposal of all construction wastes. All wastes would be handled ac-cording to applicable regulations that protect health and the environment. Therefore, the cumu-lative impacts from waste management would be negligible.


4-1 March 2019

PERSONS AND AGENCIES CONTACTED 4.0Program staff from the VA organizations were contacted and consulted to obtain data and in-formation in the preparation of this EA. The following people and organizations were contacted: [To be completed upon decision regarding consultation.]


5-1 May 2019

REFERENCES 5.0(Ameresco, 2018a). Ameresco, Inc. 2018. Project drawings for Building 110 Solar Array. De-cember 17, 2018. (Ameresco, 2018b). Ameresco, Inc. 2018. Project drawings for Building 95 Solar Array. Decem-ber 17, 2018. (Ameresco, 2019a). Ameresco, Inc. 2019. Investment Grade Audit 95% Report – Augusta Up-town – Charlie Norwood VA Medical Center, GA. March 15, 2019. (Ameresco, 2019b). Ameresco, Inc. 2019. Investment Grade Audit 95% Report – Augusta Downtown – Charlie Norwood VA Medical Center, GA. March 15, 2019. (Capstone 2019a). Capstone. 2019. C600 600kW Power Package High- pressure Natural Gas datasheet. Accessed March 21, 2019 at https://www.adigo.no/wordpress/wp-content/uploads/2015/02/C600-High-NatGas_331050D_lowres.pdf. (Capstone, 2019b). Capstone. 2019. C800 800kW Power Package High- pressure Natural Gas datasheet. Accessed March 21, 2019 at https://www.adigo.no/wordpress/wp-content/uploads/2015/02/C800-High-NatGas_331053D_lowres.pdf. (CB, 2019). Cleaver Brooks. 2019) Model CBEX Elite 100-800 HP datasheet accessed March 25, 2019 at http://cleaverbrooks.com/products-and-solutions/boilers/firetube/cbex-elite/Boiler%20Book%20CBEX%20Elite%20100-800.pdf. (GADNR, 2013). Georgia Department of Natural Resources. 2013. Ambient Monitoring Pro-gram. https://epd.georgia.gov/air/ambient-monitoring-program. (GA Power, 2019). Georgia Power. 2019. Delivering Energy. Accessed March 20, 2019 at http://www.georgiapower.com/about-energy/delivering-energy/. (HUD, 2009). U.S. Housing and Urban Development (HUD). 1985. The Noise Guidebook, a Reference Document for Implementing the Department of Housing and Urban Development’s Noise Policy. HUD‐953‐ CPD. March 1985. Accessed March 20, 2019 at https://www.hudexchange.info/resource/313/hud-noise-guidebook/ (IDcide, 2019). IDcide. 2019. Augusta, GA Weather. https://www.idcide.com/weather/ga/augusta.htm. (OSHA, 2019). Occupational Safety and Health Administration (OSHA). 2019. Noise and Hearing Conservation. Accessed March 20, 2019 at https://www.osha.gov/SLTC/noisehearingconservation/hearingprograms.html. (New South Associates, 2009). New South Associates. 2009. Cultural Resources Survey and Assessment, Charlie Norwood VA Medical Center, Augusta Uptown Campus. Stone Mountain Georgia, August 6, 2009.

https://www.adigo.no/wordpress/wp-content/uploads/2015/02/C600-High-NatGas_331050D_lowres.pdf




http://cleaverbrooks.com/products-and-solutions/boilers/firetube/cbex-elite/Boiler%20Book%20CBEX%20Elite%20100-800.pdf

http://cleaverbrooks.com/products-and-solutions/boilers/firetube/cbex-elite/Boiler%20Book%20CBEX%20Elite%20100-800.pdf

https://epd.georgia.gov/air/ambient-monitoring-program

http://www.georgiapower.com/about-energy/delivering-energy/

https://www.hudexchange.info/resource/313/hud-noise-guidebook/

https://www.idcide.com/weather/ga/augusta.htm

https://www.osha.gov/SLTC/noisehearingconservation/hearingprograms.html


5-2 May 2019

(USEPA, 1974). U.S. Environmental Protection Agency. 1974. Information on Levels of Envi-ronmental Noise Requisite to Protect Public Health and Welfare with an Adequate Margin on Safety. Publication 550/9-74-004. March 1974. (USEPA, 1978). U.S. Environmental Protection Agency. 1978. Protective Noise Levels. EPA 550/9-79-100. November 1978. (USEPA, 2007). Environmental Protection Agency. 2007. Inventory of US Greenhouse Gas Emissions and Sinks: 1990–2005. EPA 430-R-07-002. (USEPA, 2019a). U.S. Environmental Protection Agency. 2019. Georgia Nonattain-ment/Maintenance Status for Each County by Year for All Criteria Pollutants. https://www3.epa.gov/airquality/greenbook/anayo_ga.html. (USEPA 2019b). Environmental Protection Agency. 2019. Greenhouse Gas Equivalence Calcu-lator. https://www.epa.gov/energy/greenhouse-gas-equivalencies-calculator. (VA, 2010). U.S. Department of Veterans Affairs. 2010. NEPA Interim Guidance for Projects. PG-18-17 (rev.) Accessed on March 20, 2019 at http://www.cfm.va.gov/til/etc/NEPAGuidance.pdf.

https://www3.epa.gov/airquality/greenbook/anayo_ga.html

https://www.epa.gov/energy/greenhouse-gas-equivalencies-calculator

http://www.cfm.va.gov/til/etc/NEPAGuidance.pdf


6-1 May 2019

GLOSSARY 6.0Affected Environment – The existing physical, cultural or socioeconomic environment to be affected by a proposed action and alternatives. Alternative – A reasonable way to fix the identified problem or satisfy the stated need (40 CFR 1500.2). Ambient Air – Any unconfined portion of the atmosphere; open or surrounding air. Attainment Area – An area designated to have air quality as good as or better than the NAAQS as defined in the Clean Air Act. An area may be an attainment area for one pollutant and a non-attainment area for others. Best Management Practices – Methods that have been determined to be the most effective, practical means of preventing or reducing pollution from nonpoint sources. They also help pre-vent or mitigate other safety and environmental issues. Clean Air Act – Legislation enacted to monitor and control air pollution therefore improving air quality. Coastal Zone – The area where land and ocean meets that commonly extends to the water-sheds that drain to the ocean; this zone is protected by Coastal Management Zone Manage-ment Act. Combined Heat and Power (CHP) – A type of technology that produces electricity and heat (also known as cogeneration) in a single, integrated system. It converts as much as 90% of the fuel into usable energy. Criteria Pollutants – Six primary air pollutants found throughout the United States as defined by U.S. Environmental Protection Agency pursuant to the Clean Air Act. They include particu-lates, ground-level ozone, carbon monoxide, sulfur oxides, nitrogen oxides, and lead. Cultural Resources – An aspect of a cultural system that is valued by or significantly repre-sentative of a culture or that contains significant information about a culture. Types of cultural resources include: historic properties as defined in the National Historic Preservation Act; cul-tural items as defined in the Native American Graves Protection and Repatriation Act; archeo-logical resources as defined in the Archeological Resources Protection Act; sacred sites as defined in Executive Order 13007, Protection and Accommodation of Access To "Indian Sacred Sites," to which access is provided under the American Indian Religious Freedom Act; and col-lections. Cumulative Impacts (or Effects) – Impacts on the environment that result from the incremental impact of the action when added to other past, present, and reasonably foreseeable future ac-tions, regardless of which agency (federal or non-federal) or person undertakes such other ac-tions. Effects resulting from individually minor, but collectively significant, actions taking place over a period of time. Direct Effects – Impacts that are caused by and coincide in time and place with the action.


6-2 May 2019

Endangered Species – A species that is threatened with extinction throughout all or a signifi-cant portion of its range. Environmental Assessment (EA) – A concise public document, prepared in compliance with the National Environmental Policy Act, that briefly discusses the purpose and need for an ac-tion, alternatives to such action, and provides sufficient evidence and analysis of impacts to de-termine whether to prepare an environmental impact statement or finding of no significant impact (40 CFR 1508.9). Environmental Justice – The confluence of social and environmental movements, which deals with the inequitable environmental burden born by groups such as racial minorities, women, or residents of developing nations. Executive Order (EO) – An official proclamation issued by the President that may set forth poli-cy or direction or establish specific duties in connection with the execution of federal laws and programs. Floodplain – The lowlands and relatively flat areas adjoining inland waters, including flood prone areas, which are inundated by a flood. Fugitive Dust – Particulate matter composed of soil, uncontaminated from pollutants, resulting from industrial activity. Fugitive dust may include emissions from haul roads, wind erosion of exposed soil surfaces, and other activities in which soil is either moved or redistributed. Greenhouse Gas – Greenhouse gases are the gases present in the earth's atmosphere that reduce the loss of heat into space and therefore contribute to global temperatures. Habitat – Suite of existing environmental conditions required by an organism for survival and reproduction. The place where an organism typically lives. Hazardous Waste/Materials – Waste substances that can pose a substantial or potential haz-ard to human health or the environment when improperly managed. Indirect Effects – Impacts that are caused by the action and are later in time but are still rea-sonably foreseeable. Indirect effects may include growth inducing effects and other effects re-lated to induced changes in the pattern of land use, population density or growth rate, and related effects on air and water and other natural systems including ecosystems. Kilowatt (kW) – 1 thousand watts. Megawatt (MW) – 1 million watts. Mobile Source – A non-fixed source of air pollution such as cars. National Ambient Air Quality Standards (NAAQS) – Standards established by the U.S. Envi-ronmental Protection Agency that apply for outdoor air throughout the country. Primary stand-ards are designed to protect human health, with an adequate margin of safety, including sensitive populations such as children, the elderly, and individuals suffering from respiratory disease. The NAAQS represent maximum air pollutant standards that the U.S. Environmental Protection Agency set under the Clean Air Act for attainment by each state.


6-3 May 2019

National Environmental Policy Act of 1969 (NEPA) – Requires all agencies, including the VA, to examine the environmental impacts of their actions, incorporate environmental information, and use public participation in the planning and implementation of all actions. Federal agencies must integrate NEPA with other planning requirements, and prepare appropriate NEPA docu-ments to facilitate better environmental decision making (40 CFR 1500). Nonattainment Areas – The Clean Air Act and Amendments of 1990 define a "nonattainment area" as a locality where air pollution levels persistently exceed national standards or that con-tributes to ambient air quality in a nearby area that fails to meet standards. Designating an area as nonattainment is a formal rulemaking process, and USEPA normally takes this action only after air quality standards have been exceeded for several consecutive years. Particulate Matter – Small particles in the air generally considered to be pollutants. These may include dust, dirt, soot, smoke, and liquid droplets. PM10 – Particulate matter less than 10 microns in diameter. PM2.5 – Particulate matter less than 2.5 microns in diameter. Renewable Energy – Energy from the environment that is replenished (renewed), such as wind, geothermal, and solar. Runoff – Non-infiltrating water entering a stream or other conveyance channel shortly after a rainfall. Soil Erosion – The removal and loss of soil by the action of water, ice, gravity, or wind. Species – All organisms of a given kind; a group of plants or animals that breed together but are not bred successfully with organisms outside their group. Stationary Source – A fixed source of air pollution, usually a factory or power plant. Stormwater – Water discharges generated by runoff from land and impervious areas such as paved streets, parking lots, and building rooftops during rainfall and snow events. Stormwater often contains pollutants in quantities that could adversely affect water quality. Volatile Organic Compounds – Compounds that become gas under normal conditions and react with other compounds generally in the atmosphere. Watt – A watt is a measure of power, or the rate at which work is done. One watt equals one joule (a unit of energy) per second. Another measure of power is horsepower, with 1 horsepow-er theoretically equal to 746 watts. Wetlands – Areas that are inundated or saturated with surface or groundwater at a frequency and duration sufficient to support a prevalence of vegetation typically adapted for life in saturat-ed soil, including swamps, marshes, bogs, and other similar areas.


7-1 May 2019

LIST OF PREPARERS 7.0This Environmental Assessment has been prepared by the Department of Veterans Affairs with contractual assistance from Solv, LLC. The following individuals were primarily responsible for preparing and reviewing the document:

Marissa Staples Project Manager; Cultural and Historic Resources; Aesthetics; Cumulative Impacts Years of Experience: 14

Dave Henney Noise; Utilities Years of Experience: 40

Oshin Paranjape Air Quality; GIS; Waste Management Years of Experience: 1

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