U.S. Treasury Headquarters in Washington D.C.

Photograph Attribution: By Sealy j - Own work, CC BY-SA 4.0,

https://commons.wikimedia.org/w/index.php?curid=62209528

U.S.Army Corps of Engineers (USACE)

Baltimore District Planning Division 2 Hopkins Plaza, 

10th Floor Baltimore, 

MD 21201 

Re: Bureau of Engraving and Printing (BEP) Project, Draft

Environmental Impact Statement (EIS) for Construction

and Operation of a Currency Production Facility at the

Beltsville Agricultural Research Center in Washington D.C.

To Whom It May Concern:

We hope you can accept our comments even though they are sent on December 22, 2020, one day past the comments due date. Covid-19 has placed burdens on our operations that make it difficult to provide well considered comments on a prompt schedule. Environmental Review, Inc. has reviewed the Environmental Impact Statement Draft (EIS), and has the following comments: 

Comments 

1. Section 1.4 of the EIS states that the new construction of a one million square foot with a height of 40 to 50 feet would support the U.S. Treasury’s long-term plan for efficient, streamlined currency production, however, the BEP has not provided an analysis of why the given space requirements were selected. Considering the Fort Worth plant (WCF) already accounts for more than 60 percent of the printing of U.S. notes, an analysis of space requirements for this facility should be conducted. This analysis should include the inventory of current plant space, the Main Building, the Annex, and the warehouse in Landover, and show how that can be accommodated in the new plant along with the space required for future needs. An analysis is important because underestimating or overestimating the plant size is an expensive error. In addition, overestimating the plant size will unnecessarily increase the environmental impact of construction and operations. 

2.  Section 3.1.3. There is no discussion of the extent of fuel storage on site and whether an SPCC Plan may be required for the Preferred Alternative as required under the Federal Oil Pollution Act. 

3.  Section 3.7.2.2 of the EIS, under the Wetlands section, claims that the Treasury has developed the concept site plan for the CPF (Currency Production Facility) in a manner that reduces potential adverse wetland impacts to the extent feasible. Table 2.2-1 discusses environmental impacts reduction procedures for water resources, however, fails to address how wetlands will be protected from fugitive dust emissions during construction of the proposed CPF. Lines 1477-78 states that fugitive dust emissions would be the most likely emissions source to travel off-site. Considering Wetland #4 and Wetland #6 areas are within project-site boundaries, it is highly likely fugitive dust emissions will contaminate these bodies of water. This poses a hazard as increased sedimentation would alter the nutrient makeup of water as well as threaten the biomass of these wetlands. Given the construction process will occur over a period of three years, what further environmental protection measures can be put in place to mitigate the amount of fugitive dust that will settle onto these wetlands during the construction phase? 

In addition, fugitive dust emissions also pose a potential hazardous risk to children. Lines 1562-64 state that the Vansville Recreation Center and Vansville Elementary School are located approximately 1,500 feet from the project site boundary, and the Touch of Eden Daycare as approximately 1,300 feet from the site boundary. The BARC (Beltsville Agricultural Research Center) location 27 experiences wind predominantly from the south/southwest region during the spring and summer which might potentiate the risks of dust emissions reaching these schools. Particulate matter 2.5 microns or less in size (PM 2.5) is considered dangerous as it can be absorbed by lung tissue. Due to this hazard, it is suggested that the BEP should add additional dust particle monitoring stations near the schools during the construction phase so that children’s and staff’s respiratory health are not at risk. The Phase II completed for this site identified heavy metals in the soil; albeit these appear to be at background levels. In addition, during demolition there is potential for air transport of lead, from lead based paint (LBP), and/or asbestos. However, there is a potential that, during the long construction period, these airborne metal particulates could be concentrated in wetlands and streams downwind via fugitive dust emissions. These may impact sensitive hydrophytic plants and aquatic species. In addition, the use history of this site as an agricultural research facility is a concern. There is a potential that underlying soils may include pesticide residue and other research-oriented contaminants which could be transported in particulates during excavation. 

4. Section 3.8.2.2 of the EIS, under the Wildlife section states that the construction of the Proposed Action would permanently remove approximately 83.6 acres of existing vegetated wildlife habitat within the project site boundaries. Lines 1938-39 states this vegetated wildlife habitat contains numerous bird nest boxes that provide habitat for cavity-nesting bird species such as the easter blue bird (Sialia sialis) and tree swallow (Tachycineta bicolor). Lines 2006-07 states that Treasury would coordinate with owners of the on-site bird nest boxes to have them relocated from the Project Site prior to construction but does not name any specific locations. What areas or regions will the on-site bird nests be relocated to? The relocation of nests should highly consider the noise levels of construction displayed in Figure 3.5-1 as birds may not settle within noisy areas, The decimal levels of noise pollution should be monitored and controlled.

5.  Table 2.2-1 of the EIS states construction should be limited or avoided altogether within the nesting season of migratory birds observed between May 1 to September 10. However, Section ES.8 states that excavation activities will be conducted during late summer or early fall to minimize potential encounters of groundwater resources. Since these two timelines are contradicting, how will excavation activities be limited to avoid disturbing migratory birds to the greatest extent possible? According to section 3.7.2.2, excavation activities could potentially reach a depth of approximately 25 feet below the ground surface the demolition of existing buildings and basements, and removal of underground utilities. These activities will likely involve use of loud construction vehicles and machinery which may cause large disturbances for the migratory birds. The only Endangered and Threatened species identified in the area is the Northern Long Eared Bat. These chiroptera mammals are very sensitive to loud noises also. 

When responses to these comments are available, please email those to

me at This email address is being protected from spambots. You need JavaScript enabled to view it.

Sincerely,

Kobe Ramirez (Associate in California) 

Environmental Reviewer

Environmental Review, Inc. 

1792 Rogers Avenue

San Jose, California 95112

(a 501(c)(3) Nonprofit Public Benefit Corporation)