DRAFT ENVIRONMENTAL ASSESSMENT Proposed

DRAFT ENVIRONMENTAL ASSESSMENT

Proposed Ambulatory Care Center

Nebraska-Western Iowa Health Care System Omaha Veterans Affairs Medical Center

December 2017

Prepared for: U.S. Department of Veterans Affairs Nebraska-Western Iowa Health Care System Omaha Veterans Affairs Medical Center 4101 Woolworth avenue, Omaha, NE 68105

Prepared by: Olsson Associates 2111 S. 67th Street, Suite 200 Omaha, NE 68106

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Proposed Ambulatory Care Center Environmental Assessment NWIHCS Omaha VAMC December 2017

Table of Contents

Executive Summary ...... 1 1.0 Introduction ...... 7 Background ...... 7 Purpose and Need ...... 11 Space Deficiencies ...... 11 Functional Deficiencies ...... 11 Technical Deficiencies ...... 12 2.0 ACC Alternatives ...... 14 Alternative 1 – No-Action Alternative ...... 14 Alternative 2 – New On-site ACC ...... 14 Alternative 3 – New Off-site ACC ...... 14 Alternative 4 – Third-Party Contracting ...... 14 ACC Alternatives Eliminated from Consideration...... 14 ACC Alternative Concepts Retained for Detailed Analysis ...... 15 No-Action Alternative ...... 15 Proposed Action Alternative ...... 15 3.0 Affected Environment and Environmental Consequences of the Alternatives ...... 23 Aesthetics ...... 23 Definition of the Resource ...... 23 Affected Environment ...... 23 Environmental Consequences ...... 23 Air Quality ...... 25 Definition of the Resource ...... 25 Affected Environment ...... 26 Environmental Consequences ...... 27 Cultural Resources ...... 27 Definition of the Resource ...... 27 Affected Environment ...... 28 Environmental Consequences ...... 29 Geology and Soils ...... 30 Definition of the Resource ...... 30 Affected Environment ...... 30

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Environmental Consequences ...... 34 Hydrology and Water Quality ...... 35 Definition of the Resource ...... 35 Affected Environment ...... 35 Environmental Consequences ...... 38 Wildlife, Habitat, and Threatened and Endangered Species ...... 38 Definition of the Resource ...... 38 Affected Environment ...... 39 Environmental Consequences ...... 41 Noise ...... 43 Definition of the Resource ...... 43 Affected Environment ...... 43 Environmental Consequences ...... 43 Land Use ...... 44 Definition of the Resource ...... 44 Affected Environment ...... 44 Environmental Consequences ...... 46 Floodplains and Wetlands ...... 46 Definition of the Resource ...... 46 Affected Environment ...... 47 Environmental Consequences ...... 47 Socioeconomic ...... 49 Definition of the Resource ...... 49 Affected Environment ...... 49 Environmental Consequences ...... 50 Transportation and Parking ...... 52 Definition of the Resource ...... 52 Affected Environment ...... 52 Environmental Consequences ...... 53 Solid and Hazardous Materials...... 59 Definition of the Resource ...... 59 Affected Environment ...... 59 Environmental Consequences ...... 60 Utilities ...... 61

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Definition of the Resource ...... 61 Affected Environment ...... 61 Environmental Consequences ...... 62 Environmental Justice ...... 67 Definition of the Resource ...... 67 Affected Environment ...... 67 Environmental Consequences ...... 68 Cumulative Impacts and Past, Present, and Reasonably Foreseeable Future Actions ...... 69 Past, Present, and Reasonably Foreseeable Future Actions ...... 70 Cumulative Impacts ...... 71 Secondary Impacts ...... 72 Conclusion ...... 72 Potential for Generating Substantial Controversy ...... 73 4.0 Public Involvement ...... 74 5.0 Mitigation ...... 75 6.0 Conclusion ...... 80 7.0 List of Preparers ...... 83 8.0 References...... 84

Tables Table ES-1. Environmental Consequences of the Proposed Action Summary...... 4 Table 3-1. National Ambient Air Quality Standards ...... 26 Table 3-2. AQI for Douglas County in 2017 ...... 26 Table 3-3. NHRP Listings in Douglas County, Nebraska Within One Mile of the Omaha VAMC...... 29 Table 3-4. Federally and State Listed Species in Douglas County ...... 40 Table 3-5. Race and Poverty Characteristics ...... 67 Table 3-6. Common Social Concerns Potentially Affected by the Proposed Action Alternative ...... 68 Table 3-7. Reasonably Foreseeable Future Transportation Projects Within Two Miles of the Omaha VAMC Campus ...... 71 Table 6-1. Environmental Consequences of the Proposed Action Summary...... 80

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Figures Figure 1-1. Omaha VAMC Location Map ...... 8 Figure 1-2. Omaha VAMC Site Map ...... 9 Figure 1-3. Current Facility Plot Plan of the Omaha VAMC Campus ...... 10 Figure 2-1. Proposed Ambulatory Care Center Site Plan ...... 19 Figure 2-2. Proposed Ambulatory Care Center Schematic Rendering ...... 20 Figure 2-3. Omaha VAMC Future Buildings ...... 21 Figure 3-1. USGS 2014 Long-Term Seismic Hazard Map...... 31 Figure 3-2. Ecoregions of Nebraska Showing the Omaha VAMC Location in Red (NGPC NHP 2017a)...... 32 Figure 3-3. Omaha VAMC Soils Map ...... 33 Figure 3-4. Water Resources Map ...... 37 Figure 3-5. Distribution of the Northern Long-eared Bat Within Nebraska (NGPC NHP 2015) ...... 41 Figure 3-6. Omaha VAMC Zoning Map ...... 45 Figure 3-7. Omaha VAMC Wetland Map ...... 48 Figure 3-8. Current OMetro Bus Routes ...... 55 Figure 3-9. Parking Areas Impacted Due to the Proposed Action...... 56 Figure 3-10. Proposed Future OMetro Route 3 Due to the Proposed Action ...... 57 Figure 3-11. Proposed Sanitary and Storm Sewer Improvements Due to the Proposed Action ...... 65 Figure 3-12. Proposed Water Supply Improvements Due to the Proposed Action ...... 66

Appendices Appendix A Agency Correspondence Appendix B EDR Report Appendix C Public Involvement Documentation

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List of Acronyms

ACC Ambulatory Care Center ACS American Community Survey ADA American with Disabilities Act APE Area of Potential Effect AQI Air Quality Index BDOC Bed Days of Care BMPs Best Management Practices CAA Clean Air Act CEQ Council on Environmental Quality CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations CHIP IN Communities Helping Invest through Property and Improvements Needed CSW Construction Storm Water CWA Clean Water Act dBA Decibels DGSF Departmental Gross Square Feet EA Environmental Assessment EDR Environmental Data Resources EO Executive Order EPA Environmental Protection Agency ESA Environmental Study Area FEMA Federal Emergency Management Agency HVAC Heating, Ventilation, and Air Conditioning IT information technology kW kilowatt LAST Aboveground Leaking Storage Tank LUST Leaking Underground Storage Tank M million MAPA Metropolitan Area Planning Agency MUD Metropolitan Utilities District NAAQS National Ambient Air Quality Standards NCA Noise Control Act NCSS National Cooperative Soil Survey NDEQ Nebraska Department of Environmental Quality NEPA National Environmental Policy Act NGPC Nebraska Game and Parks Commission Nebraska NHP Natural Heritage Program NOA Notice of Availability NOI Notice of Intent NPDES National Pollutant Discharge Elimination System NRCS Natural Resource Conservation Service NRHP National Register of Historic Places NWI National Wetlands Inventory NWIHCS Nebraska Western Iowa Health Care System

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OFD Omaha Fire Department OMetro Omaha Metro Bus System OPPD Omaha Public Power District OR(s) Operating Room(s) PACT Patient Aligned Care Team PCMH Patient Centered Medical Home Model PL Public Law ppb parts per billion ppm parts per million RCRA Resource Conservation and Recovery Act SCIP Strategic Capital Investment Plan SHPO State Historic Preservation Officer SSC Species of Special Concern SQG Small Quantity Generator SWDA Solid Waste Disposal Act SWPP Stormwater Pollution Prevention Plan THPO Tribal Historic Preservation Office UNMC University of Nebraska Medical Center USACE United States Army Corps of Engineers USC United States Code USDA United States Department of Agriculture USFWS United States Fish and Wildlife Service USGS United States Geological Survey UST(s) Underground Storage Tank(s) VA Department of Veterans Affairs VAMC Veterans Affairs Medical Center VCP Vitrified Clay Pipe WOTUS Waters of the United States µg/m3 micrograms per cubic meter

vi Proposed Ambulatory Care Center Environmental Assessment NWIHCS Omaha VAMC December 2017

Executive Summary

This Environmental Assessment (EA) evaluates the potential environmental effects that may result from the proposed construction of the Ambulatory Care Center (ACC) and related improvements (Proposed Action) at the Omaha Veterans Affairs Medical Center (VAMC) Specifically, the EA evaluates the significance of potential direct, indirect, and cumulative environmental impacts—both positive and negative—that the Proposed Action and alternatives may have on the environment, considering natural, social, and economic aspects. Moreover, the assessment ensures that the United States Department of Veterans Affairs (VA) considers the ensuing environmental consequences prior to deciding on whether to proceed with the Proposed Action or alternatives.

Background The Omaha VAMC is in Omaha, Douglas County, Nebraska. The Omaha VAMC is part of a regional network of VA facilities that make up the Nebraska-Western Iowa Health Care System (NWIHCS). The Omaha VAMC provides a wide array of core services including:

• Inpatient care, • general medical care, • inpatient and outpatient surgical care, • psychiatric care, • ambulatory care services, and • clinical research programs.

The Omaha VAMC campus dates to approximately 1950, when the hospital was designed and constructed as a 500-bed general medical facility. Most functions of the Omaha VAMC take place in the main hospital building, although ancillary structures have been constructed over time to provide for additional services. The main hospital building was not designed to fulfill the needs of a modern medical facility, and numerous space, functional, and technical deficiencies affect most departments. Future Omaha VAMC workload projections show a significant increase for nearly all services, including medical/surgical ambulatory care, rehabilitation medicine, surgical specialties, ambulatory mental health, laboratory and pathology service, and radiology service. The Proposed Action, to construct a new ACC, would provide a necessary component to improving patient care and satisfaction at the Omaha VAMC.

Purpose and Need The purpose of the project is to provide improved ambulatory care services to veterans in the VA NWIHCS service area.

• Lacks adequate space to meet projected future clinic stops and patient needs;

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• Does not allow for the integration of related health care services and staff due to the dated nature of the existing facilities, causing unintentional fragmentation of services and staff that does not align with the Patient Aligned Care Team (PACT) model aiming provide patient-centric care, using a foundation of primary care services linking patients with specialty services; and • Houses operating rooms (ORs) cited with infection control deficiencies related to space limitations that potentially compromise sterile conditions, will not accommodate modern equipment, or permit the required separation of clean and dirty corridors for equipment, patients, and staff.

The proposed project would promote patient care and safety, maintain Omaha VAMC facility cohesiveness, increase efficiency, and improve patient and staff satisfaction.

Alternatives Four alternative concepts were developed. These alternatives included:

1. No-Action Alternative, 2. New On-site ACC: Constructing a new Ambulatory Care Center (ACC) at the existing Omaha VAMC campus, 3. New Off-site ACC: Relocating Ambulatory Care services to an existing or new facility off- site of the Omaha VAMC campus, and 4. Third-Party Contracting: Providing Ambulatory Care services off-site of the Omaha VAMC via a non-Omaha VAMC contracted health care provider.

Alternatives 3 and 4 were eliminated from consideration as both concepts would not fit the PACT model, perpetuating the fragmentation of services and staff by isolating Ambulatory Care at the expense of the patient. Primary care services would become more isolated and disconnected from specialty clinics and services. To varying degrees, Alternatives 3 and 4 would also require duplication of some clinical support facilities (mechanical and technical), and administration and staff positions to effectively manage the new site.

Two concepts were carried forward for detailed analysis: Alternative 1 – No-Action Alternative; and Alternative 2 – New On-site ACC (Proposed Action). Inclusion of a No-Action Alternative is prescribed by the Council on Environmental Quality (CEQ) regulations and serves as a benchmark against which proposed Federal actions are evaluated.

Proposed Action The Proposed Action is based on retaining all the services at the Omaha VAMC and constructing a new ACC on site to replace the existing deficient facilities. The Proposed Action consists of constructing an approximately 160,000 square-foot building to support ambulatory surgery, PACT clinical care, lobby, police service, radiology, support, and reception spaces on the existing Omaha VAMC campus. The new facility would include all electrical, mechanical and structural

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space to support the building as well as a 3,000 square-foot connecting corridor to the main hospital building.

This new onsite ACC would be dedicated to ambulatory care, allowing for new primary care clinics to be designed and constructed to meet the needs of each PACT team, including providing appropriate women veterans health care space. This new building would also allow expansion of the ambulatory surgery portion of the ORs, with more complicated surgery procedures remaining at the medical center main hospital building. While the Proposed Action does not completely mitigate the current Omaha VAMC OR space needs with regards to infection control deficiencies, modern equipment requirements, and clean/dirty corridor separation for equipment, patients, and staff; it does ensure that ambulatory surgery procedures could be conducted in an infection-free environment.

Areas of the main hospital building vacated by Ambulatory Care services would allow for the expansion, reorganization, and/or consolidation of ORs and other Omaha VAMC services. This would alleviate congestion and fragmentation of services, contributing to improved patient care. Constructing the new ACC at the Omaha VAMC main campus would promote the seamless integration of Ambulatory Care with additional Omaha VAMC services, increasing patient satisfaction and improving the overall patient experience.

The Proposed Action would temporarily reduce available parking, with additional parking provided by planned future projects. Pedestrian facilities would be significantly upgraded and would be compliant with the Americans with Disabilities Act (ADA). The Proposed Action would also provide two options for patient loading and unloading by maintaining the primary entrance at the main hospital building and construction a new primary entrance at the new ACC.

The new ACC would be a state-of-the-art facility, constructed according to modern medical facility standards, and would include new mechanical, electrical, and information technology (IT) systems currently lacking in the main hospital building. The existing sewer system and water lines directly serving the new ACC would also be upgraded.

Affected Environmental and Environmental Consequences of the Proposed Action This EA discusses environmental considerations for the project, the contextual setting of the affected environment, impacts of the No-Build Alternative and the Proposed Action, and proposed mitigation. Table ES-1 summarizes the environmental consequences of the No-Action Alternative and the Proposed Action. As previously discussed, inclusion of the No-Action Alternative serves as a benchmark against which potential impacts of the Proposed Action are evaluated.

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Table ES-1 Environmental Consequences of the Proposed Action Summary

Resource No-Action Alternative Proposed Action Aesthetics No change from current conditions No significant long-term negative impacts expected. The new ACC would be compatible with the existing Omaha VAMC campus facilities. The new ACC would not impact views from adjacent or distant locations. Short-term temporary negative impacts may result during construction. Air Quality No change from current conditions No significant long-term negative impacts expected. Short-term temporary increases in emissions expected during construction. Short- term negative impacts would be mitigated with the implementation of Best Management Practices (BMPs) to limit dust and engine exhaust. Intermittent short-term negative impacts to local air quality would also result during power outages due to the operation of a backup generator. Cultural Resources No change from current conditions No Impact to historic properties Geology and Soils No change from current conditions No significant long-term negative impacts expected. Soil compaction and modifications to site topography would be required for the new ACC. Soil erosion and/or contamination would be controlled by implementing standard BMPs for erosion and sediment control, equipment refueling, and fuel and chemical spill clean-up. Hydrology and Water Quality No change from current conditions No significant long-term negative impacts expected. Short-term impacts to water resources from increased storm water runoff, erosion, and sedimentation due to construction activities would be limited. BMPs to control erosion and sedimentation and to properly manage runoff, and dispose of contaminated soil would be implemented. Long-term positive impacts include a reduction in stormwater runoff due to decreases in impervious surface. Wildlife, Habitat, and Threatened No change from current conditions No significant long-term negative and Endangered Species impacts. The site would be revegetated following construction. Tree clearing activities would be limited to avoid birds and bat impacts.

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Resource No-Action Alternative Proposed Action Noise No change from current conditions No significant long-term negative impacts. Short-term noise impacts due to construction would be minor, and mitigated by implementing time- of-day limitations and equipment BMPs as needed. Land Use No change from current conditions No significant long-term negative impacts. The new ACC would be consistent with existing land uses and zoning. Floodplains and Wetlands No change from current conditions No significant long-term or short- term negative impacts. No wetlands or floodplains are present. Socioeconomics No change from current conditions. Long-term positive impact expected Possible long-term negative impact as Omaha VAMC services improved. as Omaha VAMC facilities are not currently adequate to meet community needs. Transportation and Parking No change from current conditions No significant negative long-term impacts. Short-term parking impacts would be mitigated with temporary off-site parking. Bus access would be maintained. Solid and Hazardous Materials No change from current conditions No significant long-term negative impacts. BMP’s would be implemented for waste disposal and spill containment during construction. Significant increases in waste are not anticipated. Solid, hazardous, and biomedical waste would be managed according to current Omaha VAMC procedures. Utilities No change from current conditions No significant negative long-term impacts. Long-term positive impact as the new ACC would include updated utility systems and back-up power generation. Environmental Justice No change from current conditions No significant long-term impacts

Public and Agency Involvement The development of this EA included coordination and consultation with appropriate local, state, and federal agencies based on the potential impacts from the Proposed Action and the permits and approvals necessary for implementation. Project scoping letters were mailed out to various federal, state, and local agencies to solicit comments and feedback. The letters and responses are included in this EA as Appendix A.

An initial Notice of Intent (NOI) announcing the preparation of the Draft EA was published in the Omaha World-Herald on September 15, 2017.

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Upon completion, the Draft EA was made available for public review online at https://www.nebraska.va.gov/, at the Omaha Public Library (W. Dale Clark Main Branch), and at the Omaha VAMC. The public review period and the Notice of Availability (NOA) of the Draft EA were advertised in the Omaha World Herald on December 20, 2017. Comments will be accepted from agencies and the public during a 30-day public review period ending on January 19, 2018. Comments and responses will be included in the Final EA.

Funding and Cost The total cost of the Proposed Action is expected to be approximately $85 million (M). The VA cost of construction for this option is limited to $56M, the amount previously appropriated for the replacement hospital project as part of the long-term campus plan discussed in a 2009 Feasibility Study (VA 2009) and related 2012 Final EA document (VA 2012). Required funding in excess of $56M would be provided under the authority of Public Law (PL) 114-294, Communities Helping Invest through Property and Improvements Needed (CHIP IN) for Veterans Act of 2016, which allows the VA to accept donations for facilities at no additional cost to the government. As such, donors have been identified and funding has been allocated to construct and complete the new ACC as proposed in the VA Strategic Capital Investment Plan (SCIP) VHA23-636-2015-27431 (VA 2016).

This EA has been prepared in accordance with the requirements of the National Environmental Policy Act (NEPA) of 1969, (42 United States Code [USC] 4321-4347), CEQ Regulations for Implementing the Procedural Provisions of NEPA (40 Code of Federal Regulations [CFR] 1500- 1508), and VA guidance for implementing NEPA (Environmental Effects of VA Actions [38 CFR 26]).

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1.0 Introduction

This EA has been prepared in accordance with the requirements of the National Environmental Policy Act (NEPA) of 1969, (42 United States Code [USC] 4321-4347), Council on Environmental Quality (CEQ) Regulations for Implementing the Procedural Provisions of NEPA (40 Code of Federal Regulations [CFR] 1500-1508), and VA guidance for implementing NEPA (Environmental Effects of VA Actions [38 CFR 26]).

Background

The Omaha VAMC is located at 4101 Woolworth Avenue, Omaha, Douglas County, Nebraska (Figures 1-1 and 1-2). The Omaha VAMC is part of regional network of VA facilities that make up the Nebraska-Western Iowa Health Care System (NWIHCS). The Omaha VAMC provides a wide array of core services including:

• Inpatient care, • general medical care, • inpatient and outpatient surgical care, • psychiatric care, • ambulatory care services, and • clinical research programs.

The Omaha VAMC campus dates to approximately 1950, when the hospital was designed and constructed as a 500-bed general medical facility. Since 1950, there have been two major additions: (1) a research building in 1975, and (2) an outpatient addition in 1987. The Omaha VAMC has affiliations with the University of Nebraska’s College of Medicine, Creighton University’s School of Medicine, and many other allied health facilities within the greater Omaha area and region. A site plan including all the current Omaha VAMC campus facilities can be found in Figure 1-3.

Most functions of the Omaha VAMC take place in the main hospital building; however, there are numerous technical issues with the aging infrastructure of this building, as well as space and functional issues in almost all departments. The Proposed Action, to construct a new ACC, would provide a necessary component to improving patient care and satisfaction at the Omaha VAMC.

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Figure 1-1. Omaha VAMC Location Map

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Fig ure 1-2. Omaha VAMC Site Map

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Figure 1-3. Current Facility Plot Plan of the Omaha VAMC Campus

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Purpose and Need

The purpose of the project is to provide improved ambulatory care services to veterans in the VA NWIHCS service area.

The proposed project is needed to address the growing health care needs of the Omaha VAMC and patient population. The existing Omaha VAMC has numerous technical issues due to aging infrastructure, as well as space and functional deficiencies. The proposed project would promote patient care and safety, maintain Omaha VAMC facility cohesiveness, increase efficiency, and improve patient and staff satisfaction.

Space Deficiencies

Future workload projections show a significant increase for nearly all Omaha VMAC services, including medical/surgical ambulatory care, rehabilitation medicine, surgical specialties, ambulatory mental health, laboratory and pathology service, and radiology service. Future projections were based upon estimated Bed Days of Care (BDOC) per patient visit. 2013 BDOC for Ambulatory Care were estimated to be 142,921. Projected 2023 and 2033 BDOC are 171,612 and 183,414, respectively. Compared to 2013, these projections represent a 20 percent increase in patient load by 2023, and a 28 percent increase in patient load by 2033 (VA 2016).

In 2009, GLHN Architects and Engineers, Inc. prepared a Feasibility Study for Correcting Space & Infrastructure Deficiencies (VA 2009) in the NWIHCS (Feasibility Study). Within this study, a base space program was established using workload projections for 2017. Based upon calculations provided in the 2009 Feasibility Study, the Omaha VAMC was projected to require 728,819 departmental gross square feet (DGSF) to meet current needs, representing a facility- wide deficit totaling 301,613 DGSF.

Specific to Ambulatory Care, year 2017 utilization space projections estimated a 43 percent increase in clinic stops requiring approximately 125,803 DGSF for Ambulatory Care. The existing DGSF at the Omaha VAMC dedicated to Ambulatory Care services is 73,964 DGSF, indicating a potential deficiency of 51,839 DGSF based upon 2017 projections (VA 2009).

More recent data is consistent with the 2017 projected need for increased DGSF dedicated to Ambulatory Care services. Projected Ambulatory Care patient loads are expected to require an additional 218,956 DGSF by 2025, a 36 percent space deficit. Projected space deficits for other services provided by the Omaha VAMC, such as Acute Care (6 percent surplus), Long-Term Care (100 percent surplus), and other non-clinical departments (19 percent deficit) are generally lower; representing less of an immediate space need (VA 2016).

Functional Deficiencies

As a part of the Feasibility Study, several significant functional issues with Ambulatory Care were identified at the Omaha VAMC. The dated nature of the existing facility does not allow for the integration of related health care services and staff. This prevents the Omaha VAMC from fully implementing the preferred Patient Centered Medical Home Model (PCMH) adopted by the VA in

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2010, also referred to as Patient Aligned Care Team (PACT). PACT aims to provide unfragmented patient-centric care, using a foundation of primary care services that seamlessly link patients with specialty services. Ambulatory Care functions, including primary care spaces, are scattered throughout the facility and are not currently designed to meet PACT requirements. Spaces are fragmented and are not ideally configured for patient flow, staff efficiency, or sharing of equipment or services (VA 2009).

Existing operating rooms (ORs) housed within the Ambulatory Care units have been cited with infection control deficiencies, often related to space limitations that potentially compromise sterile conditions and will not accommodate modern equipment (VA 2016). The existing facilities do not allow for the required separation of clean and dirty corridors for equipment, patients, and staff.

Technical Deficiencies

Aside from direct needs for more DGSF dedicated to Ambulatory Care, the Feasibility Study identified accessibility and mechanical system deficiencies to the main hospital building which currently houses Ambulatory Care services at the Omaha VAMC.

Many sidewalks at the Omaha VAMC campus are deficient. Steeply sloping sidewalks are common, making navigation difficult for staff, visitors, and patients, many of whom may have limited mobility. These sidewalks become even more treacherous in icy weather. These sidewalks must be realigned both vertically and horizontally to meet the VA’s Barrier Free Design (Photograph 1).

1 2

Photographs 1 & 2. (1) View looking north from the Omaha VAMC main hospital building showing sloped walkways. (2) View looking north at the main entrance of Omaha VAMC main hospital building constructed in 1950.

According to the 2009 Feasibility Study, the facilities currently housing Ambulatory Care services are mechanically deficient. The buildings are served by a combination of 1950’s induction units and 1970’s unit convectors (Photograph 2). These systems are in poor condition and require replacement. The condition of the distribution, control systems, and ventilation systems correspond with the condition of the equipment they serve. Exhaust fans throughout the building are rated poor. The plumbing systems are original to the 1950’s construction (except for the

12 Proposed Ambulatory Care Center Environmental Assessment NWIHCS Omaha VAMC December 2017 outpatient addition) and are in need of upgrading, including the fire sprinklers, pumps, fixtures and piping, and medical gas systems. Furthermore, emergency power is deficient for the entire Omaha VAMC with hospital and clinic function not adequately served by existing generators (VA 2009).

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2.0 ACC Alternatives

Four initial ACC alternatives were developed and analyzed to address the project purpose and need (VA 2016).

Alternative 1 – No-Action Alternative

Under Alternative 1, the No-Action Alternative, there would be no change to the Omaha VAMC facility and existing Ambulatory Care services. Inclusion of a No-Action Alternative is prescribed by the CEQ regulations and serves as a benchmark against which proposed Federal actions are evaluated.

Alternative 2 – New On-site ACC

Under Alternative 2, a new ACC facility housing all Ambulatory Care services would be constructed at the existing Omaha VAMC campus (similar to the proposed action for the long- term campus plan, VA 2009). The ACC would include five modern, infection-free operating rooms for ambulatory surgery. The building would also provide the appropriate space to support a PACT- designed layout for Primary Care and Specialty Clinics. Space vacated within the main hospital building due to construction of the ACC, estimated to be approximately 100,000 DGSF, could then be repurposed to meet additional space and reorganization needs of the Omaha VAMC.

Alternative 3 – New Off-site ACC

Under Alternative 3, the ACC facility would be relocated away from the main Omaha VAMC campus. Ambulatory Care services, including primary care and surgical services, would be provided in a newly constructed or developed off-site facility. Space vacated within the main hospital building due to construction of the ACC, estimated to be approximately 100,000 DGSF, could then be repurposed to meet additional space and reorganization needs of the Omaha VAMC.

Alternative 4 – Third-Party Contracting

Under Alternative 4, all Ambulatory Care services would be contracted out to an off-site medical provider at a non-Omaha VAMC facility. Space vacated within the main hospital building due to construction of the ACC, estimated to be approximately 100,000 DGSF, could then be repurposed to meet additional space and reorganization needs of the Omaha VAMC.

ACC Alternatives Eliminated from Consideration

Alternatives 3 and 4 were eliminated from consideration.

Alternatives 3 and 4 would both meet the project purpose; however, the Ambulatory Care services would be removed from the Omaha VAMC campus, perpetuating the fragmentation of services and staff. Although Ambulatory Care services may be consolidated at a new location, removing Ambulatory Care services from the Omaha VAMC campus would not support the PACT patient-

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centric care design that has been adopted by the VA. At the expense of the patient, primary care services would become more isolated and disconnected from specialty clinics and services.

To varying degrees, both Alternatives 3 and 4 would require duplication of clinical support facilities (mechanical and technical), and/or administration and staff positions to effectively manage the facility or contracted medical provider. These additional costs make these concepts less desirable (VA 2016).

ACC Alternative Concepts Retained for Detailed Analysis

Two concepts were carried forward for detailed analysis: Alternative 1 – No-Action Alternative; and Alternative 2 – New On-site ACC (Proposed Action).

No-Action Alternative

Under the No-Action Alternative, there would be no change to the Omaha VAMC from its existing condition. This alternative would not address the growing health care needs of the Omaha VAMC. The facility would continue to function with severe space, functional, and technical deficiencies and diminishing capability. In particular, the following conditions would continue to exist at the Omaha campus:

• The campus would have a total overall space deficiency of approximately 325,714 DGSF for the projected workload analysis for 2025; • Multiple departments would continue to be limited in their required space; • Ambulatory Care functions would remain scattered throughout the main hospital building; • Surgical Service would remain undersized and there would be no separation between clean and dirty corridors; • All outdated mechanical, electrical, information technology (IT), sewer, water, and power systems would remain; and • The Ambulatory Care services housed within the main hospital building would not adhere to the PCMH or PACT model, limiting patient care and satisfaction.

Proposed Action Alternative

The Proposed Action is based on retaining all the services at the Omaha VAMC, by constructing a new ACC on site to replace the existing facilities. Figure 2-1 shows the proposed location of the new ACC overlain on the present VAMC site. A schematic rendering of the new ACC is also shown on Figure 2-2.

The Proposed Action consists of constructing an approximately 160,000 square-foot building to support ambulatory surgery, PACT clinical care, lobby, police service, radiology, support, and reception spaces on the existing Omaha VAMC campus. The new facility would include all electrical, mechanical and structural space to support the building as well as a 3,000 square-foot connecting corridor to the main hospital building.

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The new ACC would include three levels with a partial fourth floor mechanical penthouse. The building would primarily serve an outpatient veteran population and would be joined to the existing Omaha VAMC hospital building via a 3,000 square-foot connecting corridor consisting of two routes that would separate public/patient traffic from service/staff traffic moving between the buildings. The main entry level would be on the ground floor and would include lobby and reception, ambulatory surgery, a specialty PACT, radiology, and a central utility room. The first level of the new ACC would be on the same level as the ground floor of the existing Omaha VAMC hospital building, and would include the connecting corridor that can be accessed via elevator from the new ACC ground floor main entrance. The connecting corridor would be enclosed and protected from the weather and vehicular traffic. The first and second floors would each include four PACTs and circulation space, with group spaces, educational rooms, and public spaces situated around the perimeter of each floor.

The new ACC would be built northeast of the existing main hospital building on land that currently is a surface parking lot (Figure 2-1; Photographs 3 & 4). The ground floor main entrance would be located on the northwest corner of the building and would be serviced by a new circular drive extending east from Nimitz Drive for pick up and drop off. The building would be surrounded by green space on all sides, with access to the main hospital building from the south via Center Street. Puller Drive would be closed due to the connecting corridor between the new ACC and the main hospital building and green space expansion. As a result, primary access to the main hospital building entrance would be from the north via Woolworth Avenue on Nimitz Drive. The circular loading zone at the main hospital building entrance would remain in place. Although direct access to the new ACC and main hospital building from Puller Drive would no longer be possible, Waesche Drive would be extended north providing access to parking for the new ACC, and an indirect route to the main hospital entrance from Center Street.

3 4

Photographs 3 & 4. View looking southwest (3) and west (4) toward the proposed location of the new ACC. The new ACC would be constructed on an existing surface parking lot north of the Omaha VAMC main hospital

building (shown in the background of Photograph 3).

The existing parking lot north of the new ACC would be restriped and used as the primary patient and visitor lot. Overall, construction of the new ACC would result in the temporary loss of

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approximately 255 parking spaces. Construction of two additional parking garages for staff and visitors have been proposed as part of a long-term campus plan, but would be constructed as a separate project from the new ACC. Figure 2-3 shows the proposed location of the two new parking garages, and other proposed facilities including a Fisher House, new veteran’s housing, and a new health care building.

Correction of Deficiencies This Proposed Action would provide approximately 160,000 additional square feet dedicated to ambulatory care, allowing for new primary care clinics to be designed and constructed to meet the needs of each PACT team, including appropriate women veterans’ health care spaces.

This new building would also allow expansion of the ambulatory surgery portion of the ORs, with more complicated surgery procedures remaining at the Omaha VAMC main hospital building. While the Proposed Action does not completely mitigate the current Omaha VAMC OR space needs with regards to infection control deficiencies, modern equipment requirements, and clean/dirty corridor separation for equipment, patients, and staff; it does ensure that ambulatory surgery procedures could be conducted in an infection-free environment.

The Proposed Action would retain all Ambulatory Care services within the existing Omaha VAMC campus and would facilitate future Omaha VAMC campus upgrades. Areas of the main hospital building vacated by Ambulatory Care services would allow for the expansion, reorganization, and/or consolidation of ORs and other Omaha VAMC services. This would alleviate congestion and fragmentation of services, potentially contributing to improved patient care. Constructing the new ACC at the Omaha VAMC main campus would promote the seamless integration of Ambulatory Care with additional Omaha VAMC services, increasing patient satisfaction and improving the overall patient experience.

The Proposed Action would temporarily reduce available parking, with additional parking provided by planned future projects. The Omaha VAMC would provide an off-site parking lot to mitigate for temporary parking losses. Pedestrian facilities would be significantly upgraded and would be compliant with the American with Disabilities Act (ADA). Specific upgrades would include the widening of walkways and the elimination of non-ADA compliant grades that must currently be navigated when accessing the main hospital building. The Proposed Action would also provide two options for patient loading and unloading by maintaining the primary entrance at the main hospital building and construction a new primary entrance at the new ACC.

The new ACC would be a state-of-the-art facility and constructed according to modern medical facility standards and will include new mechanical, electrical, and IT systems currently lacking in the main hospital building. The existing sewer system and water lines directly serving the new ACC would also be upgraded.

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Feasibility Study (VA 2009) and 2012 Final EA document (VA 2012). Required funding in excess of $56M would be provided under the authority of Public Law (PL) 114-294, Communities Helping Invest through Property and Improvements Needed (CHIP IN) for Veterans Act of 2016, which allows the VA to accept donations for facilities at no additional cost to the government. As such, donors have been identified and funding has been allocated to construct and complete the new ACC as proposed in the VA Strategic Capital Investment Plan (SCIP) VHA23-636-2015-27431 (VA 2016).

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Figure 2-1. Proposed Ambulatory Care Center Site Plan

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Figure 2-2. Proposed Ambulatory Care Center Schematic Rendering (Omaha VAMC main hospital building seen in background)

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Figure 2-3. Omaha VAMC Future Buildings

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Page Intentionally Left Bank

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3.0 Affected Environment and Environmental Consequences of the Alternatives

This section discusses environmental considerations for the project, the contextual setting of the affected environment, and impacts of the No-Action Alternative and Proposed Action.

Aesthetics

Definition of the Resource

A visual resource is usually defined as an area of unique beauty that is a result of the combined characteristics of the natural aspects of land and human aspects of land use. Wild and scenic rivers, unique topography, and geologic landforms are examples of the natural aspects of land. Examples of human aspects of land use include scenic highways and historic districts.

Visual resources can be regulated by management plans, policies, ordinances, and regulations that determine the types of uses that are allowable or protect specially designated or visually sensitive areas.

Affected Environment

The Omaha VAMC campus is in an urban setting within the City of Omaha. The campus abuts the Field Club golf course and Field Club Trail on the east, the Douglas County Health Department and Health Center to the north, residences of the Morton Meadows neighborhood on the west, and a major retail and commercial corridor along Center Street to the south including the Hanscom Park neighborhood (see Figure 1-2, also see zoning map Figure 3-6). The Omaha VAMC main campus consists of the main hospital building constructed in approximately 1950, various buildings support buildings, surface parking lots, and green space.

Environmental Consequences

3.1.3.1 No-Action Alternative Under the No-Action Alternative, the visual aesthetics at the Omaha VAMC would remain unchanged. The Omaha VAMC campus facilities, including buildings, parking, and pedestrian infrastructure, would continue to exist in their current condition.

3.1.3.2 Proposed Action Aesthetics or visual resources would not be significantly affected by the implementation of the Proposed Action, as all construction and demolition activities would take place within the already developed portion of the Omaha VAMC campus.

The new ACC, reconfigured parking, and new expanded green space would be visually compatible with the existing industrial nature of the VAMC main campus and nearby properties and has been designed to blend in with the existing VAMC facilities and landscape (See Figure 2-2). The new ACC would most likely be shielded from view from the golf course and neighboring

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Field Club Trail due to the tree line along the eastern edge of the Omaha VAMC campus. The new ACC would also be constructed in a central location within the Omaha VAMC campus and in a relatively low-lying area currently occupied by a surface parking lot. Furthermore, the new ACC would include three levels with a partial fourth floor mechanical penthouse and would be significantly lower in height than the main hospital building (see Figure 2-2). The new ACC would most likely not be seen from areas around Center Street or South 42nd Street. From these two locations south and west of the Omaha VAMC campus, the new ACC would be shielded by the existing main hospital building and the steep grassy embankments that are present due to the topography of the site (See Photographs 5 & 6). The new ACC would potentially be visible form the north along Woolworth Avenue between the Omaha VAMC campus and the Doulas County Health Department facilities; however, the design and location of the building would not conflict with the surroundings.

5 6

Photographs 5 & 6. View looking northwest from Center Street (5) and southeast from South 42nd Street (6) showing the grassy embankments along the roadways around the Omaha VAMC campus.

It is unlikely that the new ACC would impact the skyline or alter any longer-distance views from the surrounding areas. Due to their height, the main hospital building at the Omaha VAMC campus and the nearby Douglas County Health Department building would continue to be the dominant visual structures in the area.

There would be temporary impacts to aesthetics on the Omaha VAMC campus from site preparation, demolition, and construction. Construction zones would be screened if necessary, and impacted vegetation would be reseeded and replanted as needed.

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Air Quality

Definition of the Resource

Air Quality Index (AQI) The AQI is an index for reporting daily air quality, which shows how clean or polluted the air is and explains what associated health effects might be of concern. The AQI focuses on health effects that may be experienced within a few hours or days after breathing polluted air. The United States Environmental Protection Agency (EPA) calculates the AQI for five major pollutants regulated by the Clean Air Act (CAA): ground level ozone, particulate pollution (also known as particulate matter), carbon monoxide, sulfur dioxide, and nitrogen dioxide. For each of these pollutants, EPA has established national air quality standards to protect public health. Ground- level ozone and airborne particles are the two pollutants that pose the greatest threat to human health in the United States.

The AQI is divided into six categories: good, moderate, unhealthy for sensitive groups, unhealthy, very unhealthy, and hazardous. Each category corresponds to a different level of health concern. The six levels of health concern and their descriptions are:

• Good: AQI is 0 to 50; air quality is considered satisfactory and air pollution poses little or no risk. • Moderate: AQI is 51 to 100; air quality is acceptable. However, for some pollutants there may be a moderate health concern for a very small number of people. For example, people who are unusually sensitive to ozone may experience respiratory symptoms. • Unhealthy for Sensitive Groups: AQI is 101 to 150; although the general public is not likely to be affected at this AQI range, people with lung disease, older adults, and children are at a greater risk from exposure to ozone, whereas people with heart and lung disease, older adults, and children are at greater risk from the presence of particles in the air. • Unhealthy: AQI is 151 to 200; everyone may begin to experience some adverse health effects and members of the sensitive groups may experience effects that are more serious. • Very Unhealthy: AQI is 201 to 300; this would trigger a health alert signifying that everyone may experience more serious health effects. • Hazardous: AQI is greater than 300; this would trigger a health warning of emergency conditions. The entire population is more than likely to be affected.

Criteria Air Pollutants The CAA requires EPA to set National Ambient Air Quality Standards (NAAQS) for six common air pollutants (40 CFR 50). These commonly found air pollutants are located all over the United States and include particulate matter, ground-level ozone, carbon monoxide, sulfur oxides, nitrogen oxides, and lead. These pollutants can harm human health and the environment, or cause property damage. The EPA calls these pollutants “criteria” air pollutants because it regulates them by developing human, health based, and/ or environmentally based criteria for setting permissible levels. Table 3-1 provides the NAAQS set by the EPA.

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The EPA defines a non-attainment area as an area considered to have air quality worse than the NAAQS as defined in the Clean Air Act Amendments of 1970 (PL 91-604 Sec 109). Nonattainment areas must have and implement a plan to meet the standard, or risk losing some forms of federal financial assistance.

Table 3-1. National Ambient Air Quality Standards Primary Standards Secondary Standards Pollutant Level Averaging Time Level Averaging Time Carbon Monoxide 9 ppm 8-hour None (CO) 35 ppm 1-hour Rolling 3- month 0.15 µg/m3 Same as Primary Lead (Pb) average 1.5 µg/m3 Quarterly average Same as Primary Nitrogen Dioxide 53 ppb Annual Same as Primary (NO2) 100 ppb 1-Hour None Particulate Matter 150 µg/m3 24-hour Same as Primary (PM10) Particulate Matter 15.0 µg/m3 Annual Same as Primary (PM25) 3 35 µg/m 24-hour Same as Primary

Ozone (O3) 0.070 ppm 8-hour Same as Primary 0.03 ppm Annual 0.5 ppm 3-hour Sulfur Dioxide (SO2) 0.14 ppm 24-hour 75 ppb 1-hour None

Source: EPA 2017a (October 30, 2017) ppb – part per billion ppm – parts per million µg/m3 – micrograms per cubic meter

Affected Environment

Douglas County air quality is generally good, with one unhealthy AQI value recorded in 2017 (EPA 2017a, Nebraska Department of Environmental Quality [NDEQ] 2017). Tables 3-2 display the AQI for Douglas County, Nebraska.

Furthermore, Douglas County is currently in attainment for all NAAQS pollutant levels (NDEQ 2017). According to the most recent 2017 NDEQ air quality data, the state of Nebraska has never had a declared non-attainment determination (NDEQ 2017).

Table 3-2. AQI for Douglas County in 2017

Number of Days when Air Quality was… Unhealthy for # Days with AQI Good Moderate Unhealthy Sensitive Groups 181 111 69 1 0

Source: EPA 2017b. Data as of October 30, 2017

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Environmental Consequences

3.2.3.1 No-Action Alternative Under the No-Action Alternative, air quality conditions at the site would remain unchanged. Emission from the continued operation of the Omaha VAMC facilities and from local mobile sources, such as automobiles would persist.

3.2.3.2 Proposed Action Construction and operation of the Proposed Action would be expected to produce localized temporary effects on air quality due to construction activities. No permanent or long-term impacts to air quality are anticipated.

Construction activities associated with the Proposed Action are expected to result in temporary increases in localized particulate emissions. Operation of construction vehicles such as dump trucks, bulldozers, cranes, earth-moving activities, and waste-disposal actions would produce temporary and localized emissions of particulate matter, volatile organic compounds, nitrogen oxides, and carbon monoxide.

Fugitive emissions from demolition activities would be mitigated through Best Management Practices (BMPs). BMPs that would be implemented include:

• Machinery and other construction vehicle engines would not be left to idle unnecessarily; and • Standard dust suppression procedures would be used to control fugitive dust. Haul roads would be kept wet, and any soil that is deposited on nearby paved roads by vehicles would be removed from the roads and returned to the site or to an appropriate disposal area.

The new ACC would include a 750-kilowatt (kW) emergency generator to provide supplemental power. The generator would cause short-term local fugitive emission increases. These increases are expected to be minor, as the generator would only run during power outages.

Cultural Resources

Definition of the Resource

Section 106 of the National Historic Preservation Act, as amended, and implementing regulations found at 36 CFR 800, require that federal agencies consider any effect a proposed action may have on historic properties. This is generally accomplished through the Section 106 compliance process, as follows:

• Identify consulting parties; • Identify and evaluate historic properties located within the Area of Potential Effect (APE) established for an undertaking; • Assess adverse effects on properties listed, or eligible for listing, on the National Register of Historic Places (NRHP); and

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• Consult with the State Historic Preservation Officer (SHPO) and, as appropriate, the Advisory Council on Historic Preservation, and other interested parties to resolve adverse effects.

Four main criteria determine if a property is eligible for inclusion on the NRHP. A property is considered eligible if it meets one or more of those criteria listed below:

• Criterion A: Associated with events that have made a significant contribution to the broad pattern of our history. • Criterion B: Associated with the lives of persons significant in our past. • Criterion C: Embodies the distinctive characteristics of a type, period, or method of construction, or represents the work of a master, or that possesses high artistic values, or represents a significant and distinguishable entity whose components may lack individual distinction. • Criterion D: Has yielded, or may be likely to yield, information important in history or pre- history.

Cultural resources generally include archaeological sites, historic properties, traditional cultural places, and other places where significant historic activities have taken place. These sites are often considered valuable to the human environment, and measures must be taken to ensure that they are treated appropriately.

Congress also passed the American Indian Religious Freedom Act of 1978 (PL 95-341, 42 USC 1996) to protect and preserve for American Indians their inherent right of freedom to believe, express, and exercise their traditional religions including, but not limited to, access to sites, use and possession of sacred objects, and the freedom to worship through ceremonial and traditional sites. Therefore, the law requires that the effects of a federal undertaking on Native American sites or places (prehistoric or historic) that have religious, ceremonial, or sacred aspects be evaluated within the context of this law. Consultation with the appropriate Tribal Historic Conservation Officer (THPO) should be conducted to determine if Native American resources have the potential to be affected, and to develop appropriate avoidance or mitigation measures if needed.

Affected Environment

There are 179 properties and districts listed on the NRHP in Douglas County, including three National Historic Landmarks (NRHP 2017). Table 3-3 summarizes the 15 sites that are within one mile of the Omaha VAMC. The closest NRHP site is the Field Club Historic District, which is roughly bounded by Pacific Street, South 32nd Avenue, Center Street, and South 36th Street just east of the Omaha VAMC campus.

According to the Nebraska SHPO, the Omaha VAMC is not eligible for listing in the NRHP. Although the original core of the hospital complex was built in 1950 and is therefore of age, many additions were added to the building between 1960 and the mid-1980s (Nebraska SHPO response dated July 8, 2011 included in Appendix A).

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Table 3-3. NHRP Listings in Douglas County, Nebraska Within One Mile of the Omaha VAMC Approximate Distance from Site Name Date Listed Omaha VAMC (miles) Guy C. Barton House 08/14/73 0.97 northeast Blackstone Hotel 01/11/85 0.87 northeast Bradford-Pettis House 07/21/83 0.8 north Brandeis-Millard House 11/28/80 0.76 north Columbian School 11/28/90 0.58 north Field Club Historic District 11/15/00 0.44 east Georgia Row House 11/12/82 0.98 northeast Havens-Page House 10/07/82 0.85 northeast Charles D. McLaughlin House 11/08/82 0.74 northeast Normandie Apartments 12/06/91 0.88 northeast Park Avenue Apartment District 07/02/08 0.98 northeast Park School 11/29/89 0.92 east Selby Apartments 12/30/04 0.49 northeast Gottlieb Storz House 08/07/74 0.92 northeast Terrace Court 07/02/08 0.94 northeast

Source: NRHP 2017

Environmental Consequences

3.3.3.1 No-Action Alternative Under the No-Action Alternative, there would be no impact to Cultural Resources. There would be no modification to any existing structures, no construction of new structures, and no excavation activities that would potentially unearth cultural artifacts.

3.3.3.2 Proposed Action Impacts to Cultural Resources are not anticipated due to the Proposed Action

Coordination with the Nebraska SHPO indicated that activities associated with the Proposed Action are unlikely to impact any eligible or listed prehistoric or historic cultural resource, and provided a determination of no historic properties affected (Nebraska SHPO response dated October 4, 2017 included in Appendix A). No response was received from initial consultation with the THPO for the Sac and Fox Nation of Missouri in Kansas and Nebraska, the Omaha Tribe, the Santee Sioux Nation, the Ponca Tribe of Nebraska, the Winnebago Tribe of Nebraska, and the Iowa tribe of Kansas and Nebraska.

The Nebraska SHPO also indicated that the Omaha VAMC campus had not previously been surveyed by a professional archeologist, and that buried or obscured cultural or human remains may be discovered due to construction activities associated with the Proposed Action. Should artifacts or human remains be discovered due to the Proposed Action, work would be immediately

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halted and remains left in place in accordance with Standard VA Construction Policy. The Nebraska SHPO, THPO, and appropriate authorities would be immediately notified to re-initiate the Section 106 and tribal consultation process. In coordination with the Nebraska SHPO and THPO, the services of a professional archaeologist would likely be retained to evaluate the findings prior to commencing work.

It is also recommended that on-site personnel closely monitor mechanical excavation of soils, and any other ground disturbing activities that may result, for cultural materials that might be revealed or unearthed throughout the course of construction. In the event of an inadvertent discovery, the Section 106 and THPO consultation process would be re-initiated with the appropriate consulting parties.

Geology and Soils

Definition of the Resource

Geology Geological resources consist of solid materials that make up the Earth’s surface and subsurface such as rocks, minerals, and other unconsolidated materials. Most commonly, these resources are described in terms of topography, physiography, composition, soils, geologic hazards, and paleontology.

Soils Soils are the unconsolidated mineral or organic materials on the immediate surface of the earth that serve as natural mediums for the growth of land plants. Soil is made up of particles of broken rock that have been chemically and environmentally altered through various processes, such as weathering and erosion. Various factors that affect the formation of soils include parent materials, climate, topography, biological factors, and time. The United States Department of Agriculture (USDA) Natural Resource Conservation Service (NRCS) and the National Cooperative Soil Survey (NCSS) provide an elaborate classification and mapping of soil types throughout the United States.

Affected Environment

Geology Douglas County generally contains bedrock of the Cretaceous Period dating between 66 to 145 million years ago at a depth ranging from 30 to 275 feet. Overlaying the bedrock are layers of loess, till, and alluvium. Pockets of sand and gravel are also present throughout, and have been found to be excellent sources of groundwater (University of Nebraska School of Natural Resources 2017).

The most recent United States Geologic Survey (USGS) long-term seismicity model (2014) shows eastern Nebraska as a low-hazard area with respect to future earthquake activity (Figure 3-1).

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The map displays earthquake ground motions for various probability levels across the United States. These probabilities are applied in seismic provisions of building codes, insurance rate structures, risk assessments, and other public policy. The Omaha VAMC site lies within the two to four percent ground acceleration probability or very low hazard range (USGS 2014).

Figure 3-1. USGS 2014 Long-Term Seismic Hazard Map. The map displays earthquake ground motions for various probability levels across the United States. These probabilities are applied in seismic provisions of building codes, insurance rate structures, risk assessments, and other public policy. The Omaha VAMC site lies within the two to four percent ground acceleration probability or very low hazard range (USGS 2014).

Soils The project is located within the Nebraska/Kansas Loess Hills Level IV Ecoregion of the Western Corn Belt Plains (Chapman et al. 2001). These areas include dissected hills with deep, silty, well drained soils supported a potential natural vegetation of tallgrass prairie with scattered oak- hickory forests along stream valleys (Nebraska Game and Parks Commission Nebraska [NGPC] Natural Heritage Program [NHP] 2017a, Rolfsmeier and Steinauer 2010) (Figure 3-2). Cropland agriculture is now common and ample precipitation in the growing season supports dryland agriculture, with only a few areas requiring irrigation.

The Omaha VAMC campus and adjacent areas include two mapped soil units (Figure 3-3). The Urban land – Udarents complex, zero to 16 percent slopes, covers approximately 98 percent of the Omaha VAMC campus. This complex is a silt loam formed from silty loess parent material.

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This soil is typically greater than 80 inches in depth frequently found on hillslopes and sideslopes. There are no prime farmland soils within the ESA (USDA NRCS 2017).

The ESA no longer supports naturally occurring plant communities. The ESA and the surrounding vicinity have been converted to urban land uses. The Omaha VAMC campus slopes downward gently to the north and west with on-site elevation ranging from 1,180 to 1,250 feet above sea level.

Omaha VAMC

Figure 3-2. Ecoregions of Nebraska Showing the Omaha VAMC Location in Red (NGPC NHP 2017a).

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Figure 3-3. Omaha VAMC Soils Map

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Environmental Consequences

3.4.3.1 No-Action Alternative Under the No-Action Alternative, no demolition, construction, or site upgrade activities would occur that would affect geological resources or soils. Thus, no impacts to geological resources or soils would be expected to result from this alternative.

3.4.3.2 Proposed Action Geology Under the Proposed Action, construction and demolition activities could result in modifications to subsurface features. The excavation of surficial soil for the placement of slabs for new structures would have a long-term effect on topography of the subsurface geologic formation; however, this effect would be minor as the existing subsurface geologic formation does not have a specific economic (i.e., mining resource) or other structural use. The use of this formation as structural support for a new building would be consistent with adjacent land uses.

Soils Soil disturbance is defined as anything that causes the impairment of physical, chemical, and biological properties and processes, such as erosion, compaction, displacement, rutting, burning, loss of organic matter, and mass movement of soil.

Implementation of the Proposed Action would result in earth-moving and excavation activities limited to the immediate vicinity of the construction and demolition work areas. During earth- moving activities, soils would be subject to erosion. BMPs for erosion and sedimentation control would be implemented during construction to mitigate the potential for soil erosion during earth- moving and excavation activities.

Areas disturbed by excavation would be backfilled and subsequently re-planted, re-seeded, or sodded. Erosion and sediment control measures implemented during construction activities are also required to comply with stormwater pollution prevention rules. A Stormwater Pollution Prevention Plan (SWPP) would be prepared and implemented prior to initiating any site-disturbing activities as required by the City of Omaha.

As with almost any construction project involving the use of heavy equipment, there is some risk of an accidental fuel or chemical spill, and the potential contamination of soils. To reduce the potential for soil contamination, fuels would be stored and maintained in a designated equipment staging area. A person(s) designated as being responsible for equipment fueling would closely monitor the fueling operation and an emergency spill kit containing absorption pads, absorbent material, a shovel or rake, and other cleanup items, would be readily available onsite in the event of an accidental spill. Following these precautions, the potential for an accidental chemical or fuel spill occurring and resulting in adverse impacts to soils would be minimal. In additional to a SWPP, a National Pollution Discharge Elimination System (NPDES) Construction Storm Water (CSW)

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permit would be obtained prior to construction if required (See Section 3.5 for additional discussion regarding NPDES) (NDEQ 2016b).

No significant soil erosion, sedimentation, or contamination is expected to result from the Proposed Action due to the implementation of BMPs, erosion and sediment control measures, and conditions outlined within SWPP and NPDES CSW permit, as needed.

Hydrology and Water Quality

Definition of the Resource

Water resources are sources of water that are useful or potentially useful to humans. Fresh water resources are essential for many agricultural, industrial, recreational, household, and environmental activities. Fresh water resources are generally divided into ground water or surface water sources

Groundwater Groundwater is the water located beneath the surface of the earth, within soil pore spaces, and in the fractures of geologic formations. Groundwater is naturally replenished by surface water from precipitation, streams, and rivers. Groundwater is often used for agricultural, municipal, and industrial uses through the construction of wells.

Surface Water Surface water is any water that has collected on the ground or contained in a stream, river, lake, wetland, or ocean. Surface water is replenished through precipitation and is naturally depleted through evaporation and subsurface seepage into the groundwater.

Stormwater is surface water from precipitation events. Runoff is created when stormwater cannot be rapidly absorbed by the ground, or falls on impervious surfaces (parking lots, roads, buildings, compacted soils, etc). Runoff can cause many problems, including the erosion of watercourses and flooding. When stormwater creates runoff, pollutants are introduced into surface water and transported.

The Clean Water Act (CWA) (33 USC 1251) regulates discharges of pollutants into the Waters of the United States (WOTUS) by establishing quality standards for surface waters. The CWA makes it unlawful to discharge any pollutant from a point source into navigable waters, unless a permit is obtained. The EPA’s NPDES controls discharges. NPDES regulates the discharge of point (pipe, manufactured ditch, etc) and nonpoint (stormwater) sources of water pollution.

Affected Environment

Groundwater The Omaha VAMC is located within the Western Interior Plains Aquifer System. This aquifer system underlies most of Kansas, the eastern and southern parts of Nebraska, and a small area in west-central Missouri. It consists of water-yielding dolomite, limestone, and sandstone that are

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stratigraphically equivalent to aquifers of the Ozark Plateaus Aquifer System. However, in contrast to the Ozark Plateaus system, the Western Interior Plains Aquifer System contains no freshwater.

Little water is withdrawn from the Western Interior Plains Aquifer System because the aquifer system is deeply buried and contains highly mineralized water. Regional groundwater movement in this aquifer system is southeastward to eastward. Much of the water discharges from the aquifer system in the transition zone between the Western Interior Plains and the Ozark Plateaus aquifer systems (USGS 1997).

Surface Water The Omaha VAMC is located within the Big Papillion-Mosquito Watershed and drains into the Missouri River. This watershed contains a portion of seven counties: Douglas, Sarpy, and Washington Counties in Nebraska and Harrison, Mills, Pottawattamie, and Shelby Counties in Iowa. Papillion Creek is a 15.5-mile long tributary of the Missouri River in Nebraska. Its watershed lies in Washington, Douglas, and Sarpy counties, including parts of the city of Omaha and the Omaha VAMC. The main branch of Papillion Creek is known as Big Papillion Creek. Papillion Creek empties into the Missouri River south of Bellevue and just north of the mouth of the Platte River. The location of the Omaha VAMC with respect to nearby surface water resources is shown on Figure 3-4.

According to the Nebraska Department of Environmental Quality (NDEQ), a number streams and water bodies within the watershed are impaired (NDEQ 2016a). Impaired streams within the vicinity of the Omaha VAMC include the Missouri River, Little Papillion Creek, Big Papillion Creek, Papillion Creek and Cole Creek. Impaired uses include recreation and aquatic life.

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Figure 3-4. Water Resources Map

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Environmental Consequences

3.5.3.1 No-Action Alternative The No-Action Alternative would have no effect on hydrology or water resources. Existing conditions would be maintained, and no increases in stormwater runoff, erosion, or sedimentation would be expected.

3.5.3.2 Proposed Action There could be minor, short-term impacts to water resources because of increased stormwater runoff, erosion, and sedimentation due to construction.

To help minimize erosion and sedimentation and to properly manage runoff for both stormwater quantity and quality, BMPs would be implemented pursuant to Nebraska’s stormwater regulatory program rules. These BMPs, including silt fences and temporary sediment traps and basins, would be implemented as appropriate to control erosion and sedimentation (see Section 3.4 for additional discussion regarding erosion and sediment control). In addition, during construction, hazardous materials would be identified and controlled, and any accidental spills would be contained (See Section 3.12 for a more details discussion regarding hazardous materials). Spills from construction activity that may infiltrate the soil, although unlikely, could degrade groundwater quality. If such a spill should occur, the affected area would be attended to immediately and the soil would be removed and disposed of according to NDEQ guidelines and other permit requirements. With the implementation of the BMPs discussed above, construction activities associated with the Proposed Action would not have a significant effect on ground water or surface water resources.

Long-term impacts to water quality are not anticipated. The Proposed Action would result in a net decrease in impermeable surfaces (approximately 44,000 square feet) as the new ACC would be partially built on what currently is an existing parking lot, and sections of Puller Drive and nearby surface parking lots would be converted to green space (see Figure 2-1). As a result, the Proposed Action is expected to decrease storm water runoff from the Omaha VAMC once complete. The Proposed Action is unlikely to result in increases in wastewater discharge from the Omaha VAMC beyond normal growth projections. The Omaha VAMC would coordinate with the City or Omaha and NDEQ to obtain the appropriate NPDES permits for future operation.

Wildlife, Habitat, and Threatened and Endangered Species

Definition of the Resource

Wildlife Wildlife includes all non-domesticated plants (flora), animals (fauna), and other organisms.

Habitat Habitat is the natural environmental of a given species. Habitat can include the physical, biological, and climatic characteristics required for an organism’s survival and reproduction.

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Threatened and Endangered Species The Endangered Species Act of 1973 (16 USC 1531) prohibits actions that endanger the critical habitat or species of fish, wildlife or plant that is in danger of extinction. The Endangered Species Act also forbids the “taking” (i.e. killing, harming, harassing) of any such species. Threatened and endangered species are listed, and certain rules and regulations restrict actions that will adversely affect such species and their habitats.

Affected Environment

Wildlife Common wildlife species of Douglas County include song birds, cottontail rabbit, skunk, squirrels, raccoon, deer, and opossum. At the Omaha VAMC, various wildlife species have the potential to be present, dependent on the type of habitat available. The VAMC is in a highly developed area of Omaha, within a high vehicular traffic area. However, the golf course and Field Club Trail abutting the east side of the VAMC property could provide habitat for a variety of wildlife species. Wildlife species likely to be present at the site are typically limited to small mammals, various species of birds, reptiles, and amphibians that are accustomed to living in urban environments.

Habitat Douglas County is found within the Tallgrass Prairie Ecoregion of Nebraska. Most tallgrass prairie has been heavily grazed or converted for agricultural or urban use in Douglas County. Common tree species of Douglas County include maple, hickory, dogwood, mulberry, plum, cherry, oak, willow, cottonwood, and elm. Typical native and non-native grasses include smooth brome, Kentucky bluegrass, perennial ryegrass, Indian grass, big blue stem, and tall fescue. At the Omaha VAMC the site is mainly urbanized with buildings, parking lots, and sidewalks. The green space that is present is made up of manicured grasses and various ornamental trees and shrubs.

Threatened and Endangered Species Table 3-4 provides a summary of the federal and state-listed species provided by the United States Fish and Wildlife Service (USFWS) and the NGPC that are known to be present or could potentially be present in Douglas County. This table includes ten species, including the lake sturgeon (Acipenser fulvescens), river otter (Lontra canadensis), sturgeon chub (Macrhybopsis gelida), American ginseng (Panax quinquefolium), interior least tern (Sternula antillarum), pallid sturgeon (Scaphirhynchus albus), piping plover (Charadrius melodus), northern long-eared bat (Myotis septentrionalis), Red Knot (Calidris canutus rufa), and western prairie fringed orchid (Platanthera praeclara).

The American Ginseng, red knot, interior least tern, river otter, piping plover, pallid sturgeon, lake sturgeon, and sturgeon chub are only found along certain water bodies such as the Missouri, Platte, and Elkhorn River which are located well outside of the ESA. The western prairie fringed orchid has the potential to occur within Douglas County; however, there are no known populations within the great Omaha area, and there is no suitable habitat within or adjacent to the ESA (mesic

39 Proposed Ambulatory Care Center Environmental Assessment NWIHCS Omaha VAMC December 2017 to wet tallgrass prairies and wet meadows). These species would not be present at the VAMC and would not be affected by implementation of the Proposed Action or No-Action Alternative.

Table 3-4. Federal and State Listed Species in Douglas County

Common Name Scientific Name Federal Status State Status Lake Sturgeon Acipenser fulvescens -- Threatened

Interior Least Tern Sterna antillarum Endangered Endangered

Piping Plover Charadrius melodus Threatened Threatened

Red Knot Calidris canutus rufa Threatened --

River Otter Lontra canadensis -- Threatened

Sturgeon Chub Macrhybopsis gelida -- Endangered

Northern Long-eared Bat Myotis septentrionalis Threatened Threatened

Pallid Sturgeon Scaphirhynchus albus Endangered Endangered

American Ginseng Panax quinquefolium -- Threatened

Western Prairie Fringed Orchid Platanthera praeclara Threatened --

Source: USFWS (2017a) and NGPC NHP (2017b)

Northern Long-eared Bat - The northern long-eared bat is a medium-sized bat with a body length of 3 to 3.7 inches but a wingspan of 9 to 10 inches. Their fur color can be medium to dark brown on the back and tawny to pale-brown on the underside. As its name suggests, this bat is distinguished by its long ears, particularly as compared to other bats in its genus, Myotis.

Figure 3-5 provides a distribution map for the northern long-eared bat within Nebraska. This species does have the potential to be present at the Omaha VAMC due to being within the species range and having trees on site to provide potential maternity roosting habitat.

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Figure 3-5. Distribution of the Northern Long-eared Bat Within Nebraska

(NGPC NHP 2015)

Environmental Consequences

3.6.3.1 No-Action Alternative Wildlife Under the No-Action Alternative, the Proposed Action would not be implemented at the Omaha VAMC. Therefore, no construction would take place and there would be no impacts to wildlife species, migratory birds, or their habitats. Animals inhabiting buildings, such as bats, rodents, insects, and small mammals would continue to remain mostly undisturbed. There would be no new effects on wildlife or wildlife habitat.

Habitat Under the No-Action Alternative, construction activities would not occur and there would be no additional impacts to any habitat at the Omaha VAMC campus. Existing disturbances such as mowing and grounds maintenance, and foot and vehicular traffic would continue.

Threatened and Endangered Species The No-Action Alternative would have no effect on any threatened or endangered species. Construction activities would not occur, and site conditions would remain unchanged.

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3.6.3.2 Proposed Action Wildlife Under the Proposed Action Alternative, a new ACC would be constructed on an existing parking lot and green space at the Omaha VAMC. All of the work would be on existing VAMC property, limiting direct and indirect impacts to nearby habitats that support local, non-listed, wildlife species and migratory birds.

It is estimated that project may require the removal of approximately 10 trees and would impact manicured lawns. These areas may be used to a limited degree by small mammals, reptiles, and various songbirds; however, it is unlikely that these species reside on the premises or breed within the developed portion of the VAMC. Impacts to wildlife due to the loss of these areas would be minimal. Furthermore, most species that would use the area (if not all) are highly mobile. Individuals that feel threatened or bothered by any of the proposed activities would likely relocate to adjacent areas. Therefore, potential impacts to wildlife and migratory birds due to implementing the Proposed Action Alternative would be minimal and short-term.

Habitat Construction activities would entail the use of heavy machinery, trucks, and trailers. Construction activities would necessitate removal of vegetation surrounding work areas, primarily manicured lawns, but also trees or shrubs located very close to the project site. Impacts would occur in previously disturbed areas and adverse impacts to habitat would be minimal. Following completion of all construction and demolition activities, all disturbed areas would be reseeded or re-vegetated and erosion control BMPs would be maintained until the vegetation is fully reestablished.

Threatened and Endangered Species The Proposed Action would not impact threatened and endangered species at the Omaha VAMC or adjacent properties (See Appendix A, NGPC response letter dated November 6, 2017 and USFWS response letter dated November 30, 2017,). The Omaha VAMC will continue consultation with the USFWS and NGPC as needed to ensure the Proposed Action will not jeopardize the continued existence of any threatened or endangered species, or adversely modify critical habitat.

Tree removal would be conducted outside the maternity roosting season for the northern long- eared bat (June 1 to July 31) and for the migratory bird nesting season (April 1 to July 15). If tree removal cannot be avoided outside these seasons, then surveys would be conducted by a qualified biologist to determine if these species are present. If found, coordination with the USFWS and NGPC would be initiated to determine an appropriate course of action (Appendix A).

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Noise

Definition of the Resource

Noise pollution is typified by distracting, irritating, or damaging sounds that are freely audible. Sounds are generally considered noise pollution if they adversely affect wildlife, natural processes, human activity or health, or are capable of damaging physical structures.

The prevailing source of artificial noise pollution is from transportation. In rural areas, train, airplane, and vehicle noise can disturb wildlife habits, potentially affecting hunting, mating, and social behaviors. In urban areas, traffic noise can cause sleep disruption in humans and animals, hearing loss, increases in stress, and decreases in productivity. Construction activities, entertainment districts, and industrial facilities are additional sources of noise pollution commonly found in urban settings.

The Noise Control Act (NCA) of 1972 established a national policy to promote an environment for all citizens that is free from noise that jeopardizes their health and welfare (42 USC 4901). The NCA established mechanisms of setting emission standards for sources of noise, including motor vehicles, aircraft, certain types of Heating, Ventilation, and Air Conditioning (HVAC) equipment, and major appliances. The EPA has established noise guidelines and to protect citizens from potential hearing damage and other adverse physiological, psychological, and social effects associated with noise; however, noise is typically regulated at the state and local level. In general, the NCA established that noise levels in exceedance of 55 decibels (dBA) outdoors and 45 dBA indoors are likely to cause interference and annoyance. Furthermore, continued exposure to noise levels in exceedance of 70 dBA can cause hearing loss.

Affected Environment

The primary sources of noise at the Omaha VAMC include pedestrian and vehicular traffic, deliveries, grounds maintenance, and the operation of facility equipment including HVAC and power generation. Sensitive receptors that are located near the Omaha VAMC include nearby churches, golf course, trail, and surrounding residential areas. In addition, noise generated at the Omaha VAMC has the potential to affect the patient experience at the Omaha VAMC main hospital building and nearby Douglas County Health Center.

Environmental Consequences

3.7.3.1 No-Action Alternative Under the No-Action Alternative, ambient noise levels would remain unchanged near the Omaha VAMC. Routine facility operations, vehicle traffic, and construction activities from other projects near the Omaha VAMC campus would continue to generate noise.

3.7.3.2 Proposed Action Implementation of the Proposed Action would not involve the long-term operation of significant noise-generating sources, nor would it increase or alter the existing levels of the primary noise sources near the Omaha VAMC campus. However, due to construction-related activities, there

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would be a temporary increase in localized noise generated during construction of the new ACC and associated facilities.

Noise effects to workers may require the use of hearing protection equipment. The Proposed Action would require the use of heavy equipment for clearing, leveling, construction, and demolition activities. Heavy equipment commonly produces noise levels ranging from 70 to 95 dBA at a distance of 50 feet. Noise impacts to Omaha VAMC users and nearby residents are expected to occur only during daylight hours and are expected to be minor. Measures would be implemented if needed to mitigate noise impacts during construction activities. These measures may include limiting specific construction activities to certain times of day, designating construction access areas and roads, and using barriers or noise dampening mats, among other methods. Construction noise levels would be reduced to low or none during nighttime hours.

Land Use Definition of the Resource

Land use refers to natural land uses and land uses that reflect human modification. Natural land use classifications include wildlife areas, forests, and other open or undeveloped areas. Human land uses include residential, commercial, industrial, utilities, agricultural, recreational, and other developed uses. Management plans, policies, ordinances, and regulations determine the types of uses that are allowable, or protect specially designated or environmentally sensitive uses.

Affected Environment

The Omaha VAMC campus is in an urban setting within the City of Omaha. The campus abuts a golf course and public trail on the east, the Douglas County Health Department and Health Center to the north, residences of the Morton Meadows neighborhood on the west, and the Hanscom Park neighborhood and a major retail and commercial corridor along Center Street to the south (see Figure 1-2).

The entire ESA is currently zoned for General Office uses (see Figure 3-6).

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Figure 3-6. Omaha VAMC Zoning Map

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Environmental Consequences

3.8.3.1 No-Action Alternative The No-Action Alternative would have no effect on land use. The Omaha VAMC campus is currently consistent with City of Omaha zoning regulations.

3.8.3.2 Proposed Action Implementation of the Proposed Action would not result in any short or long-term negative impacts to land use with the ESA or adjacent areas. Land use within the Omaha VAMC campus due to the Proposed Action would generally remain unchanged. The new ACC, parking, and greenspace would be constructed entirely within the Omaha VAMC property boundary and would be consistent with existing facilities and infrastructure, providing needed modernization and expansion of existing facilities. Land use adjacent to the ESA would be unaffected by the project.

The Proposed Action would be consistent with current City of Omaha zoning regulations (See Figure 3-6).

Floodplains and Wetlands

Definition of the Resource

Floodplains According to Executive Order (EO) 11988, Floodplain Management, a floodplain is defined as:

“the lowland and relatively flat areas adjoining inland and coastal waters including flood prone areas of offshore islands, including a minimum, that area subject to a one percent or greater chance of flooding in any given year.”

EO 11988 requires federal agencies to avoid the long and short-term adverse effects associated with the occupancy and modification of floodplains. In addition, this EO requires agencies to avoid direct and indirect support of floodplain development whenever there is a practicable alternative (44 CFR 26951).

Wetlands A wetland is an area with sufficient hydrology to support hydrophytic (water-loving) vegetation and the development hydric soils by creating anoxic (without oxygen) below-ground conditions. Wetlands include swamps, marshes, bogs, etc. Wetlands are extremely biologically diverse and can support a wide variety of plant and animal life. Wetlands are beneficial in that they improve water quality, store floodwater, provide fish and wildlife habitat, are aesthetically pleasing, and are biologically productive.

Section 404 of the CWA established a program to regulate the discharge of dredged or fill in WOTUS, including wetlands. Activities in WOTUS regulated under this program include fill for

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development, water resource projects, and infrastructure development. Section 404 requires a permit before dredged or fill material may be discharged into WOTUS (33 USC 1344).

EO 11990, Protection of Wetlands, requires federal agencies to minimize the destruction, loss, or degradation of wetlands, and to preserve and enhance the natural and beneficial values of wetlands. It also requires that agencies avoid construction in wetlands, to the extent practicable (44 CFR 26951).

Affected Environment

Floodplains The Omaha VAMC campus is not located within a known mapped floodplain or floodway (Federal Emergency Management Agency [FEMA] Panel 31055C0351H). FEMA indicates that the vicinity of the Omaha VAMC contains “no special flood hazard areas” (FEMA Panel 31055C0351H). The ESA is not adjacent or within close proximity to a known waterbody (FEMA 2005).

Wetlands The USFWS maintains a National Wetlands Inventory (NWI) that provides information on the characteristics, extent, and status of the nation’s wetlands and deep-water habitats (USFWS 2017b). According to this data, there are no wetlands or waters on Omaha VAMC grounds or adjacent the Omaha VAMC. During a site survey on October 20, 2017, wetland vegetation was observed in a stormwater detention basin on the eastern edge of the ESA near the Field Club Trail and parking lot (Figure 3-7). No other potential wetland areas were found during the site visit at the Omaha VAMC.

Environmental Consequences

3.9.3.1 No-Action Alternative Floodplains The No-Action Alternative would have no impact to floodplains. The Omaha VAMC campus is not located within a mapped floodplain or floodway (FEMA 2005), and is not adjacent or in close proximity to any surface waterbody.

Wetlands Under the No-Action Alternative, there would be no impact to wetlands. There would be no modification to any existing structures, no construction of new structures, and no excavation or fill activities that would potentially impact wetlands. Therefore, no impacts to wetlands would result from implementation of the No-Action Alternative.

3.9.3.2 Proposed Action Floodplains The Proposed Action would have no impact to floodplains. The Omaha VAMC campus is not located within a known floodplain or floodway (FEMA 2005) and is not adjacent or in close proximity to any surface waterbody.

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Figure 3-7. Omaha VAMC Wetland Map

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Wetlands The Proposed Action would not involve any dredge or fill activities in wetlands and would have no direct impact on federal or state jurisdictional waters. Pending coordination with United States Army Corps of Engineers (USACE) pursuant to Section 404 of the CWA, it is anticipated that the Proposed Action would likely be a “no permit required” activity (Appendix A).

Socioeconomic

Definition of the Resource

This section discusses social and economic aspects of the ESA and surrounding community, including population and employment, community facilities and characteristics, and the existing business climate.

Affected Environment

Population The VAMC is located within Omaha, Nebraska, in Douglas County. In 2010, Omaha had a population of 408,958 as of the 2010 U.S. Census (U.S. Census Bureau 2010). The median population age is 33.5 with 70.3 percent of the population aged 18 years and older. The 2010 U.S. Census Bureau showed that Omaha is a growing city with about 4.9 percent growth between 2000 and 2010, from 390,007 people to 408,958. The City's growth rate was below that of Douglas County (11.5 percent) and Nebraska (6.7 percent) (U.S. Census Bureau 2010 and 2000).

The 2015 American Community Survey (ACS) estimated a veteran population of 27,331. Approximately 34 percent of these veterans are Vietnam era veterans, 17.7 percent serving in the Gulf War from 1990 to 2001, and 14.3 percent serving in Gulf Wars after 2001. Approximately 91 percent of these veterans are male. An estimated 25 percent of veterans in the Omaha area have a disability (U.S. Census Bureau 2015).

Employment As of September 2017, the Omaha-Council Bluffs metropolitan statistical area alone provided a labor force of 470,565 workers, about 2.6 percent of which were unemployed; Douglas County's workforce was 291,657 with an unemployment rate of 2.7 percent. These unemployment rates are slightly higher than the Nebraska state average of 2.5 percent, but lower than the national average of 4.2 percent (Bureau of Labor Statistics 2017). Government provided the largest source of employment in the metropolitan area in 2010, with health care, social assistance and retail trade serving as the largest private employment sectors (Bureau of Economic Analysis 2017).

2010 Census data indicates that approximately 91.6 percent of the 177,510 housing units in the City of Omaha were occupied. Approximately 14,891 units were vacant. Of these vacant units, approximately 52.8 percent (7,862 units) were available for rent and roughly 13.0 percent (1,931 units) were available for sale.

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Health and Safety The Omaha Police Department provides crime prevention, law enforcement, and public safety services for the areas surrounding the Omaha VAMC. The city has four police precincts and 73 patrol districts: Northeast Precinct at 30th and Taylor, Northwest Precinct at 103rd Street north of Fort Street, Southeast Precinct at 25th and Vinton, and Southwest Precinct at 99th and M Street. The Omaha VAMC is within the Southeast Precinct, which has 17 patrol districts (Omaha Police 2017).

The Omaha Fire Department (OFD) has 24 fire stations throughout Omaha, providing fire prevention education, emergency medical response coordination, hazardous materials response, and a mass casualty decontamination services. In addition to performing normal duties of truck and engine companies, the OFD also responds to high angle rescue, confined space rescue, and trench rescue (OFD 2017). The Fire Department Emergency Medical Services Bureau Chief coordinates medic unit response with all Class II emergency rooms and their medical directors. Medic units, along with Emergency Response Teams Airworthiness Directive and Advanced Life Support engine companies, are manned on a 24-hour basis. Additional responsibilities include all administrative, equipment, liaison and training functions. This bureau also oversees the Department's Infectious Disease Control program (OFD 2017).

Within the Greater Omaha area, there are 15 hospitals including Nebraska’s only Children’s Hospital and Medical Center. The University of Nebraska Medical Center (UNMC) is a research facility with programs in bioterrorism response, cancer research and transplantation. Catholic Health initiatives (CHI) has five locations in the metropolitan area, and Methodist Health System has several facilities. The City of Council Bluffs has two, full-service hospitals – CHI Mercy Council Bluffs and Jennie Edmundson Hospital, as well as numerous specialized clinics (Greater Omaha Area Economic Development Partnership 2017).

The Omaha VAMC exclusively serves the Omaha and Council Bluff’s Veteran community’s medical needs. The VA Health Care System also operates seven clinics located in Bellevue, Lincoln, Grand Island, Holdrege, Norfolk, North Platte, and O’Neill, Nebraska, and another clinic located in Shenandoah, Iowa. These clinics offer a variety of services ranging from primary care, limited specialty care, mental health services, laboratory work, prescriptions, and optometry services. Most specialty care providers at these clinics refer patients to the Omaha VAMC. The Omaha VAMC is the only center with a full-service hospital located between Denver, Colorado; Des Moines, Iowa; Sioux Falls, South Dakota; and Leavenworth, Kansas. The Omaha VAMC does not have a full-service emergency room and relies on the UNMC.

Environmental Consequences

3.10.3.1 No-Action Alternative The No-Action Alternative would have no significant impacts on social cohesion, economic vitality or opportunities. There would be no change to the community services provided by the Omaha VAMC from the existing conditions under implementation of the No-Action Alternative. Ambulatory Care functions would remain scattered throughout the main hospital building. Under the No-Action

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Alternative, spaces would remain fragmented and unsuitably configured for patient flow, staff efficiency, and sharing of equipment and services.

However, the No-Action Alternative would likely result in increased delay and inefficiencies of care for the veteran community. The existing facility at the Omaha VAMC is incompatible with the PHMC and PACT models of care and would continue to limit patient care and satisfaction. Limited patient care and satisfaction would likely contribute to a limited quality of life for the veteran community and may impact the veteran community’s ability to contribute to the economic vitality of the Greater Omaha area.

Police and fire emergency service would not change in relation to the No-Action Alternative. Omaha Police and Fire Departments would be expected to serve the community in the same manner.

3.10.3.2 Proposed Action Project construction would have a minor short-term beneficial impact on the economy and employment in Omaha due to temporary employment of local and/or out-of-state construction contractors. Impacts to emergency services such as fire and police response may need to be mitigated for during construction of the ACC’s associated walkway and closure of Puller Drive. After construction, emergency services would likely access the primary Omaha VAMC facility via a reconstructed access point on Puller Drive.

Long-term impacts of the Proposed Action would be beneficial, allowing for compliance with the VA preferred models of care and addressing space deficiencies identified for Ambulatory Care at the Omaha VAMC. Construction of the ACC would result in a beneficial impact to the overall functionality of the Omaha VAMC by consolidating ACC services and creating better intra-service relationships. Construction of the ACC would allow the Omaha VAMC to provide PHMC and PACT models of care and would likely increase patient satisfaction. Increased patient care and satisfaction would likely contribute to an enhanced quality of life for the veteran community. An increased quality of life would likely increase the veteran community’s ability to contribute to the economic vitality of the Greater Omaha area.

No reduction of services provided by the Omaha VAMC would result from implementation of the Proposed Action. Alternatively, construction of the ACC would enhance the community services provided by the Omaha VAMC, as well as increase the efficiency of these services.

No change is expected to police and fire services provided to the Omaha VAMC and surrounding community due to construction of the Proposed Action. During construction, the Omaha VAMC should coordinate with these service providers to make them aware of potential access changes due to construction and the closure of Puller Drive after construction.

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Transportation and Parking

Definition of the Resource

Transportation is the movement of people and goods from one location to another. The field can be divided into:

• Infrastructure – the fixed installations necessary for transport, such as roads, railways, airways, waterways, canals, pipelines, and terminals (airports, railway stations, bus stations, warehouses, trucking terminals, etc). Terminals may be used for both the interchange of passengers and cargo and for maintenance.

• Vehicles – automobiles, bicycles, buses, trains, trucks, people, helicopters, and aircraft.

• Operations – the manner in which vehicles are operated, and the procedures set for this purpose including financing, legalities, and policies. In the transport industry, operations and ownership of infrastructure can be either public or private, depending on the country and mode.

Parking is the act of stopping or standing of a vehicle whether occupied or not. Parking infrastructure is constructed in combination with most major and minor destinations, to facilitate the coming and going of the destination’s users.

Affected Environment

The Omaha VAMC is served by a road system accessed via Woolworth Avenue from the north and Center Street from the south. The road system consists of Puller Drive, Nimitz Drive, Eisenhower Drive, and Waesche Drive. Currently, there are approximately 1,234 parking spaces available to staff and patients. However, there are over 1,400 employees (shifts excluded), 60 occupied beds, and an average of 660 outpatient visits per day, which indicates a deficiency of available parking spaces.

Currently, the Omaha Metro Bus System (OMetro) Route 3 accesses the property via Center Street on the south and Woolworth Avenue on the north and traverses the campus via Puller and Nimitz Drives. A bus stop is located at the main entrance of the existing Omaha VAMC hospital building. Route 3 runs south and north approximately twice per hour but only stops at the Omaha VAMC once an hour per direction, between the hours of 6:42am to 7:45pm on weekdays and 7:42am to 5:45pm on Saturdays. Route 3 does not stop at the Omaha VAMC on Sundays (OMetro 2017a).

Route 15 travels north and south adjacent to the site along 42nd Street and a bus stop is located on Route 15 at South 42nd Street and Center Street. Route 15 stops at South 42nd Street and Center Street running east and west at least three times an hour on weekdays between 5:11am to 6:56pm, with a stop once an hour from 7:11pm to 12:11am, until service resumes at 5:11am. On Saturdays, service to the bus stop at South 42nd Street and Center Street is provided running east and west between the hours of 6:11am to 11:03pm with a stop approximately every hour.

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Sunday services is provided running east and west between the hours of 7:41am to 8:41pm, with hourly stops (OMetro 2017b).

Figure 3-8 shows the existing OMetro Bus Routes 3 and 15 in relation to the Omaha VAMC.

Environmental Consequences

3.11.3.1 No-Action Alternative The No-Action Alternative would have no significant impacts to transportation or parking at the Omaha VAMC. The OMetro Bus Route 3 would be unchanged and would be expected to operate as it currently does on the Omaha VAMC campus. Parking deficiencies would increase as patient load grows as projected.

3.11.3.2 Proposed Action As currently planned, construction activities would result in the loss of approximately 550 parking spaces. Figure 3-9 shows the existing parking areas and areas to be impacted during and after construction of the ACC. This temporary loss could be mitigated by relocating construction staging areas to green spaces located between Puller and Waesche Drives to the extent possible. After construction, a net loss of 255 parking spaces is expected. This loss could be mitigated by implementing use of an off-site parking area within the vicinity of the Omaha VAMC. The Center Mall located south of Center Street provides surface and garage parking spaces. The net parking space loss is likely temporary as a separate parking structure is planned for construction in FY2021 that would provide an additional 380 parking spaces, providing for current and future parking needs.

There would be no permanent impacts to OMetro bus routes due to the Proposed Action. The Omaha VAMC would coordinate with OMetro to provide bus access during construction activities. After construction of the Proposed Action is complete, OMetro Route 3 would access the Omaha VAMC campus via Woolworth Avenue only and pull into the reconstructed roundabout at the main entrance to the Omaha VAMC main hospital building. Figure 3-10 shows the proposed Route 3 after construction is completed. There would be no change to service provided by Route 15 due to the Proposed Action.

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Figure 3-8. Current OMetro Bus Routes

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Figure 3-9. Parking Areas Impacted Due to the Proposed Action

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Figure 3-10. Proposed Future OMetro Route 3 Due to the Proposed Action

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Solid and Hazardous Materials

Definition of the Resource

The Resource Conservation and Recovery Act (RCRA) (42 USC 6901) created the framework for hazardous and non-hazardous waste management programs in the United States. Materials regulated by RCRA are known as “solid wastes.” Only materials that meet the definition of solid waste under RCRA can be classified as hazardous wastes, which are subject to additional regulation. EPA developed detailed regulations that define what materials qualify as solid wastes and hazardous wastes (EPA 2017c).

Solid Waste RCRA defines "solid waste" as any garbage or refuse, sludge from a wastewater treatment plant, water supply treatment plant, or air pollution control facility and other discarded material, resulting from industrial, commercial, mining, and agricultural operations. Solid waste is not limited to wastes that are physically solid. Many solid wastes are liquid, semi-solid, or contained gasses.

Hazardous Materials The terms “hazardous materials” and “hazardous waste” refer to substances defined as hazardous by Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and the Solid Waste Disposal Act (SWDA), as amended by the RCRA. In general, hazardous materials include substances that, because of their quantity, concentration, or physical, chemical, or infectious characteristics, may present substantial danger to public health or the environment when released into the environment.

Hazardous wastes that are regulated under RCRA are defined as any solid, liquid, contained gaseous, or semisolid waste, or any combination of wastes that either exhibit one or more of the hazardous characteristics of ignitability, corrosivity, toxicity, or reactivity, or are listed as a hazardous waste under 40 CFR 261.

Affected Environment

The Omaha VAMC is listed as a Small Quantity Generator (SQG) which is defined as generating more than 100 kilograms, but less than 1,000 kilograms of hazardous waste per month. As a SQG, the Omaha VAMC must comply with the hazardous waste regulations set forth in 40 CFR 262 regarding handling, management, containers, and site preparedness regarding hazardous waste. A licensed local contractor currently handles the removal and proper off-site disposal of solid waste, including potentially hazardous medical waste. The facility contains various hazardous materials, such as medical and biological wastes. These are managed and collected by Waste Management daily (Monday through Friday). Hazardous wastes are transported off-site and disposed of by a fully trained and licensed contractor.

According to the Environmental Data Resources (EDR) Radius Map Report (2017), there are two leaking underground storage tank (LUST) sites, one aboveground leaking storage tank (LAST) site, three operational underground storage tanks (USTs) located at the Omaha VAMC. The

59 Proposed Ambulatory Care Center Environmental Assessment NWIHCS Omaha VAMC December 2017 operations USTs consist of a 6,000-gallon diesel UST used for the standby diesel generator in the Auxiliary Power Building.

One of LUST sites is in the Auxiliary Power Building and listed as “backlogged – not yet investigated” by the EDR Radius Map Report (2017). A release of diesel fuel was discovered on January 21, 2003. The amount of the release was not included in the EDR Radius Map Report. A fuel oil release was discovered on September 3, 1998 and is listed as No Further Action (Incident Closed).

The LAST site was a diesel spill discovered on September 1, 2015. The site is listed as No Further Action (Incident Closed).

The Omaha VAMC contains a small, inactive, nuclear reactor that was once used for research purposes. However, the fuel from this reactor has been removed and a remediation plan is in process.

The Omaha VAMC is located within the boundaries of the Omaha Lead Superfund Site. This site consists of approximately 15,000 residential properties, within a 27 square-mile boundary in the eastern portion of the Omaha metropolitan area. However, this superfund site does not include either the Omaha Central Business District, the Omaha VAMC, or any other nonresidential properties in the boundary area.

The complete EDR Radius Map Report (2017) is provided in Appendix B.

Environmental Consequences

3.12.3.1 No-Action Alternative Under the No-Action Alternative, waste generation, collection, and disposal would continue according to current practices. Waste would continue to be generated at the site as predicted, and hazardous materials present at the site would remain at the site. There would be no impact to either waste management or hazardous materials management from this alternative.

3.12.3.2 Proposed Action Solid Waste The Proposed Action would require the handling of construction material and disposal of wastes from construction activities, which would affect waste management resources in the area. The following waste types are anticipated to increase during implementation of the Proposed Action:

• Solid waste (office wastes, material packaging, glass, etc.); and • Construction and demolition solid wastes (concrete, steel, lumber, etc.)

Construction debris primarily comprised of wood, metal, and asphalt would be the typical waste expected to be generated during the various construction projects. This solid waste would be disposed of either at the local landfill or at another appropriate municipal solid waste landfill.

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Additionally, the project would generate excess soil from excavation activities. This soil would be stockpiled at an approved material management area for future use.

Solid waste generated during the operation of the new ACC would be disposed of at the local landfill or other appropriate solid waste landfill. The amount of waste generated during operation of the new ACC would not be expected to increase substantially from current volumes forecasted for the Omaha VAMC. All solid waste would be disposed of appropriately as required by RCRA Solid Waste regulations.

Hazardous Waste Construction activities associates with the Proposed Action, are not expected to generate hazardous wastes. Spills from construction related activities could cause hazardous materials to be released to the storm sewer system. These may include solvents, oil, grease, gasoline, caulk, paint, or hydraulic fluids. Any spills from construction-related activities would be cleaned up with absorbent blankets and storage containers in a timely manner to minimize the potential for overland flow into the storm water.

Construction activities would not be expected to impact known releases from LUST sites located on the Omaha VAMC. If contaminated soils and/or water or hazardous materials are encountered, then all work within the immediate area of the discovered hazardous material would stop until VA, NDEQ, and appropriate agencies could be notified and a plan to dispose of the hazardous materials has been developed.

Operation of the new ACC is expected to produce additional biomedical waste materials; however, this would not be expected to increase substantially from current volumes forecasted for the Omaha VAMC. Biomedical waste would be managed according to current Omaha VAMC procedures.

Utilities

Definition of the Resource

Utilities refer to the set of services provided by public utility organizations consumed by the public, such as electricity, natural gas, water, sewage, and telephone services.

Affected Environment

Water The Omaha Metropolitan Utilities District (MUD) is the sole water provider for the Omaha VAMC. There are three connections to the existing water distribution system: one connection to an existing 8-inch line at the intersection of South 42nd Street and Woolworth Avenue; another connection to an existing 42-inch line in Woolworth Avenue approximately 1,000 feet east of the South 42nd Street intersection; and a connection to a 6-inchline that is approximately mid-block at Center Street. In addition, the Omaha VAMC campus is linked by two separate distribution systems to ensure that if one section were shut down, there are alternative sources to maintain

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water service to the site. Main water lines are original and most likely cast iron or transite piping. A single 8-inch and 10-inch distribution system provides both the potable and fire water service for the Omaha VAMC campus. Previously, the main hospital building contained a water storage facility capable of providing fire flows or four days of emergency water supply. This facility is currently not functional.

The storm sewer and sanitary sewer systems are currently interconnected. Both systems appear to be constructed around 1950. Stormwater catch basins and inlets are original. The stormwater system is in fair condition and appears to adequately drain the Omaha VAMC campus. Sanitary sewers are likely constructed from vitrified clay pipe (VCP), though not substantiated. The City of Omaha, by federal mandate, is implementing a citywide project to separate these two systems.

Steam Generation Steam generation is accomplished on site. The system appears to be in good condition and has been updated over the years. Though the boilers are beyond their useful lifespan, their condition warrants continued use. The condensate receiver tanks and pumps are the exception and are original system components, which require replacement. The other systems within the plant range from fair to excellent condition. The site energy systems, tanks, pipes, and tunnel systems are in good to average condition.

Electrical Systems The site electrical distribution system at the Omaha VAMC is served by the local electrical utility, Omaha Public Power District (OPPD). The site electrical system is generally less than 20 years old and has sufficient capacity to serve existing and future loads. Much of the Omaha VAMC campus electrical distribution systems are in acceptable condition for their age, with the expected deficiencies in branch circuit capacity, mainly affecting the main hospital building. Emergency power is the single largest deficiency at the Omaha VAMC campus, as the hospital and clinical functions are not adequately served by generator sources. Much of the fluorescent lighting in most buildings is recommended to be upgraded to more energy-efficient lamps and ballasts. The fire alarm systems are typically in acceptable condition, though some outbuildings lack fire alarm systems entirely.

Technology Systems There is adequate telephone service from the local utility, Cox Communications. The telecommunications systems in renovated buildings have been implemented in a professional manner and reflect current industry standards and practices. Older areas of the facility, where numerous systems have been layered, have reached capacity and are encumbered by the not removing abandoned systems or cabling.

Environmental Consequences

3.13.3.1 No-Action Alternative The site water and sewer systems at the Omaha VAMC campus are aging and due for replacement. Under the No-Action Alternative, the onsite water storage needed to meet Physical

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Security and Life Safety requirements (four-day supply) would continue to not be met. In addition, under this alternative, the Omaha VAMC campus would continue to experience a deficiency in emergency power. The hospital and clinical functions would continue to not be adequately served by generator sources. Under the No-Action Alternative, the plumbing systems that are original to the 1950 construction and are in poor condition, as well as the outdated technology systems would remain at the VAMC. Therefore, implementing the No-Action Alternative would continue the adverse condition of the utility systems at the VAMC.

3.13.3.2 Proposed Action Under the Proposed Action, construction of the new ACC would increase the load upon existing infrastructure and utilities, including electricity, potable water, and sanitary sewer; however, potential impacts to existing utilities would be minimal.

The City of Omaha is under a federal mandate to separate their storm flow from the sanitary sewer flow. As a result, any new construction at the Omaha VAMC must consider this criterion during the design process and adhere to City of Omaha guidelines for stormwater detention and sanitary design. Under the Proposed Action, approximately 700 feet of storm sewer would be removed and relocated to accommodate the construction of the new ACC. New storm sewer would be constructed starting at the existing entrance of the main hospital building, extending north and east just outside of the proposed footprint of the new ACC, and discharging into the existing holding pond located on the eastern edge of the property. New sanitary sewer would also be constructed on the eastern side of the new ACC. The new sanitary sewer would include an extension running north from the new ACC to accommodate future connections and expansion (see Figure 3-11).

The Proposed Action would require removing approximately 350 total feet of water line at two locations: (1) near the front entrance of the main hospital building to accommodate construction connector between the main hospital building and the new ACC, and (2) east of the new ACC to accommodate a utility yard. To account for these removals, approximately 900 feet of new 10- inch water lines would be installed. Approximately 640 feet of water line would be constructed just south of Woolworth Avenue providing a bridge between the two MUD water main connections on the north side of the Omaha VAMC campus. This connection would provide redundant connections to the MUD water main system, decreasing the chances of a service disruption. Additional water line would be constructed east of the proposed ACC. This water line would serve as the primary connection of the ACC to the Omaha VAMC campus water distribution system (see Figure 3-12).

The new ACC would include new IT, phone, emergency and fire suppression systems, water systems, HVAC, and lighting. The new ACC would be constructed according to modern medical facility standards. The new ACC would include a 750kW emergency generator to provide power during local utility outages.

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Figure 3-11. Proposed Sanitary and Storm Sewer Improvements Due to the Proposed Action

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Map showing existing and future water supply infrastructure at the Omaha VAMC main campus.

Figure 3-12. Proposed Water Supply Improvements Due to the Proposed Action

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Environmental Justice

Definition of the Resource

According to the EPA’s Office of Environmental Justice, environmental justice is defined as follows:

“Environmental Justice is the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies. EPA has this goal for all communities and persons across this Nation. It will be achieved when everyone enjoys the same degree of protection from environmental and health hazards and equal access to the decision- making process to have a healthy environment in which to live, learn, and work.”

In 1994, EO 12898 - Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations, was issued. This EO requires that federal agencies make achieving environmental justice part of their mission. In addition, the EPA has identified environmental justice as a key priority. EO 12898 was issued to ensure the fair treatment of all individuals, regardless of their race, national origin, or income, with respect to the development and enforcement of environmental laws, regulations, and policies.

Affected Environment

To adequately evaluate environmental justice issues, information on race and poverty characteristics was obtained. Information was also gathered on the veteran population due to this demographic being the primary Omaha VAMC audience. This information can be found for Census Tract 003800 including the Omaha VAMC and surrounding neighborhoods, Douglas County, and the state of Nebraska in Table 3-5.

Table 3-5. Race and Poverty Characteristics Census Tract Characteristics Nebraska Douglas County 003800 Total Population 1,826,341 517,110 4,203 % White 82.2% 72.1% 68.9% % Black or African American 4.5% 11.6% 15.8% % American Indian, Eskimo, or Aleut 0.8% 0.5% 0.03% % Asian 1.8% 2.7% 5.7% % Native Hawaiian and Other Pacific Islander 0.1% 0.1% 0.1% % Hispanic or Latino 9.2% 11.2% 26.9% % Other 0.1% 0.1% 7.2% % Two or More Races 1.5% 2.0% 2.11% % Families Below Poverty 7.9% 9.4% 25.52% Median Household Income $49,342 $51,878 $27,079 Veteran Population 132,918 32,803 297

Source: U.S. Census Bureau (2000, 2010) and ACS (2015)

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The community near the Omaha VAMC has a higher proportion of minority populations and families living in poverty as compared to Douglas County and the State of Nebraska. The local community also has a lower median household income when compared to both county and state- wide data.

Environmental Consequences

3.14.3.1 No-Action Alternative Under the No-Action Alternative, no negative or positive impacts to low income and minority populations would result.

3.14.3.2 Proposed Action Adverse environmental justice impacts would mean a disproportionately high and negative human health or environmental effect on minority and low-income populations. Table 3-6 provides an environmental impact checklist for some of the more common social concerns that could result from the Proposed Action.

Table 3-6. Common Social Concerns Potentially Affected by the Proposed Action

Social Concern Potential Effect Comments Impacts to minority and low-income There would be no impacts to No populations minority or low-income populations Changes in ethnic or racial There would be no changes to No composition ethnic or racial composition Influx or outflow of temporary Positive effect on the local Positive Effect workers economy. Job creation. Community disruption or Construction will have a temporary Negative minimal to minor disintegration increase in noise and traffic Changes in land use patters No Land use will not change

Changes in lifestyle No Lifestyle will not change There would be no changes in Changes in social interactions, No social interactions, family ties, or family ties, kinship patters kinship patters. Displacement / relocation of No business will be relocated or No businesses displaced. Changes in the ability to provide and Positive Effect Omaha VAMC services improved deliver social services Construction activities are not Changes in aesthetics or perceived Temporary negative minimal to aesthetically pleasing. Minor environmental quality minor negative effects from dust and noise. Changes in public health, safety, or No changes to public health or No perceived well-being safety No community facilities would be Displacement of community facilities No displaced Construction and demolition projects Changes in public vehicular access Negative minimal to minor may require temporary detours

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Social Concern Potential Effect Comments Construction and demolition projects Negative minimal to minor during Changes in public pedestrian may require temporary detours. construction. Overall positive access Project will improve pedestrian effects. facilities. ADA compliant. The Field Club Trail would not be Changes in recreation No impacted No changes to leisure-time activities Changes in leisure-time activities No would result. Temporary positive effect on local economy during construction Changes in local employment Positive Effect process. Omaha VAMC expansion opportunities may provide additional permanent employment opportunities. Temporary positive effect on local Changes in community tax base Positive Effect economy There would be no changes in Changes in commerce, recreation, No commerce, recreation, or related or related services services

There would be no adverse impacts to environmental justice under implementation of the Proposed Action. Minor short-term impacts may occur during construction; however, the new ACC would benefit the overall community potentially providing additional employment and overall improved Omaha VA services.

Cumulative Impacts and Past, Present, and Reasonably Foreseeable Future Actions

In compliance with the NEPA and CEQ regulations, potential secondary and cumulative impacts on the environment were assessed for the Proposed Action. This analysis was performed using existing, readily available data. These regulations require the discussion of cumulative impacts include a list of past, present, and reasonably foreseeable anticipated future projects producing related or cumulative impacts. The discussions of cumulative impacts should consider the likelihood that impacts would occur and reflect the severity of the anticipated impacts.

According to NEPA, secondary (indirect) impacts are those that are "caused by an action and are later in time or farther removed in distance but are still reasonably foreseeable" (40 CFR 1508.8). Generally, these impacts are induced by the initial action.

Cumulative impacts are impacts that result from the incremental consequences of an action when added to other past and reasonably foreseeable future actions, regardless of which agency (federal or non-federal) or person undertakes such other actions. Cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time (40 CFR 1508.7).

A reasonably foreseeable future action is a potential future action used to help predict impacts. The reasonably foreseeable future actions are not actual allocations or decisions and are not speculative, but they are likely to occur based on reliable sources.

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When taken in consideration with other ongoing and proposed construction projects near the Omaha VAMC, minor impacts are anticipated for aesthetics; air quality; geology and soils; hydrology and water quality; noise; and socioeconomics including transportation and parking, because of the implementation of the Proposed Action

Past, Present, and Reasonably Foreseeable Future Actions

Past, present, and future actions expected to directly or indirectly affect resources in the vicinity of the Proposed Action are listed below:

3.15.1.1 Past Actions • Residential and commercial redevelopment has occurred north of the Omaha VAMC in the area known as “The Blackstone” (roughly 36th Street to 42nd Street along Farnam Street) since 2014. • Commercial and industrial development has occurred on the UNMC’s campus including completion of the Buffet Cancer Center in 2017. The UNMC has obtained numerous facilities along the Leavenworth Street corridor from approximately 42nd Street to 38th Street and has demolished and redeveloped facilities in the area. • Farnam Street between 36th and 42nd Streets was converted from a one-way to a two- way roadway in 2014.

3.15.1.2 Present Actions Known actions currently underway in the vicinity of the Proposed Action include continued work on the UNMC’s campus, additional commercial and residential redevelopment work in the Blackstone, Park Avenue, and Midtown neighborhoods of Omaha, and minor road projects throughout eastern Omaha.

3.15.1.3 Future Actions Transportation Projects Transportation projects forecast from 2017 continue to reflect the city’s desire to improve service in older sections of Omaha, largely east of 72nd Street, but also indicate a shift in emphasis designed to keep up with needs in the growing western areas of the city. Projects in the western half (west of 72nd Street) of the city are generally intended to improve capacity and safety. Streets that are in poor condition in the eastern part of the city are typically resurfaced unless it is more cost effective to reconstruct them.

Reasonably foreseeable future transportation projects likely to occur during the construction of the Proposed Action within a two-mile radius of the Omaha VAMC are described in Table 3-7:

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Table 3-7. Reasonably Foreseeable Future Transportation Projects Within Two Miles of the Omaha VAMC Campus Planned Location Construction Description Year This project includes grading, drainage, widening of I-80 pavement in both directions, lengthening the 16th Street I-80 Omaha: Bridge, and rebuilding the ramps/loops in the 13th Street 24th St. to 13th St. 2018 - 2020 interchange. All of the on and off-ramps/loops in the 13th Street Interchange interchange will be rebuilt and I-80 mainline lanes expanded by one or two lanes. 24th Street Interstate 2018 Bridge repair and overlay on the 24th Street Bridge over I-80. Bridge Q Street Bridge 2018 Replacement of existing bridge between 26th and 27 Streets Implementation of a high-capacity bus rapid transit service along Omaha Bus Rapid Transit 2018 the Dodge Street corridor from approximately the Westroads Transit Center to downtown Omaha. Reduce 24th Street from 4-lanes to 3-lanes between 24th Street Road Diet 2019 L Street to Leavenworth Street Reduce 30th Street from 4-lanes to 3-lanes between Cuming 30th Street Road Diet 2019 Street to Ames Avenue Concrete repair and asphalt resurfacing on Northwest Radial N-64 Concrete Repair 2019 Highway (N-64) from Military Avenue to Cuming Street Bridge repair and approach work, bridge painting, and I-80/I-480 Bridges 2019 mechanically stabilized earth wall I-480: 20th Street - Bridge repair and overlay on westbound and eastbound I-480 2020 and 2021 Missouri River Bridges from 20th Street to the Missouri River

Metropolitan Area Planning Agency (MAPA) 2016

Development Projects Known future development projects include additional redevelopment in the Blackstone and Midtown Neighborhoods, redevelopment of the Steel Castings area located near Saddle Creek Road and Farnam Street by the University of Nebraska Medical Center, and a $10M renovation of Williams Science Hall at UNMC.

Future VA Projects at the Omaha VAMC Future planned projects at the Omaha VAMC include a Fisher House, veteran housing, staff and visitor parking garages, and an additional health care facility. The Fisher House is a comfort home where military and veterans’ families can stay at no cost while a loved one is receiving treatment. Future planned projects at the Omaha VAMC and their locations are illustrated in Figure 2-3.

Cumulative Impacts

Past, present, and reasonably foreseeable future actions described above would not impact the Proposed Action. Development in the Blackstone, Midtown, and Park Avenue neighborhoods are part of a growing trend of redevelopment in east Omaha that has been occurring over the past several years. Redevelopment in these areas would not impact activities on the Omaha VAMC campus. Transportation projects described above are part of on-going maintenance and repair

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and are not construction of new road systems. These projects are to be expected for aging infrastructure in the eastern part of Omaha. This redevelopment is expected to increase the efficiency and cohesiveness of existing transportation networks around the Omaha VAMC. The implementation of the Omaha Bus Rapid Transit system will improve connections, reduce roadway congestion, reduce travel times for existing riders, and ideally promote additional redevelopment and infill of services along the Omaha Bus Rapid Transit system network.

When combined with planned future actions for the Omaha VAMC, the new ACC will improve the aesthetics and land use at the Omaha VAMC by enhancing the connection to main hospital building, improving parking areas, and develop a denser campus that will improve cohesion between facilities and improve services offered by the Omaha VAMC. These combined actions will improve the quality of service provided to users of the Omaha VAMC which would provide a beneficial impact to the socioeconomics of Omaha VAMC staff and patients. Improved facilities would likely lead to an increase in job satisfaction for Omaha VAMC staff. Improved quality of care would likely provide a beneficial impact to Omaha VAMC patients and may result in an improved quality of life for the Omaha VAMC patient community.

Phasing of the planned future actions for the Omaha VAMC would not result in negative cumulative impacts for the area. Strategic implementation of projects as funding becomes available will lead to staggered, temporary construction related impacts to resources such as aesthetics, air quality, noise, traffic, and construction impacts. These impacts would be expected to be resolved upon the completion of each construction project.

Secondary Impacts

The CEQ definition states indirect (or secondary) impacts "may include growth-inducing effects and other effects related 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" (40 CFR 1508.8).

The key consideration is whether the project would encourage growth in the context of the Omaha VAMC’s plans and growth patterns. With respect to indirect growth-inducing impacts, the Proposed Action – construction of the ACC – would not create the need for any new community service or facilities and would fulfill an identified need for the Omaha VAMC. Growth and development beyond the Omaha VAMC campus is already anticipated, expected to occur independent of the project, and is not contingent upon growth within the Omaha VAMC campus. The Proposed Action would serve the existing community and is not anticipated to accelerate the current rate of population growth or development within the region.

Conclusion

Based on the above evaluation of potential impacts from the Proposed Action and in consideration of other past, present, and reasonably foreseeable projects potentially affecting the same resources and area, no significant secondary or cumulative impacts are anticipated as a result of the Proposed Action.

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Potential for Generating Substantial Controversy

This EA will serve as an instrument for public and agency comment during the project planning and review period, and feedback will be reviewed for final determination of potential for generating substantial controversy and incorporated into the Final EA.

The proposed action would be funded via the CHIP IN for Veterans Act of 2016, which allows the VA to accept donations for facilities at no additional cost to the federal government. This unique public-private partnership includes a significant private investment accounting for approximately 35% of the total project cost. The CHIP IN for Veterans Act of 2016 provides a unique and effective mechanism to maximize the effectiveness of limited public funds to meet the project purpose and need.

The proposed action would not require an expansion of the existing Omaha VAMC campus and is not expected to result in impacts to adjacent properties. The ACC facility would be constructed in an existing paved area with no lasting negative impact to the surrounding environment, as detailed throughout this EA document. Overall, construction of the new ACC is expected to provide a benefit to the community at large. An increase in services and patient capacity will not just benefit the VA community, but will help to limit or prevent patient overflow to other VA and non-VA medical facilities, potentially increasing the quality and availability of care for the general public.

A formerly proposed action, analyzed under the NEPA process in 2012 would have resulted in the construction of an entirely new and redesigned Omaha VAMC campus and the subsequent demolishment of the original Omaha VAMC hospital. This previously proposed action was widely supported by the Omaha VA community, bipartisan representatives, as well as local stakeholders and did not generate substantial controversy. Construction of a new ACC as proposed within this EA, is smaller in both size and scope compared to the proposed action as presented in 2012, and is expected to garner similar overall support.

Based on the reasons detailed above, substantial controversy is not expected to occur from the proposed action presented in this EA.

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4.0 Public Involvement

Opportunities were provided for the public and other stakeholders to be involved in the identification of social, economic, and environmental impacts associated with the project. The intent of the public involvement process was to identify the project scope, educate the public and other stakeholders regarding the project need and proposed solutions, incorporate public comments to evaluate and refine the project, and achieve consensus among affected parties.

The development of this EA included coordination and consultation with appropriate local, state, and federal agencies based on the potential impacts from the Proposed Action and the permits and approvals necessary for implementation. Letters describing the Proposed Action were mailed to various federal, state, and local agencies to solicit comments and feedback on the project. Letters were mailed to following agencies on September 14, 2017:

• EPA • USFWS • USACE • NDEQ • NGPC • SHPO • THPO – Sac and Fox Nation of Missouri in Kansas and Nebraska • THPO – Omaha Tribe • THPO – Santee Sioux Nation • THPO – Ponca Tribe of Nebraska • THPO – Winnebago Tribe of Nebraska • THPO – Iowa tribe of Kansas and Nebraska

The letters and responses are included in this EA as Appendix A.

An initial Notice of Intent (NOI) announcing the preparing of the Draft EA was published in the Omaha World-Herald on September 15, 2017 (Appendix C).

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5.0 Mitigation

In compliance with applicable federal, state, and local legislation, as well as any general or special conditions required by pending permits, mitigation measures have been incorporated into the project as needed based upon specific activities associated with the Proposed Action. As defined in Section 1508.20 of the CEQ regulations, the proposed mitigation measures have been designed to:

• Avoid the impact altogether by not taking a certain action or parts of an action, • Minimize impacts by limiting the degree or magnitude of the action and its implementation, • Rectify the impact by repairing, rehabilitating, or restoring the affected environment, • Reduce or eliminate the impact over time by preservation and maintenance operations during the life of the action, or • Compensate for the impact by replacing or providing substitute resources or environments.

Future actions proposed as part of this project would employ the following mitigation measures to ensure that environmental impacts from the Proposed Action are minimized to the greatest extent practicable. Adherence to the following mitigation measures, in conjunction with all applicable and appropriate local, state, and federal regulations and permit conditions, would ensure that the environmental impacts resulting from the Proposed Action are minimized to the greatest extent feasible.

The mitigation measures are presented in association with the resource(s) for which they are most directly associated. Although some of the listed mitigation measures apply to multiple resources, they may only be listed once.

Aesthetics The Proposed Action may cause temporary impacts to aesthetics on the Omaha VAMC campus due to site preparation, demolition, and construction activities. The following mitigation measure is recommended:

• Construction zones would be fenced and screened from the public, including Omaha VAMC patients and staff, as necessary. • Disturbed areas would be revegetated and landscaped as soon as feasible following construction.

Air Quality The Proposed Action would likely cause short-term and localized impacts to air quality due to construction and operation of the new ACC. No permanent or long-term impacts to air quality are anticipated.

The contractor would employ BMPs to control dust and other fugitive emissions during construction. These measures include, but are not limited to:

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• Machinery and other construction vehicle engines would not be left to idle unnecessarily, in accordance with state or local regulations. • An adequate and readily available water source would be available prior to the start of construction, demolition, or grading activities. Water misting or sprays will be used as required if particularly dusty activities are necessary during dry or windy periods. • Haul roads would be kept wet. Water would also be applied to exposed soil during grading and to waste materials during demolition activities. • Work site roads would be cleaned regularly and maintained, unsurfaced roads would be restricted to essential construction traffic only, and vehicles exiting the site would be cleaned as needed making use of wheel wash facilities. Soil that is deposited on nearby paved roads by vehicles would be removed from the roads and returned to the site or to an appropriate disposal area. • Construction would be phased to minimize concurrent dust-generating activities. • On-site construction traffic routes would be centralized within the work zone. • Bare areas, including slopes, starting from the initial grading phase would be rapidly reseeded and landscaped. • Material handling systems and site stockpiling of materials would be designed and laid out to minimize exposure to wind. • The VA would acquire the appropriate state and local permits required for the installation and use of the emergency generator and/or incinerator.

Cultural Resources Impacts to Cultural Resources are not anticipated due to the Proposed Action; however, the following mitigation measures apply:

• On-site personnel should closely monitor mechanical excavation of soils, and any other ground disturbing activities that may occur, for cultural materials that might be revealed or unearthed throughout the course of construction. • Should artifacts or human remains be discovered due to the Proposed Action, work would be immediately halted and remains left in place in accordance with Standard VA Construction Policy. The Nebraska SHPO, THPO, and appropriate authorities would be immediately notified to re-initiate the Section 106 and tribal consultation process. In coordination with the Nebraska SHPO and THPO, the services of a professional archaeologist would likely be retained to evaluate the findings prior to commencing work.

Geology and Soils The Proposed Action is not expected to impact geology or soil resources. BMPs would be applied to any construction activity that would remove vegetation or cause soil disturbance as outlined in an erosion and sediment control plan and SWPP. BMPs include:

• Application of erosion and sediment control measures such as silt fences, straw bales, and other temporary measures to be placed in low-lying areas and along portions of the site perimeter. These measures would be applied to control erosion and trap transported

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sediments onsite during activities that could cause soil to be exposed and displaced. Erosion and sediment control measures would be inspected on a regular schedule, as well as after any storm event. • All disturbed areas would be stabilized and re-vegetated with native plant vegetation following commencement of project implementation activities. Proper seed selection would result in native plants with deep root systems, which would stabilize soils, foster greater infiltration, and reduce runoff from the site. • All fuels would be stored and maintained in a designated equipment staging area to reduce the potential for soil contamination. A person(s) would be designated as being responsible for equipment fueling, who closely monitors the fueling operation and has an emergency spill kit containing absorption pads, absorbent material, a shovel or rake, and other cleanup items readily available onsite in the event of an accidental spill. • National Pollution Discharge Elimination System (NPDES) Construction Storm Water (CSW) permit would be obtained prior to construction if required.

Hydrology and Water Quality The Proposed Action is not expected to impact hydrology or water quality.

• NPDES permits would be obtained prior to construction and operation of the new ACC if required based upon expected stormwater or wastewater loads. Construction and operation activities would comply with all permit conditions. NOIs for NPDES general permit coverages would be submitted at least 30 days before the discharge is to occur. • A SWPP would be prepared and implemented prior to initiating any site-disturbing activities if required by the City of Omaha. Erosion and sediment control measures implemented during construction activities are also required to comply with SWPP rules. • Spills from construction activity that may infiltrate the soil, although unlikely, could degrade groundwater quality. If such a spill should occur, the affected area should be attended to immediately and the soil would be removed and disposed of according to NDEQ guidelines and other permit requirements.

Wildlife, Habitat, and Threatened and Endangered Species The Proposed Action is not expected to impact wildlife, habitat, or threatened and endangered species with implementation of the following mitigation measures:

• Before construction begins, existing features such as trees, walls, and hedges, which are to be retained, will be identified in the contract documentation (specifications) and strict instructions issued so that they are protected during the construction process. Special regard would be given to mature trees that do not have to be removed as part of the project and they would receive protection. In the event of accidental damage to a tree, proper remedial measures would be taken to minimize the damage and ensure the survival of the tree. Following completion of construction activities, all disturbed areas would be reseeded or re-vegetated and erosion control BMPs would be maintained until the vegetation is fully reestablished.

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• The contractor would control the growth and spread of weeds on the project site. The application of herbicides would be allowed according to manufacturer’s recommendation. Herbicides would not be applied within the vicinity of known wetlands, waterbodies, or streams. • Tree removal would be conducted outside the maternity roosting season for the northern long-eared bat (June 1 to July 31) and the migratory bird nesting season (April 1 to July 15). If tree removal cannot be avoided during the times, surveys would be conducted by a qualified biologist to determine if these species are present. If found, construction activities would cease and consultation with the USFWS and NGPC would be initiated to determine the appropriate course of action.

Noise Implementation of the Proposed Action may cause a temporary increase in localized noise generated during construction of the new ACC and associated facilities. The following mitigation measures would be implemented as needed:

• Enclosures, temporary noise barriers, noise dampening maps, and other similar methods would be used to shield construction noise. • Construction staging activities and access roads would be isolated and located as far from noise sensitive areas as feasible. • Noisy equipment would be replaced when possible. • Construction activities would be scheduled to avoid sensitive times of the day as per City of Omaha ordinance. Operation of any pile driver, steam shovel, pneumatic hammer, derrick, steam or electric hoist or other appliance causing loud or unusual noise would not be allowed between the hours of 10:00pm and 7:00am. • Workers would use hearing protection equipment when needed.

Land Use • No proposed mitigation

Floodplains and Wetlands • No proposed mitigation

Socioeconomic The Proposed Action would have minor and temporary socioeconomic impacts. The following mitigation measures would be implemented as needed:

• Temporary parking losses would be mitigated by implementing use of an off-site parking area and providing a shuttle service to the Omaha VAMC. The Omaha VAMC would also secure additional surface and garage parking at the Center Mall located south of Center Street as available.

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• The Omaha VAMC would coordinate with OMetro to maintain bus access during construction activities, and work to finalize the revised OMetro Route 3 bus route and schedule, to ensure continued service during and after construction activities.

Solid and Hazardous Materials The Proposed Action would not result in impacts due to solid or hazardous waste with the implementation of the following mitigation measures:

• Solid waste would be disposed of either at the local landfill or at another appropriate municipal solid waste landfill. Materials would be recycled and/or reused during building construction or demolition activities, to minimize the amount of waste generated by the project if feasible • Excess soil would be stockpiled at an approved material management area for future use. • Solid waste generated during the operation of the new ACC would be disposed of at the local landfill or other appropriate solid waste landfill. All solid waste would be disposed of appropriately as required by RCRA Solid Waste regulations. Biomedical waste produced from the operation of the new ACC would be disposed of according to established Omaha VAMC procedures. • Fuels, lubricants, hydraulic fluids and other and chemicals used on the construction site would be carefully handled to avoid spillage, properly secured against unauthorized access or vandalism, and provided with spill containment according to codes of practice. Waste oils, hydraulic fluids, and other chemical substances would be collected in leak- proof containers and removed from the site for disposal or recycling. • Any spills from construction-related activities would be cleaned up with absorbent blankets and storage containers in a timely manner to minimize the potential for overland flow into the storm water. • If contaminated soils and/or water or hazardous materials are encountered, then all work within the immediate area of the discovered hazardous material would stop until VA, NDEQ, and appropriate agencies could be notified and a plan to dispose of the hazardous materials has been developed.

Utilities • No proposed mitigation

Environmental Justice • No proposed mitigation

79 Proposed Ambulatory Care Center Environmental Assessment NWIHCS Omaha VAMC December 2017

6.0 Conclusion

This DEA has been prepared in accordance with CEQ regulations (40 CFR 1500–1508) and VA guidance (38 CFR 26). The VA has determined that the document adequately and accurately discusses the environmental issues and impacts of the Proposed Action. Based on the analysis to-date, adverse impacts are considered minor and can be mitigated (see Table 6-1).

The VA will make a determination based on the public comments and the Final EA as to whether the project may be carried forward with a Finding of No Significant Impact, or whether an Environmental Impact Statement may be required.

Table 6-1. Environmental Consequences of the Proposed Action Summary

Resource No-Action Alternative Proposed Action Aesthetics No change from current conditions No significant long-term negative impacts expected. The new ACC would be compatible with the existing Omaha VAMC campus facilities. The new ACC would not impact views from adjacent or distant locations. Short-term temporary negative impacts may result during construction. Air Quality No change from current conditions No significant long-term negative impacts expected. Short-term temporary increases in emissions expected during construction. Short- term negative impacts would be mitigated with the implementation of Best Management Practices (BMPs) to limit dust and engine exhaust. Intermittent short-term negative impacts to local air quality would also result during power outages due to the operation of a backup generator. Cultural Resources No change from current conditions No Impact to historic properties Geology and Soils No change from current conditions No significant long-term negative impacts expected. Soil compaction and modifications to site topography would be required for the new ACC. Soil erosion and/or contamination would be controlled by implementing standard BMPs for erosion and sediment control, equipment refueling, and fuel and chemical spill clean-up. Hydrology and Water Quality No change from current conditions No significant long-term negative impacts expected. Short-term impacts to water resources from increased stormwater runoff, erosion, and sedimentation due to construction activities would be

80 Proposed Ambulatory Care Center Environmental Assessment NWIHCS Omaha VAMC December 2017

Resource No-Action Alternative Proposed Action Hydrology and Water Quality No change from current conditions limited. BMPs to control erosion and (continued) (continued) sedimentation and to properly manage runoff, and dispose of contaminated soil would be implemented. Long-term positive impact includes a reduction in stormwater runoff due to decreases in impervious surface. Wildlife, Habitat, and Threatened No change from current conditions No significant long-term negative and Endangered Species impacts. The site would be revegetated following construction. Tree clearing activities would be limited to avoid birds and bat impacts. Noise No change from current conditions No significant long-term negative impacts. Short-term noise impacts due to construction would be minor, and mitigated by implementing time- of-day limitations and equipment BMPs as needed. Land Use No change from current conditions No significant long-term negative impacts. The new ACC would be consistent with existing land uses and zoning. Floodplains and Wetlands No change from current conditions No significant long-term or short- term negative impacts. No wetlands or floodplains are present. Socioeconomics No change from current conditions. Long-term positive impact expected Possible long-term negative impact as Omaha VAMC services improved. as Omaha VAMC facilities are not currently adequate to meet community needs. Transportation and Parking No change from current conditions No significant negative long-term impacts. Short-term parking impacts would be mitigated with temporary off-site parking. Bus access would be maintained. Solid and Hazardous Materials No change from current conditions No significant long-term negative impacts. BMP’s would be implemented for waste disposal and spill containment during construction. Significant increases in waste are not anticipated. Solid, hazardous, and biomedical waste would be managed according to current Omaha VAMC procedures. Utilities No change from current conditions No significant negative long-term impacts. Long-term positive impact as the new ACC would include updated utility systems and back-up power generation. Environmental Justice No change from current conditions No significant long-term impacts

81 Proposed Ambulatory Care Center Environmental Assessment NWIHCS Omaha VAMC December 2017

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82 Proposed Ambulatory Care Center Environmental Assessment NWIHCS Omaha VAMC December 2017

7.0 List of Preparers

Tony Baumert – Technical Lead, Olsson Associates Lucinda Bugbee – Senior Team Coordinator, Olsson Associates Amy Cherko – Project Scientist, Olsson Associates Hilary Clark – Senior Scientist, Olsson Associates Madison Leonard – Associate Scientist, Olsson Associates Brian Osborn – Team Leader, Olsson Associates Carrie Wencel – Associate Scientist, Olsson Associates

83 Proposed Ambulatory Care Center Environmental Assessment NWIHCS Omaha VAMC December 2017

8.0 References

16 United States Code 1531

33 United States Code 1251

33 United States Code 1344

36 Code of Federal Regulations 800

38 Code of Federal Regulations 26

40 Code of Federal Regulations 50

40 Code of Federal Regulations 261

40 Code of Federal Regulations 262

40 Code of Federal Regulations 1500-1508

40 Code of Federal Regulations 1508.7

40 Code of Federal Regulations 1508.8

42 United States Code 1996

42 United States Code 4321-4347

42 United States Code 4901

42 United States Code 6901

44 Code of Federal Regulations 26951 – Executive Order 11988 Floodplain Management and EO 11990 Protection of Wetlands

Bureau of Economic Analysis. 2017. CA25N Total full-time and part-time employment by NAICS industry. Last Updated November 17, 2016. Available online at http://www.bea.gov/iTable/iTable.cfm?ReqID=70&step=1&isuri=1&acrdn=5. Accessed November 1, 2017.

Bureau of Labor Statistics. 2017. LAUMT313654000000003, LAUMT313654000000004, LAUMT313654000000005, LAUMT313654000000006, LAUCN310550000000003, LAUCN310550000000006, LAUST310000000000003, Local Area Unemployment Statistics, Not Seasonally Adjusted. Last Updated September 2017. Available online https://beta.bls.gov/dataViewer/. Accessed November 1, 2017.

Chapman, Shannen S., Omernik, James M., Freeouf, JerryA., Huggins, Donald G., McCauley, James R., Freeman, Craig C., Steinauer, Gerry, Angelo, Robert T., and Schlepp, Richard L. 2001. Ecoregions of Nebraska and Kansas (color poster with map, descriptive text, summary tables, and photographs): Reston, Virginia, U.S. Geological Survey (map scale 1:1,950,000).

84 Proposed Ambulatory Care Center Environmental Assessment NWIHCS Omaha VAMC December 2017

Department of Veterans Affairs. 2009. Feasibility Study for Correcting Space and Infrastructure Deficiencies-VA Nebraska Western Iowa Health Care System-Omaha Campus

Department of Veterans Affairs. 2012. Final Environmental Assessment of a Proposed New Omaha Veterans Affairs Medical Center (VAMC), Douglas County, Nebraska.

Department of Veterans Affairs. 2016. Strategic Capitol Investment Plan VHA23-636-2015- 27431

Douglas Omaha Geographic Information System. 2017. https://www.dogis.org/Html5Viewer/?viewer=dogis

Environmental Data Resources Radius Map Report. 2017. Omaha VA Medical Center Campus. Inquiry Number 5092548.2s

ESRI. 2009. USA Topo Maps. From 2011 National Geographic Society, i-cubed. Modified October 5, 2017.

Executive Order 12898 - Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations

Federal Emergency Management Agency. 2005. FIRM. Panel 31055C0351H

Greater Omaha Economic Development Partnership. 2017. Greater Omaha Health Care. http://www.selectgreateromaha.com/Live-Work/Healthcare.aspx. Accessed November 1, 2017.

Metropolitan Area Planning Agency. 2016. Transportation Improvement Program FY2017-2022.

National Register of Historic Places. 2017. National Register of Historic Places Mapper. https://www.nps.gov/maps/full.html?mapId=7ad17cc9-b808-4ff8-a2f9-a99909164466 accessed October 31, 2017.

Nebraska Department of Environmental Quality. 2016a. 2016 Surface Water Quality Integrated Report. http://deq.ne.gov/Publica.nsf/Pages/WAT234

Nebraska Department of Environmental Quality. 2016b. Authorization to Discharge Under the National Pollutant Discharge Elimination System (NPDES) General NPDES Permit Number NER16000 for Storm Water Discharges from Construction Sites to Waters of the State of Nebraska

Nebraska Department of Environmental Quality. 2017. 2017 Ambient Air Monitoring Network Plan. NDEQ Document #17-005. Public Inspection Draft 060717.

Nebraska Game and Parks Commission Nebraska Natural Heritage Program. 2015. Northern Long-eared Bat Range Map. http://outdoornebraska.gov/wp- content/uploads/2015/09/NHP_RangeMap_NorthernLongEaredBat.pdf

Nebraska Game and Parks Commission Nebraska Natural Heritage Program. 2017a. http://outdoornebraska.gov/naturalheritageprogram/

85 Proposed Ambulatory Care Center Environmental Assessment NWIHCS Omaha VAMC December 2017

Nebraska Game and Parks Commission Nebraska Natural Heritage Program. 2017b. Special Status Species for Douglas County. http://outdoornebraska.gov/wp- content/uploads/2017/02/T-and-E-Species-by-County-2017.pdf

Omaha Fire and Rescue Department. 2017. https://www.omaha-fire.org/about-us/. Accessed November 1, 2017.

Omaha Police Department. 2017. Precincts and Patrol Districts. https://police.cityofomaha.org/about-us/precincts Accessed November 1, 2017.

OMetro. 2017a. Route 3 Information. http://www.ometro.com/index.php/route/route-3/ Accessed November 1, 2017.

OMetro. 2017b. Route 15 Information. http://www.ometro.com/index.php/route/route-15/ Accessed November 1, 2017.

Public Law 95-341. American Indian Religious Freedom Act of 1978.

Public Law 114-294. 2016. Communities Helping Invest Through Property and Improvements Needed for Veterans Act of 2016

Rolfsmeier, Steven B. and Gerry Steinauer. 2010. Terrestrial Ecological Systems and Natural Communities of Nebraska. Nebraska Natural Heritage Program. Nebraska Game and Parks Commission.

United States Department of Agriculture Natural Resource Conservation Service. 2017. Web Soil Survey. https://websoilsurvey.sc.egov.usda.gov/App/WebSoilSurvey.aspx

United States Environmental Protection Agency. 2017a. NAAQS Table. https://www.epa.gov/criteria-air-pollutants/naaqs-table

United States Environmental Protection Agency. 2017b. Air Quality Index Report. https://www.epa.gov/outdoor-air-quality-data/air-quality-index-report

United States Environmental Protection Agency. 2017c. Summary of the Resource Conservation and Recovery Act. https://www.epa.gov/laws-regulations/summary-resource- conservation-and-recovery-act. Accessed November 1, 2017

United States Fish and Wildlife Service. 2017a. Species by County Report. https://ecos.fws.gov Accessed November 1, 2017.

United States Fish and Wildlife. 2017b. Nation Wetlands Inventory. https://www.fws.gov/wetlands/data/Mapper.html

United States Geological Survey. 1997. Ground water Atlas of the United States. https://pubs.usgs.gov/ha/ha730/ch_d/D-text7.html

United States Geological Survey. 2014. Earthquake Hazards Program 2014 Long-term Model. https://earthquake.usgs.gov/hazards/hazmaps/conterminous/index.php#2014

86 Proposed Ambulatory Care Center Environmental Assessment NWIHCS Omaha VAMC December 2017

United States Census Bureau. 2000. Census 2000 Data for the United States. https://www.census.gov/census2000/states/us.html

United States Census Bureau. 2010. 2010 Census Data. https://www.census.gov/2010census/data/

United States Census Bureau. 2015. 2015 American Community Survey. https://www.census.gov/programs-surveys/acs/

University of Nebraska School of Natural Resources. 2017. http://snr.unl.edu/data/geologysoils/index.aspx

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Appendix A Agency Correspondence

DEPARTMENT OF VETERANS AFFAIRS Office of Construction & Facilities Management, Central Region 1425 Tri-State Parkway, Suite 140, Gurnee, IL 60031

September 14, 2017

Larry Shepard US EPA Region 7 11201 Renner Blvd. Lenexa, KS 66219

RE: Ambulatory Clinic, Environmental Assessment, Nebraska Veteran’s Affairs Douglas County, Nebraska

Dear Mr. Shepard:

The Veteran’s Affairs (VA) Nebraska-Western Iowa Health Care System, a component of the Department of Veterans Affairs, is in the process of completing an Environmental Assessment for the construction of a new ambulatory care clinic (ACC) facility located at the existing Omaha Veterans Affairs Medical Center (VAMC) in Omaha, Douglas County, Nebraska. In accordance with the National Environmental Policy Act (NEPA) of 1969, as amended; the Council on Environmental Quality (CEQ) NEPA implementation guidelines (40 Code of Federal Regulations [CFR] 1500-1508); and VA guidance for implementation of NEPA (NEPA Interim Guidance for Projects, 2010) the VA is requesting input from your agency on potential environmental impacts.

The VA is proposing to construct a new ACC on its existing hospital grounds at 42nd and Center Streets (Figure 1). The proposed project consists of a 157,438-square foot three-story clinical office building, with a partial fourth floor mechanical penthouse, parking areas, patient and visitor drop off areas, a proposed road, and new green spaces. The building would serve a primarily outpatient veteran population and would be joined to the existing VAMC via a connector walkway structure.

The VA requests your input regarding potential environmental concerns your agency may have. Please provide comment within 30 days of receipt of this letter. If you have any questions, or require additional information, please do not hesitate to call me at 224.610.3531. Your response may also be forwarded to my e-mail address: [email protected].

Thank you for your assistance.

Sincerely,

Glenn H. Wittman, P.G. Regional Environmental Engineer Department of Veterans Affairs Office of Construction & Facilities Mgmt. 1425 Tri-State Parkway, Suite 140 Gurnee, IL 60031-2497

DEPARTMENT OF VETERANS AFFAIRS Office of Construction & Facilities Management, Central Region 1425 Tri-State Parkway, Suite 140, Gurnee, IL 60031

September 14, 2017

Eliza Hines U.S. Fish and Wildlife Service 9325 South Alda Road Wood River, NE 68883

RE: Ambulatory Clinic, Environmental Assessment, Nebraska Veteran’s Affairs Douglas County, Nebraska

Dear Ms. Hines:

The purpose of the project is to provide ambulatory care services to veterans in the Nebraska- Western Iowa area. The proposed project is needed to address the growing health care needs of the VAMC and patient population. The existing VA medical center has numerous technical issues with the aging infrastructure as well as space and functional deficiencies. The proposed project would promote patient care and safety, maintain VA identity, increase efficiency, and improve patient and staff satisfaction. The VA requests your input regarding potential environmental concerns your agency may have. Please provide comment within 30 days of receipt of this letter. If you have any questions, or require additional information, please do not hesitate to call me at 224.610.3531. Your response may also be forwarded to my e-mail address: [email protected].

Thank you for your assistance.

Sincerely,

Glenn H. Wittman, P.G. Regional Environmental Engineer Department of Veterans Affairs Office of Construction & Facilities Mgmt. 1425 Tri-State Parkway, Suite 140 Gurnee, IL 60031-2497

United States Department of the Interior

FISH AND WILDLIFE SERVICE Ecological Services Nebraska Field Office 9325 South Alda Road Wood River, Nebraska 68883

November 30, 2017

FWS NE: 2017-514

Mr. Glenn Wittman Regional Environmental Engineer Department of Veterans Affairs Office of Construction & Facilities Mgmt. 1425 Tri-State Parkway, Suite 140 Gurnee, Illinois 60031-2497

Re: Ambulatory Clinic Environmental Assessment, Nebraska Veterans Affairs, Douglas County, Nebraska.

Dear Mr. Wittman:

This responds to your September 18, 2017, request for technical assistance from the U.S. Fish and Wildlife Service (Service) for the proposed construction of a new ambulatory care clinic located at the existing Omaha Veterans Affairs Medical Center in Omaha, Douglas County, Nebraska. The Service has responsibility for conservation and management of fish and wildlife resources for the benefit of the American public under the following authorities: 1) Endangered Species Act of 1973; 2) Fish and Wildlife Coordination Act; 3) Bald and Golden Eagle Protection Act; and 4) Migratory Bird Treaty Act MBTA. The National Environmental Policy Act requires compliance with all of these statutes and regulations.

Based the commitments made to avoid tree clearing from June 1-July 31 to protect the federally threatened Northern long-eared bat and from April 1-July 15 to protect migratory birds1 (October 2, 2017 email), we do not anticipate any impacts on federal trust species or their habitats. Should the project design change, or during the term of this action, additional information on listed or proposed species or their critical habitat become available, or if new information reveals effects of the action that were not previously considered, consultation with the Service should be initiated to assess any potential impacts on listed species.

1 October 2, 2017 email from Brian Osborn acknowledges the standard commitment that tree clearing will be avoided between April 1 and July 15 (nesting season) for compliance with MBTA. If tree clearing must occur during the nesting season, a nesting bird survey will be completed prior to any activity in order to avoid impacts to active bird nests. 2 All federally listed species under ESA are also State-listed under the Nebraska Nongame and Endangered Species Conservation Act. However, there are also State-listed species that are not federally listed. To determine if the proposed project may affect State-listed species, the Service recommends that the project proponent contact Mr. Ryan Joe ([email protected]) at the Nebraska Game and Parks Commission, 2200 N. 33rd Street, Lincoln, NE 68503-0370.

The Service appreciates the opportunity to review and comment on the subject proposed project. Should you have questions regarding these comments, please contact me at [email protected] or (308) 382-6468, extension 204.

Sincerely,

Eliza Hines Nebraska Field Supervisor

cc: NGPC; Lincoln, NE (Attn: Ryan Joe) DEPARTMENT OF VETERANS AFFAIRS Office of Construction & Facilities Management, Central Region 1425 Tri-State Parkway, Suite 140, Gurnee, IL 60031

September 14, 2017

Mr. John Moeschen U.S. Army Corps of Engineers NE State Regulatory Office 8901 South 154th Street, Suite 1 Omaha, NE 68138

RE: Ambulatory Clinic, Environmental Assessment, Nebraska Veteran’s Affairs Douglas County, Nebraska

Mr. Moeschen:

Sincerely,

Glenn H. Wittman, P.G. Regional Environmental Engineer Department of Veterans Affairs Office of Construction & Facilities Mgmt. 1425 Tri-State Parkway, Suite 140 Gurnee, IL 60031-2497

DEPARTMENT OF VETERANS AFFAIRS Office of Construction & Facilities Management, Central Region 1425 Tri-State Parkway, Suite 140, Gurnee, IL 60031

September 14, 2017

Carla Felix Nebraska Department of Environmental Quality 1200 N Street, Suite 400 PO Box 98922 Lincoln, NE 68509-8922

RE: Ambulatory Clinic, Environmental Assessment, Nebraska Veteran’s Affairs Douglas County, Nebraska

Dear Ms. Felix:

Sincerely,

Glenn H. Wittman, P.G. Regional Environmental Engineer Department of Veterans Affairs Office of Construction & Facilities Mgmt. 1425 Tri-State Parkway, Suite 140 Gurnee, IL 60031-2497

DEPARTMENT OF VETERANS AFFAIRS Office of Construction & Facilities Management, Central Region 1425 Tri-State Parkway, Suite 140, Gurnee, IL 60031

September 14, 2017

Carey Grell Nebraska Game and Parks 2200 N 33rd St Lincoln, NE 68503

RE: Ambulatory Clinic, Environmental Assessment, Nebraska Veteran’s Affairs Douglas County, Nebraska

Dear Ms. Grell:

Sincerely,

Glenn H. Wittman, P.G. Regional Environmental Engineer Department of Veterans Affairs Office of Construction & Facilities Mgmt. 1425 Tri-State Parkway, Suite 140 Gurnee, IL 60031-2497

November 6, 2017

Glenn Wittman Department of Veterans Affairs 1425 Tri-State Parkway, Suite 140 Gurnee, IL 60031-2497

RE: Construction of Ambulatory Clinic located at the existing Omaha Veterans Affairs Medical Center (VAMC) in Omaha, Douglas County

Dear Mr. Wittman:

Nebraska Game and Parks Commission (NGPC) staff members have reviewed the information for the proposal identified above. This project would involve construction of a new clinical office building on the existing hospital grounds that would be joined to the existing VAMC via a connector walkway structure. This review was requested pursuant to the National Environmental Policy Act (NEPA).

Based on our review, we have determined that the project as described will have no adverse impacts on resources within our agency’s areas of concern, including state-listed threatened and endangered species, fish and wildlife resources and their habitats, or NGPC properties.

Thank you for opportunity to review this proposal. Please contact me if you have any questions regarding these comments at 402-471-5423 or [email protected].

Sincerely,

Carey Grell Environmental Analyst Supervisor Planning and Programming Division

DEPARTMENT OF VETERANS AFFAIRS Office of Construction & Facilities Management, Central Region 1425 Tri-State Parkway, Suite 140, Gurnee, IL 60031

September 14, 2017

Ms. Jill Dolberg State Historic Preservation Office Nebraska State Historical Society P.O. Box 82554 Lincoln, NE 68501-2554

RE: Ambulatory Clinic, Environmental Assessment, Nebraska Veteran’s Affairs Douglas County, Nebraska

Dear Ms. Dolberg:

The Veteran’s Affairs (VA) Nebraska-Western Iowa Health Care System, a component of the Department of Veterans Affairs, is in the process of completing an Environmental Assessment for the construction of a new construction ambulatory care clinic (ACC) facility located at the existing Omaha Veterans Affairs Medical Center (VAMC) in Omaha, Douglas County, Nebraska. In accordance with the National Environmental Policy Act (NEPA) of 1969, as amended; the Council on Environmental Quality (CEQ) NEPA implementation guidelines (40 Code of Federal Regulations [CFR] 1500-1508); and VA guidance for implementation of NEPA (NEPA Interim Guidance for Projects, 2010) the VA is requesting input from your agency on potential environmental impacts.

The purpose of the project is to provide ambulatory care services to veterans in the Nebraska- Western Iowa area. The proposed project is needed to address the growing health care needs of the VAMC and patient population. The existing VA medical center has numerous technical issues with the aging infrastructure as well as space and functional deficiencies. The proposed project would promote patient care and safety, maintain VA identity, increase efficiency, and improve patient and staff satisfaction. Coordination with the Nebraska State Historical Society was completed in 2011 (HP# 1103-204- 01) for a project to redevelop the VAMC. This project has been abandoned; however, at the time the SHPO determined the VAMC was not eligible for listing in the National Register of Historic Places because of the significant modification that has occurred at this property.

The VA requests your input regarding potential environmental concerns your agency may have regarding the proposed project. Please provide comment within 30 days of receipt of this letter. If you have any questions, or require additional information, please do not hesitate to call me at 224.610.3531. Your response may also be forwarded to my e-mail address: [email protected].

Thank you for your assistance.

Sincerely,

Glenn H. Wittman, P.G. Regional Environmental Engineer Department of Veterans Affairs Office of Construction & Facilities Mgmt. 1425 Tri-State Parkway, Suite 140 Gurnee, IL 60031-24

A-22 DEPARTMENT OF VETERANS AFFAIRS Office of Construction & Facilities Management, Central Region 1425 Tri-State Parkway, Suite 140, Gurnee, IL 60031

September 14, 2017

Tribal Historic Preservation Office Sac and Fox Nation of Missouri in Kansas and Nebraska 305 North Main Street Reserve, KS 66434

RE: Ambulatory Clinic, Environmental Assessment, Nebraska Veteran’s Affairs Douglas County, Nebraska

To Whom It May Concern:

Sincerely,

Glenn H. Wittman, P.G. Regional Environmental Engineer Department of Veterans Affairs Office of Construction & Facilities Mgmt. 1425 Tri-State Parkway, Suite 140 Gurnee, IL 60031-2497

DEPARTMENT OF VETERANS AFFAIRS Office of Construction & Facilities Management, Central Region 1425 Tri-State Parkway, Suite 140, Gurnee, IL 60031

September 14, 2017

Thomas Parker Tribal Historic Preservation Office Director Omaha Tribal Historic Preservation Office P.O. Box 368 Macy, NE 68039

RE: Ambulatory Clinic, Environmental Assessment, Nebraska Veteran’s Affairs Douglas County, Nebraska

Dear Mr. Parker:

Sincerely,

Glenn H. Wittman, P.G. Regional Environmental Engineer Department of Veterans Affairs Office of Construction & Facilities Mgmt. 1425 Tri-State Parkway, Suite 140 Gurnee, IL 60031-2497

DEPARTMENT OF VETERANS AFFAIRS Office of Construction & Facilities Management, Central Region 1425 Tri-State Parkway, Suite 140, Gurnee, IL 60031

September 14, 2017

Duane Whipple Tribal Historic Preservation Office Santee Sioux Nation 425 Frazier Ave. N. #2 Niobara, NE 68760

RE: Ambulatory Clinic, Environmental Assessment, Nebraska Veteran’s Affairs Douglas County, Nebraska

Dear Mr. Whipple:

Sincerely,

Glenn H. Wittman, P.G. Regional Environmental Engineer Department of Veterans Affairs Office of Construction & Facilities Mgmt. 1425 Tri-State Parkway, Suite 140 Gurnee, IL 60031-2497

DEPARTMENT OF VETERANS AFFAIRS Office of Construction & Facilities Management, Central Region 1425 Tri-State Parkway, Suite 140, Gurnee, IL 60031

September 14, 2017

Ponca Tribe of Nebraska Tribal Historic Preservation Office PO Box 288 Niobrara, NE 68760

RE: Ambulatory Clinic, Environmental Assessment, Nebraska Veteran’s Affairs Douglas County, Nebraska

To Whom It May Concern:

Sincerely,

Glenn H. Wittman, P.G. Regional Environmental Engineer Department of Veterans Affairs Office of Construction & Facilities Mgmt. 1425 Tri-State Parkway, Suite 140 Gurnee, IL 60031-2497

DEPARTMENT OF VETERANS AFFAIRS Office of Construction & Facilities Management, Central Region 1425 Tri-State Parkway, Suite 140, Gurnee, IL 60031

September 14, 2017

Randy Teboe Tribal Historic Preservation Office Winnebago Tribe of Nebraska PO Box 687 Winnebago, NE 68071

RE: Ambulatory Clinic, Environmental Assessment, Nebraska Veteran’s Affairs Douglas County, Nebraska

Dear Mr. Teboe:

Thank you for your assistance.

Sincerely,

Glenn H. Wittman, P.G. Regional Environmental Engineer Department of Veterans Affairs Office of Construction & Facilities Mgmt. 1425 Tri-State Parkway, Suite 140 Gurnee, IL 60031-2497

DEPARTMENT OF VETERANS AFFAIRS Office of Construction & Facilities Management, Central Region 1425 Tri-State Parkway, Suite 140, Gurnee, IL 60031

September 14, 2017

F. Martin Fee Tribal Historic Preservation Officer Iowa Tribe of Kansas and Nebraska 3345 B. Thrasher Rd. White Cloud, KS 66094

RE: Ambulatory Clinic, Environmental Assessment, Nebraska Veteran’s Affairs Douglas County, Nebraska

Dear Mr. Fee:

Sincerely,

Glenn H. Wittman, P.G. Regional Environmental Engineer Department of Veterans Affairs Office of Construction & Facilities Mgmt. 1425 Tri-State Parkway, Suite 140 Gurnee, IL 60031-2497

Appendix B EDR Report

Omaha VA Medical Center Campus 4101 Woolworth Avenue Omaha, NE 68105

Inquiry Number: 5092548.2s October 31, 2017

The EDR Radius Map™ Report

6 Armstrong Road, 4th floor Shelton, CT 06484 Toll Free: 800.352.0050 www.edrnet.com

FORM-LBF-CHZ TABLE OF CONTENTS

SECTION PAGE

Executive Summary ES1 Overview Map 2 Detail Map 3 Map Findings Summary 4 Map Findings 8 Orphan Summary 212 Government Records Searched/Data Currency Tracking GR-1

GEOCHECK ADDENDUM

GeoCheck - Not Requested

Thank you for your business. Please contact EDR at 1-800-352-0050 with any questions or comments.

Disclaimer - Copyright and Trademark Notice This Report contains certain information obtained from a variety of public and other sources reasonably available to Environmental Data Resources, Inc. It cannot be concluded from this Report that coverage information for the target and surrounding properties does not exist from other sources. NO WARRANTY EXPRESSED OR IMPLIED, IS MADE WHATSOEVER IN CONNECTION WITH THIS REPORT. ENVIRONMENTAL DATA RESOURCES, INC. SPECIFICALLY DISCLAIMS THE MAKING OF ANY SUCH WARRANTIES, INCLUDING WITHOUT LIMITATION, MERCHANTABILITY OR FITNESS FOR A PARTICULAR USE OR PURPOSE. ALL RISK IS ASSUMED BY THE USER. IN NO EVENT SHALL ENVIRONMENTAL DATA RESOURCES, INC. BE LIABLE TO ANYONE, WHETHER ARISING OUT OF ERRORS OR OMISSIONS, NEGLIGENCE, ACCIDENT OR ANY OTHER CAUSE, FOR ANY LOSS OF DAMAGE, INCLUDING, WITHOUT LIMITATION, SPECIAL, INCIDENTAL, CONSEQUENTIAL, OR EXEMPLARY DAMAGES. ANY LIABILITY ON THE PART OF ENVIRONMENTAL DATA RESOURCES, INC. IS STRICTLY LIMITED TO A REFUND OF THE AMOUNT PAID FOR THIS REPORT. Purchaser accepts this Report "AS IS". Any analyses, estimates, ratings, environmental risk levels or risk codes provided in this Report are provided for illustrative purposes only, and are not intended to provide, nor should they be interpreted as providing any facts regarding, or prediction or forecast of, any environmental risk for any property. Only a Phase I Environmental Site Assessment performed by an environmental professional can provide information regarding the environmental risk for any property. Additionally, the information provided in this Report is not to be construed as legal advice. Copyright 2017 by Environmental Data Resources, Inc. All rights reserved. Reproduction in any media or format, in whole or in part, of any report or map of Environmental Data Resources, Inc., or its affiliates, is prohibited without prior written permission. EDR and its logos (including Sanborn and Sanborn Map) are trademarks of Environmental Data Resources, Inc. or its affiliates. All other trademarks used herein are the property of their respective owners.

TC5092548.2s EXECUTIVE SUMMARY

A search of available environmental records was conducted by Environmental Data Resources, Inc (EDR). The report was designed to assist parties seeking to meet the search requirements of EPA’s Standards and Practices for All Appropriate Inquiries (40 CFR Part 312), the ASTM Standard Practice for Environmental Site Assessments (E 1527-13) or custom requirements developed for the evaluation of environmental risk associated with a parcel of real estate.

TARGET PROPERTY INFORMATION

ADDRESS

4101 WOOLWORTH AVENUE OMAHA, NE 68105

COORDINATES

Latitude (North): 41.2431860 - 41˚ 14’ 35.46’’ Longitude (West): 95.9734830 - 95˚ 58’ 24.53’’ Universal Tranverse Mercator: Zone 15 UTM X (Meters): 250825.4 UTM Y (Meters): 4569806.0 Elevation: 1223 ft. above sea level

USGS TOPOGRAPHIC MAP ASSOCIATED WITH TARGET PROPERTY

Target Property Map: 6713756 OMAHA SOUTH, NE Version Date: 2014

North Map: 6713754 OMAHA NORTH, NE Version Date: 2014

AERIAL PHOTOGRAPHY IN THIS REPORT

Portions of Photo from: 20140921 Source: USDA

TC5092548.2s EXECUTIVE SUMMARY 1 MAPPED SITES SUMMARY

Target Property Address: 4101 WOOLWORTH AVENUE OMAHA, NE 68105

Click on Map ID to see full detail.

MAP RELATIVE DIST (ft. & mi.) IDSITE NAME ADDRESS DATABASE ACRONYMS ELEVATION DIRECTION A1 VA AUXILIARY POWER B 4101 WOOLWORTH, HEAT LUST TP A2 VA AUXILIARY POWER 4101 WOOLWORTH, HE RGA LUST TP A3 UNI OF NEBRASKA/OMAH MOTOR POOL - BLDG 40 UST TP A4 OMAHA VA MEDICAL CEN 4101 WOOLWORTH AVE ICIS, US AIRS, FINDS, ECHO TP A5 VA MEDICAL CENTER - 4101 WOOLWORTH AVE SEMS-ARCHIVE, RCRA-SQG TP A6 VETERANS ADMIN MEDIC 4101 WOOLWORTH FTTS, HIST FTTS TP A7 VA MEDICAL CENTER 4101 WOOLWORTH AVE RGA LUST TP A8 V. A., DEPARTMENT OF 4101 WOOLWORTH AVENU MLTS TP A9 VA MED CENTER OPC BL 4101 WOOLWORTH RGA LUST TP A10 VA MED CENTER OPC 4101 WOOLWORTH RGA LUST TP A11 4101 WOOLWORTH AVE ERNS TP A12 OMAHA VA MEDICAL CEN 4101 WOOLWORTH AVE SHWS, AIRS, TIER 2 TP A13 HEATING PLANT, VA HO 4101 WOOLWORTH, HEAT RGA LUST TP A14 4101 WOOLWORTH AVE ERNS TP A15 4101 WOOLWORTH AVE ERNS TP A16 OMAHA VA MEDICAL CEN 4101 WOOLWORTH AVE RGA HWS TP A17 UNL - OMAHA - MEDICA 40TH & DEWEY UST TP A18 OMAHA VA MEDICAL CEN NE OF CENTER ST & PU LAST TP A19 HEATING PLANT, VA 4101 WOOLWORTH, HE RGA LUST TP A20 OMAHA VA MEDICAL CEN 4101 WOOLWORTH AVE LUST, UST, HIST UST, NPDES TP Reg OMAHA LEAD INTERSECTION I480 & NPL, SEMS, US ENG CONTROLS, US INST CONTROL, ROD,...Same 1 ft. B21 CENTER MALL 42 & CENTER ST LUST Lower 51, 0.010, SW 22 JENSEN SERVICE GARAG 709 39TH ST S EDR Hist Auto Lower 60, 0.011, SE 23 DOUGLAS COUNTY HOSPI 4102 WOOLWORTH AVE LUST, UST, HIST UST, AIRS Lower 106, 0.020, NNW B24 DINGERS TEXACO SERVI 4119 CENTER ST EDR Hist Auto Lower 124, 0.023, SW 25 PARKS CLEANERS & TAI 4001 CENTER ST EDR Hist Cleaner Lower 128, 0.024, SSW B26 ILLIS LOUIS GAS STA 4201 CENTER ST EDR Hist Auto Lower 187, 0.035, SW B27 CREDIT CAR CENTER IN 4201 CENTER ST LUST, UST, FINDS Lower 187, 0.035, SW 28 COUNTRY CORNER INC 3831 CENTER RD EDR Hist Auto Lower 198, 0.038, ESE C29 CENTER STREET CONOCO 3741 CENTER ST EDR Hist Auto Lower 461, 0.087, ESE 30 JENSEN NELS FILLING 2038 42ND S EDR Hist Auto Lower 464, 0.088, SSW C31 CLOTHING CARE CENTER 3717 CENTER ST EDR Hist Cleaner Lower 505, 0.096, ESE C32 EAGLE FOOD MART INC 3707 CENTER ST LUST, UST, HIST UST Lower 599, 0.113, ESE D33 FAMILY SERVICE 2101 S 42ND ST UST Lower 757, 0.143, SSW D34 FAMILY SERVICES 2101 SOUTH 42ND LUST Lower 757, 0.143, SSW E35 MCPHERSON SERVICE 3563 CENTER ST LUST, UST, HIST UST Lower 1071, 0.203, ESE E36 FREEWAY SERVICE 3555 CENTER LUST Lower 1214, 0.230, ESE E37 FREEWAY SERVICE 3555 CENTER ST UST Lower 1214, 0.230, ESE 38 NAGL MANUFACTURING C 3626 MARTHA ST LUST, AIRS, NPDES Lower 1380, 0.261, SE

5092548.2s Page 2 MAPPED SITES SUMMARY

Target Property Address: 4101 WOOLWORTH AVENUE OMAHA, NE 68105

Click on Map ID to see full detail.

MAP RELATIVE DIST (ft. & mi.) IDSITE NAME ADDRESS DATABASE ACRONYMS ELEVATION DIRECTION 39 UPRR 39TH & PACIFIC 39TH & PACIFIC LUST Lower 1408, 0.267, NNE 40 FIELD CLUB OF OMAHA 3615 WOOLWORTH LUST Higher 1512, 0.286, ENE 41 TEDS SERVICE 4525 CENTER STREET LUST, UST, HIST UST, ICIS, US AIRS Lower 1589, 0.301, WSW 42 KIEWIT CONSTRUCTION 3921 MASON ST RCRA-CESQG, LUST, UST, HIST UST Lower 1621, 0.307, North 43 NORRIS JR HIGH SCHOO 2235 S 46 ST LUST Lower 2197, 0.416, SSW F44 LORENZ-MARCY STREET 39TH ST & MARCY ST SEMS-ARCHIVE Lower 2238, 0.424, North F45 MARCY STREET DRUM SI 3902 MARCY ST SHWS, LUST Lower 2258, 0.428, North 46 TOTAL 1893 4103 LEAVENWORTH LUST Lower 2539, 0.481, North 47 COMMUNITY ALLIANCE I 4001 LEAVENWORTH ST LUST, NPDES Lower 2621, 0.496, North 48 FIELD CLUB TRAIL SIT 3911 LEAVENWORTH ST BROWNFIELDS Lower 2630, 0.498, North 49 CONTOUR LANDSCAPING 2114 S 48TH ST SEMS-ARCHIVE, SHWS, RCRA NonGen / NLR Lower 2876, 0.545, WSW 50 JOHN HERREN RESIDENC 4840 HICKORY ST SHWS Lower 3177, 0.602, West 51 UNIVERSITY OF NEBRAS 4367 EMILE STREET CORRACTS, RCRA-TSDF, RCRA-LQG, US AIRS Lower 3394, 0.643, NNW 52 OMAHA AF STA Z-71 FUDS Higher 4335, 0.821, North 53 DON SHAFER DISPLAY 1325 PARK AVE SHWS Higher 4353, 0.824, ENE 54 UTILITIES SERVICES G 2623 CENTER ST SHWS, BROWNFIELDS Lower 5229, 0.990, East

5092548.2s Page 3 EXECUTIVE SUMMARY

TARGET PROPERTY SEARCH RESULTS The target property was identified in the following records. For more information on this property see page 8 of the attached EDR Radius Map report:

Site Database(s) EPA ID

VA AUXILIARY POWER B LUST N/A 4101 WOOLWORTH, HEAT File Number: 012203-QK-1630 OMAHA, NE Facility Status: BACKLOGGED - NOT YET INVESTIGATED

VA AUXILIARY POWER RGA LUST N/A 4101 WOOLWORTH, HE Facility ID: 012203-QK-1630 OMAHA, NE

UNI OF NEBRASKA/OMAH UST N/A MOTOR POOL - BLDG 40 Facility ID: 6681 OMAHA, NE 68198

OMAHA VA MEDICAL CEN ICIS N/A 4101 WOOLWORTH AVE FRS ID:: 110001508084 OMAHA, NE 68105 US AIRS Database: US AIRS (AFS), Date of Government Version: 10/12/2016 EPA plant ID:: 110001508084 FINDS Registry ID:: 110001508084 ECHO

VA MEDICAL CENTER - SEMS-ARCHIVE NE3360010315 4101 WOOLWORTH AVE Site ID: 0702024 OMAHA, NE 68105 EPA Id: NE3360010315 RCRA-SQG EPA ID:: NE3360010315

VETERANS ADMIN MEDIC FTTS N/A 4101 WOOLWORTH Database: FTTS INSP, Date of Government Version: 04/09/2009 OMAHA, NE 68105 HIST FTTS Database: HIST FTTS INSP, Date of Government Version: 10/19/2006

VA MEDICAL CENTER RGA LUST N/A 4101 WOOLWORTH AVE Facility ID: 120591-NH-0800 OMAHA, NE Facility ID: 021199-99-0006

V. A., DEPARTMENT OF MLTS N/A 4101 WOOLWORTH AVENU OMAHA, NE 68105

TC5092548.2s EXECUTIVE SUMMARY 4 EXECUTIVE SUMMARY

License Number:: 26-00138-10

VA MED CENTER OPC BL RGA LUST N/A 4101 WOOLWORTH Facility ID: 021898-99-0000 OMAHA, NE

VA MED CENTER OPC RGA LUST N/A 4101 WOOLWORTH Facility ID: 021898-99-0000 OMAHA, NE

4101 WOOLWORTH AVE ERNS N/A 4101 WOOLWORTH AVE NRC Report #: 1039169 OMAHA, NE 68105

OMAHA VA MEDICAL CEN SHWS N/A 4101 WOOLWORTH AVE DEQ Id: 10289 OMAHA, NE 68105 AIRS Facility Id: 10289 TIER 2 Facility Id: 10289

HEATING PLANT, VA HO RGA LUST N/A 4101 WOOLWORTH, HEAT Facility ID: 012203-QK-1630 OMAHA, NE

4101 WOOLWORTH AVE ERNS N/A 4101 WOOLWORTH AVE NRC Report #: 1112526 OMAHA, NE

4101 WOOLWORTH AVE ERNS N/A 4101 WOOLWORTH AVE NRC Report #: 1112533 OMAHA, NE

OMAHA VA MEDICAL CEN RGA HWS N/A 4101 WOOLWORTH AVE Facility ID: 10289 OMAHA, NE

UNL - OMAHA - MEDICA UST N/A 40TH & DEWEY Facility ID: 11375 OMAHA, NE 68198

OMAHA VA MEDICAL CEN LAST N/A NE OF CENTER ST & PU OMAHA, NE

TC5092548.2s EXECUTIVE SUMMARY 5 EXECUTIVE SUMMARY

File Number: 090115-PH-1315 Facility Status: NO FURTHER ACTION (INCIDENT CLOSED)

HEATING PLANT, VA RGA LUST N/A 4101 WOOLWORTH, HE Facility ID: 012203-QK-1630 OMAHA, NE

OMAHA VA MEDICAL CEN LUST N/A 4101 WOOLWORTH AVE File Number: 121197-TH-0935 OMAHA, NE 68105 File Number: 021199-99-0006 File Number: 021898-99-0000 File Number: 120591-NH-0800 Facility Status: BACKLOGGED - NOT YET INVESTIGATED Facility Status: NO FURTHER ACTION (INCIDENT CLOSED) UST Tank Id/Tank Status: Currently in Use Facility ID: 8007 HIST UST Facility Id: 8007 NPDES Facility Id: 10289

DATABASES WITH NO MAPPED SITES No mapped sites were found in EDR’s search of available ("reasonably ascertainable ") government records either on the target property or within the search radius around the target property for the following databases:

STANDARD ENVIRONMENTAL RECORDS

Federal NPL site list Proposed NPL Proposed National Priority List Sites NPL LIENS Federal Superfund Liens

Federal Delisted NPL site list Delisted NPL National Priority List Deletions

Federal CERCLIS list FEDERAL FACILITY Federal Facility Site Information listing

Federal RCRA non-CORRACTS TSD facilities list RCRA-TSDF RCRA - Treatment, Storage and Disposal

TC5092548.2s EXECUTIVE SUMMARY 6 EXECUTIVE SUMMARY

Federal RCRA generators list RCRA-LQG RCRA - Large Quantity Generators RCRA-CESQG RCRA - Conditionally Exempt Small Quantity Generator

Federal institutional controls / engineering controls registries LUCIS Land Use Control Information System

State and tribal landfill and/or solid waste disposal site lists SWF/LF Licensed Landfill List

State and tribal leaking storage tank lists INDIAN LUST Leaking Underground Storage Tanks on Indian Land

State and tribal registered storage tank lists FEMA UST Underground Storage Tank Listing AST Hazardous Chemical AST List INDIAN UST Underground Storage Tanks on Indian Land

State and tribal institutional control / engineering control registries INST CONTROL Nebraska’s Institutional Control Registry

State and tribal voluntary cleanup sites INDIAN VCP Voluntary Cleanup Priority Listing VCP RAPMA Sites

ADDITIONAL ENVIRONMENTAL RECORDS

Local Brownfield lists US BROWNFIELDS A Listing of Brownfields Sites

Local Lists of Landfill / Solid Waste Disposal Sites SWRCY Recycling Resource Directory INDIAN ODI Report on the Status of Open Dumps on Indian Lands DEBRIS REGION 9 Torres Martinez Reservation Illegal Dump Site Locations ODI Open Dump Inventory IHS OPEN DUMPS Open Dumps on Indian Land

Local Lists of Hazardous waste / Contaminated Sites US HIST CDL Delisted National Clandestine Laboratory Register US CDL National Clandestine Laboratory Register

Local Lists of Registered Storage Tanks HIST AST Aboveground Storage Tank Database Listing

TC5092548.2s EXECUTIVE SUMMARY 7 EXECUTIVE SUMMARY

Local Land Records LIENS 2 CERCLA Lien Information

Records of Emergency Release Reports HMIRS Hazardous Materials Information Reporting System SPILLS Surface Spill List SPILLS 90 SPILLS 90 data from FirstSearch SPILLS 80 SPILLS 80 data from FirstSearch

Other Ascertainable Records RCRA NonGen / NLR RCRA - Non Generators / No Longer Regulated DOD Department of Defense Sites SCRD DRYCLEANERS State Coalition for Remediation of Drycleaners Listing US FIN ASSUR Financial Assurance Information EPA WATCH LIST EPA WATCH LIST 2020 COR ACTION 2020 Corrective Action Program List TSCA Toxic Substances Control Act TRIS Toxic Chemical Release Inventory System SSTS Section 7 Tracking Systems RMP Risk Management Plans RAATS RCRA Administrative Action Tracking System PADS PCB Activity Database System COAL ASH DOE Steam-Electric Plant Operation Data COAL ASH EPA Coal Combustion Residues Surface Impoundments List PCB TRANSFORMER PCB Transformer Registration Database RADINFO Radiation Information Database DOT OPS Incident and Accident Data CONSENT Superfund (CERCLA) Consent Decrees INDIAN RESERV Indian Reservations FUSRAP Formerly Utilized Sites Remedial Action Program UMTRA Uranium Mill Tailings Sites US MINES Mines Master Index File ABANDONED MINES Abandoned Mines DOCKET HWC Hazardous Waste Compliance Docket Listing UXO Unexploded Ordnance Sites FUELS PROGRAM EPA Fuels Program Registered Listing DRYCLEANERS Drycleaner Facility Listing Financial Assurance Financial Assurance Information Listing UIC Undergound Injection Control Database

EDR HIGH RISK HISTORICAL RECORDS

EDR Exclusive Records EDR MGP EDR Proprietary Manufactured Gas Plants

SURROUNDING SITES: SEARCH RESULTS Surrounding sites were identified in the following databases.

TC5092548.2s EXECUTIVE SUMMARY 8 EXECUTIVE SUMMARY

Elevations have been determined from the USGS Digital Elevation Model and should be evaluated on a relative (not an absolute) basis. Relative elevation information between sites of close proximity should be field verified. Sites with an elevation equal to or higher than the target property have been differentiated below from sites with an elevation lower than the target property. Page numbers and map identification numbers refer to the EDR Radius Map report where detailed data on individual sites can be reviewed.

Sites listed in bold italics are in multiple databases.

Unmappable (orphan) sites are not considered in the foregoing analysis. STANDARD ENVIRONMENTAL RECORDS

Federal NPL site list NPL: Also known as Superfund, the National Priority List database is a subset of CERCLIS and identifies over 1,200 sites for priority cleanup under the Superfund program. The source of this database is the U.S. EPA.

A review of the NPL list, as provided by EDR, and dated 05/30/2017 has revealed that there is 1 NPL site within approximately 1 mile of the target property.

______Equal/Higher Elevation ______Address Direction ______/ Distance Map _____ ID Page _____ OMAHA LEAD INTERSECTION I480 & 0 - 1/8 (0.000 mi.) 0 55

Federal CERCLIS list SEMS: SEMS (Superfund Enterprise Management System) tracks hazardous waste sites, potentially hazardous waste sites, and remedial activities performed in support of EPA’s Superfund Program across the United States. The list was formerly know as CERCLIS, renamed to SEMS by the EPA in 2015. The list contains data on potentially hazardous waste sites that have been reported to the USEPA by states, municipalities, private companies and private persons, pursuant to Section 103 of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). This dataset also contains sites which are either proposed to or on the National Priorities List (NPL) and the sites which are in the screening and assessment phase for possible inclusion on the NPL.

A review of the SEMS list, as provided by EDR, and dated 07/11/2017 has revealed that there is 1 SEMS site within approximately 0.5 miles of the target property.

______Equal/Higher Elevation ______Address Direction ______/ Distance Map _____ ID Page _____ OMAHA LEAD INTERSECTION I480 & 0 - 1/8 (0.000 mi.) 0 55

Federal CERCLIS NFRAP site list SEMS-ARCHIVE: SEMS-ARCHIVE (Superfund Enterprise Management System Archive) tracks sites that have no further interest under the Federal Superfund Program based on available information. The list was formerly known as the CERCLIS-NFRAP, renamed to SEMS ARCHIVE by the EPA in 2015. EPA may perform a minimal level of assessment work at a site while it is archived if site conditions change and/or new information becomes available. Archived sites have been removed and archived from the inventory of SEMS sites. Archived status

TC5092548.2s EXECUTIVE SUMMARY 9 EXECUTIVE SUMMARY indicates that, to the best of EPA’s knowledge, assessment at a site has been completed and that EPA has determined no further steps will be taken to list the site on the National Priorities List (NPL), unless information indicates this decision was not appropriate or other considerations require a recommendation for listing at a later time. The decision does not necessarily mean that there is no hazard associated with a given site; it only means that. based upon available information, the location is not judged to be potential NPL site.

A review of the SEMS-ARCHIVE list, as provided by EDR, and dated 07/11/2017 has revealed that there is 1 SEMS-ARCHIVE site within approximately 0.5 miles of the target property.

______Lower Elevation ______Address Direction ______/ Distance Map _____ ID Page _____ LORENZ-MARCY STREET 39TH ST & MARCY ST N 1/4 - 1/2 (0.424 mi.) F44 102

Federal RCRA CORRACTS facilities list CORRACTS: CORRACTS is a list of handlers with RCRA Corrective Action Activity. This report shows which nationally-defined corrective action core events have occurred for every handler that has had corrective action activity.

A review of the CORRACTS list, as provided by EDR, and dated 09/13/2017 has revealed that there is 1 CORRACTS site within approximately 1 mile of the target property.

______Lower Elevation ______Address Direction ______/ Distance Map _____ ID Page _____ UNIVERSITY OF NEBRAS 4367 EMILE STREET NNW 1/2 - 1 (0.643 mi.) 51 107

Federal institutional controls / engineering controls registries US ENG CONTROLS: A listing of sites with engineering controls in place.

A review of the US ENG CONTROLS list, as provided by EDR, and dated 08/10/2017 has revealed that there is 1 US ENG CONTROLS site within approximately 0.5 miles of the target property.

______Equal/Higher Elevation ______Address Direction ______/ Distance Map _____ ID Page _____ OMAHA LEAD INTERSECTION I480 & 0 - 1/8 (0.000 mi.) 0 55

US INST CONTROL: A listing of sites with institutional controls in place. Institutional controls include administrative measures, such as groundwater use restrictions, construction restrictions, property use restrictions, and post remediation care requirements intended to prevent exposure to contaminants remaining on site. Deed restrictions are generally required as part of the institutional controls.

A review of the US INST CONTROL list, as provided by EDR, and dated 08/10/2017 has revealed that there is 1 US INST CONTROL site within approximately 0.5 miles of the target property.

______Equal/Higher Elevation ______Address Direction ______/ Distance Map _____ ID Page _____ OMAHA LEAD INTERSECTION I480 & 0 - 1/8 (0.000 mi.) 0 55

TC5092548.2s EXECUTIVE SUMMARY 10 EXECUTIVE SUMMARY

State- and tribal - equivalent CERCLIS SHWS: The Nebraska Department of Environmental Quality is providing this information from it’s own database. The data, although not verified to be the most current or accurate for any specific site, is generally based on the contents of the physical documents in the files. You may contact the Records Management Unit at (402) 471-3557 to make arrangements to view or to get a photocopy of the physical file.

A review of the SHWS list, as provided by EDR, and dated 09/18/2017 has revealed that there are 5 SHWS sites within approximately 1 mile of the target property.

______Equal/Higher Elevation ______Address Direction ______/ Distance Map _____ ID Page _____ DON SHAFER DISPLAY 1325 PARK AVE ENE 1/2 - 1 (0.824 mi.) 53 211 DEQ Id: 11172

______Lower Elevation ______Address Direction______/ Distance Map _____ ID Page _____ MARCY STREET DRUM SI 3902 MARCY ST N 1/4 - 1/2 (0.428 mi.) F45 103 DEQ Id: 11097 CONTOUR LANDSCAPING 2114 S 48TH ST WSW 1/2 - 1 (0.545 mi.) 49 105 DEQ Id: 59486 JOHN HERREN RESIDENC 4840 HICKORY ST W 1/2 - 1 (0.602 mi.) 50 107 DEQ Id: 98668 UTILITIES SERVICES G 2623 CENTER ST E 1/2 - 1 (0.990 mi.) 54 211 DEQ Id: 64016

State and tribal leaking storage tank lists LUST: The Leaking Underground Storage Tank Incident Reports contain an inventory of reported leaking underground storage tank incidents. The data come from the Department of Environmental Control’s Spill Tracking Reports.

A review of the LUST list, as provided by EDR, and dated 07/11/2017 has revealed that there are 16 LUST sites within approximately 0.5 miles of the target property.

______Equal/Higher Elevation ______Address Direction ______/ Distance Map _____ ID Page _____ FIELD CLUB OF OMAHA 3615 WOOLWORTH ENE 1/4 - 1/2 (0.286 mi.) 40 92 File Number: 110899-CT-0930 File Number: 10040-MRF-1000 Facility Status: NEBRASKA RBCA TIER I OR TIER II INVESTIGATION Facility Status: NO FURTHER ACTION (INCIDENT CLOSED)

______Lower Elevation ______Address Direction______/ Distance Map _____ ID Page _____ CENTER MALL 42 & CENTER ST SW 0 - 1/8 (0.010 mi.) B21 79 File Number: 011691-KM-0900 File Number: 020791-99-0006 Facility Status: LUST TRUST FUND PRIORITY LIST - PENDING WORK Facility Status: NO FURTHER ACTION (INCIDENT CLOSED) DOUGLAS COUNTY HOSPI 4102 WOOLWORTH AVE NNW 0 - 1/8 (0.020 mi.) 23 80

TC5092548.2s EXECUTIVE SUMMARY 11 EXECUTIVE SUMMARY

File Number: 04137-BHI-1600 File Number: 100592-CT-1510 Facility Status: NO FURTHER ACTION (INCIDENT CLOSED) Facility Status: BACKLOGGED - NOT YET INVESTIGATED CREDIT CAR CENTER IN 4201 CENTER ST SW 0 - 1/8 (0.035 mi.) B27 83 File Number: AP8162 Facility Status: NO FURTHER ACTION (INCIDENT CLOSED) EAGLE FOOD MART INC 3707 CENTER ST ESE 0 - 1/8 (0.113 mi.) C32 85 File Number: 081398-GW-1030 Facility Status: NO FURTHER ACTION (INCIDENT CLOSED) FAMILY SERVICES 2101 SOUTH 42ND SSW 1/8 - 1/4 (0.143 mi.) D34 88 File Number: 052897-99-0007 Facility Status: NO FURTHER ACTION (INCIDENT CLOSED) MCPHERSON SERVICE 3563 CENTER ST ESE 1/8 - 1/4 (0.203 mi.) E35 88 File Number: 041599-NM-1000 Facility Status: LUST TRUST FUND PRIORITY LIST - PENDING WORK FREEWAY SERVICE 3555 CENTER ESE 1/8 - 1/4 (0.230 mi.) E36 90 File Number: 081087-99-0000 Facility Status: NO FURTHER ACTION (INCIDENT CLOSED) NAGL MANUFACTURING C 3626 MARTHA ST SE 1/4 - 1/2 (0.261 mi.) 38 91 File Number: 120597-NM-1400 Facility Status: NO FURTHER ACTION (INCIDENT CLOSED) UPRR 39TH & PACIFIC 39TH & PACIFIC NNE 1/4 - 1/2 (0.267 mi.) 39 92 File Number: 031986-99-0000 Facility Status: NO FURTHER ACTION (INCIDENT CLOSED) TEDS SERVICE 4525 CENTER STREET WSW 1/4 - 1/2 (0.301 mi.) 41 93 File Number: 091297-TH-1007 Facility Status: NEBRASKA RBCA TIER I OR TIER II INVESTIGATION KIEWIT CONSTRUCTION 3921 MASON ST N 1/4 - 1/2 (0.307 mi.) 42 97 File Number: 072012-NH-1520 File Number: 030499-99-0003 File Number: 100192-99-0000 Facility Status: NO FURTHER ACTION (INCIDENT CLOSED) NORRIS JR HIGH SCHOO 2235 S 46 ST SSW 1/4 - 1/2 (0.416 mi.) 43 101 File Number: 03280-KAM-1500 Facility Status: NO FURTHER ACTION (INCIDENT CLOSED) MARCY STREET DRUM SI 3902 MARCY ST N 1/4 - 1/2 (0.428 mi.) F45 103 File Number: 052093-NM-0730 Facility Status: NO FURTHER ACTION (INCIDENT CLOSED) TOTAL 1893 4103 LEAVENWORTH N 1/4 - 1/2 (0.481 mi.) 46 104 File Number: 102898-TH-1130 File Number: 091693-JB-1500 Facility Status: NO FURTHER ACTION (INCIDENT CLOSED) COMMUNITY ALLIANCE I 4001 LEAVENWORTH ST N 1/4 - 1/2 (0.496 mi.) 47 104 File Number: 011993-EL-1330 Facility Status: NO FURTHER ACTION (INCIDENT CLOSED)

TC5092548.2s EXECUTIVE SUMMARY 12 EXECUTIVE SUMMARY

State and tribal registered storage tank lists UST: The Underground Storage Tank database contains registered USTs. USTs are regulated under Subtitle I of the Resource Conservation and Recovery Act (RCRA). The data come from the Department of Environmental Control’s Facility and Tank Data.

A review of the UST list, as provided by EDR, and dated 05/02/2017 has revealed that there are 6 UST sites within approximately 0.25 miles of the target property.

______Lower Elevation ______Address Direction ______/ Distance Map _____ ID Page _____ DOUGLAS COUNTY HOSPI 4102 WOOLWORTH AVE NNW 0 - 1/8 (0.020 mi.) 23 80 Tank Id/Tank Status: Currently in Use Facility ID: 1866 Facility ID: 4045 CREDIT CAR CENTER IN 4201 CENTER ST SW 0 - 1/8 (0.035 mi.) B27 83 Facility ID: 8162 EAGLE FOOD MART INC 3707 CENTER ST ESE 0 - 1/8 (0.113 mi.) C32 85 Tank Id/Tank Status: Currently in Use Facility ID: 565 FAMILY SERVICE 2101 S 42ND ST SSW 1/8 - 1/4 (0.143 mi.) D33 87 Facility ID: 11501 MCPHERSON SERVICE 3563 CENTER ST ESE 1/8 - 1/4 (0.203 mi.) E35 88 Facility ID: 3490 FREEWAY SERVICE 3555 CENTER ST ESE 1/8 - 1/4 (0.230 mi.) E37 90 Facility ID: 4670

State and tribal Brownfields sites BROWNFIELDS: A listing of potential brownfields sites.

A review of the BROWNFIELDS list, as provided by EDR, and dated 09/18/2017 has revealed that there is 1 BROWNFIELDS site within approximately 0.5 miles of the target property.

______Lower Elevation ______Address Direction ______/ Distance Map _____ ID Page _____ FIELD CLUB TRAIL SIT 3911 LEAVENWORTH ST N 1/4 - 1/2 (0.498 mi.) 48 105 Facility Id: 98410

ADDITIONAL ENVIRONMENTAL RECORDS

Local Lists of Registered Storage Tanks HIST UST: A listing of underground storage tank locations. This listing contains detail information that the UST listing does not. It is no longer updated by the agency. For current information see the UST listing.

A review of the HIST UST list, as provided by EDR, and dated 02/28/2005 has revealed that there are 3

TC5092548.2s EXECUTIVE SUMMARY 13 EXECUTIVE SUMMARY

HIST UST sites within approximately 0.25 miles of the target property.

______Lower Elevation ______Address Direction ______/ Distance Map _____ ID Page _____ DOUGLAS COUNTY HOSPI 4102 WOOLWORTH AVE NNW 0 - 1/8 (0.020 mi.) 23 80 Facility Id: 4045 EAGLE FOOD MART INC 3707 CENTER ST ESE 0 - 1/8 (0.113 mi.) C32 85 Facility Id: 565 MCPHERSON SERVICE 3563 CENTER ST ESE 1/8 - 1/4 (0.203 mi.) E35 88 Facility Id: 3490

Other Ascertainable Records FUDS: The Listing includes locations of Formerly Used Defense Sites Properties where the US Army Corps Of Engineers is actively working or will take necessary cleanup actions.

A review of the FUDS list, as provided by EDR, and dated 01/31/2015 has revealed that there is 1 FUDS site within approximately 1 mile of the target property.

______Equal/Higher Elevation ______Address Direction ______/ Distance Map _____ ID Page _____ OMAHA AF STA Z-71 N 1/2 - 1 (0.821 mi.) 52 210

ROD: Record of Decision. ROD documents mandate a permanent remedy at an NPL (Superfund) site containing technical and health information to aid the cleanup.

A review of the ROD list, as provided by EDR, and dated 09/27/2017 has revealed that there is 1 ROD site within approximately 1 mile of the target property.

______Equal/Higher Elevation ______Address Direction ______/ Distance Map _____ ID Page _____ OMAHA LEAD INTERSECTION I480 & 0 - 1/8 (0.000 mi.) 0 55

PRP: A listing of verified Potentially Responsible Parties

A review of the PRP list, as provided by EDR, and dated 10/25/2013 has revealed that there is 1 PRP site within approximately 0.001 miles of the target property.

______Equal/Higher Elevation ______Address Direction ______/ Distance Map _____ ID Page _____ OMAHA LEAD INTERSECTION I480 & 0 - 1/8 (0.000 mi.) 0 55

LEAD SMELTERS: A listing of former lead smelter site locations.

A review of the LEAD SMELTERS list, as provided by EDR, has revealed that there is 1 LEAD SMELTERS site within approximately 0.001 miles of the target property.

______Equal/Higher Elevation ______Address Direction ______/ Distance Map _____ ID Page _____ OMAHA LEAD INTERSECTION I480 & 0 - 1/8 (0.000 mi.) 0 55 Database: LEAD SMELTER 1, Date of Government Version: 05/30/2017

TC5092548.2s EXECUTIVE SUMMARY 14 EXECUTIVE SUMMARY

EDR HIGH RISK HISTORICAL RECORDS

EDR Exclusive Records EDR Hist Auto: EDR has searched selected national collections of business directories and has collected listings of potential gas station/filling station/service station sites that were available to EDR researchers. EDR’s review was limited to those categories of sources that might, in EDR’s opinion, include gas station/filling station/service station establishments. The categories reviewed included, but were not limited to gas, gas station, gasoline station, filling station, auto, automobile repair, auto service station, service station, etc. This database falls within a category of information EDR classifies as "High Risk Historical Records", or HRHR. EDR’s HRHR effort presents unique and sometimes proprietary data about past sites and operations that typically create environmental concerns, but may not show up in current government records searches.

A review of the EDR Hist Auto list, as provided by EDR, has revealed that there are 6 EDR Hist Auto sites within approximately 0.125 miles of the target property.

______Lower Elevation ______Address Direction ______/ Distance Map _____ ID Page _____ JENSEN SERVICE GARAG 709 39TH ST S SE 0 - 1/8 (0.011 mi.) 22 80 DINGERS TEXACO SERVI 4119 CENTER ST SW 0 - 1/8 (0.023 mi.) B24 82 ILLIS LOUIS GAS STA 4201 CENTER ST SW 0 - 1/8 (0.035 mi.) B26 83 COUNTRY CORNER INC 3831 CENTER RD ESE 0 - 1/8 (0.038 mi.) 28 84 CENTER STREET CONOCO 3741 CENTER ST ESE 0 - 1/8 (0.087 mi.) C29 85 JENSEN NELS FILLING 2038 42ND S SSW 0 - 1/8 (0.088 mi.) 30 85

EDR Hist Cleaner: EDR has searched selected national collections of business directories and has collected listings of potential dry cleaner sites that were available to EDR researchers. EDR’s review was limited to those categories of sources that might, in EDR’s opinion, include dry cleaning establishments. The categories reviewed included, but were not limited to dry cleaners, cleaners, laundry, laundromat, cleaning/laundry, wash & dry etc. This database falls within a category of information EDR classifies as "High Risk Historical Records", or HRHR. EDR’s HRHR effort presents unique and sometimes proprietary data about past sites and operations that typically create environmental concerns, but may not show up in current government records searches.

A review of the EDR Hist Cleaner list, as provided by EDR, has revealed that there are 2 EDR Hist Cleaner sites within approximately 0.125 miles of the target property.

______Lower Elevation ______Address Direction ______/ Distance Map _____ ID Page _____ PARKS CLEANERS & TAI 4001 CENTER ST SSW 0 - 1/8 (0.024 mi.) 25 83 CLOTHING CARE CENTER 3717 CENTER ST ESE 0 - 1/8 (0.096 mi.) C31 85

TC5092548.2s EXECUTIVE SUMMARY 15 EXECUTIVE SUMMARY

Due to poor or inadequate address information, the following sites were not mapped. Count: 10 records.

______Site Name ______Database(s) FORMER OMAHA SHOT WORKS FACILITY/A SEMS-ARCHIVE, LEAD SMELTERS LAST 36TH & FARNAM STS LUST UPRR UST SITE 516 LUST UNMC OMAHA WOMEN’S CLUB LUST ENCOR CENTRAL AREA RECYCL LUST OMAHA PUBLIC POWER DIST LUST TERRACE PLAZA LUST VA MED CENTER SHOP AREA LUST PIERCE ST TANK SITE LUST

TC5092548.2s EXECUTIVE SUMMARY 16 1

6 6

0 1

1 1

1 120 0

6 1

0 0

1 0 200 1 40 2 0 2 1 1 6 1 1 1

1 0

1 2 1 0 1 1 kkVV 2 0 1 691 6 0 0 16 0 2 1 1 2 0 0 1 2 0 0 1 1 6 0 1 1 1 0 00

2 1 8 0 1 1 2

0 6 0 6

0 1 1 0

1 1 1 1 0 1 1 1 6 6 1 1 6 0 0 1 1 6 2 0 2 0

0 0 2

0 1 1 2

0 1 4 1

4 2 0

2 2

0 1 0

0 2 1 2 1 0 0 2 0 0 0 0 0 0 0 6 8 8 1 0 0 1 1 1 1 2 4 0

0 1 2 0 6 1 1 1 1

6 1 1

0 0 0 2 2 0 1 1 0 1

2 1 00 1 2 1 1 1 6 1 0

0 1 1 1 6 1 1 1 0 1 1 2 0 0 2 8

0 0

1 2

1 0

6 0 1 0 1 6 0

0 1

0 6

2 0 1 1 0

2 1 1 6 6 0 0 0 1 0

0 1

2 1

0 0

0 6 1 1 1 2 1 1 0 1 1 60 1 6 0 0 1 1 2 6

2 1 0 0 1 00 1 0 6 1 4 2 0 0 1 1 200 4 2 1 2 0 0 0 1 6 1 1 1 6 2 0 0 1 0 1 2 1 1 2 0 0 4 200 0 1

EDR Inc. 1160

1200

1240

1200

1160

20 1 1

1200

1160

1200 1160

EDR Inc. MAP FINDINGS SUMMARY

Search Distance Target Total Database(Miles) Property < 1/8 1/8 - 1/4 1/4 - 1/2 1/2 - 1 > 1 Plotted

STANDARD ENVIRONMENTAL RECORDS

Federal NPL site list NPL 1.000 1 0 0 0 NR 1 Proposed NPL 1.000 0 0 0 0 NR 0 NPL LIENS 0.001 0 NR NR NR NR 0 Federal Delisted NPL site list Delisted NPL 1.000 0 0 0 0 NR 0 Federal CERCLIS list FEDERAL FACILITY 0.500 0 0 0 NR NR 0 SEMS 0.500 1 0 0 NR NR 1 Federal CERCLIS NFRAP site list SEMS-ARCHIVE 0.500 1 0 0 1 NR NR 2 Federal RCRA CORRACTS facilities list CORRACTS 1.000 0 0 0 1 NR 1 Federal RCRA non-CORRACTS TSD facilities list RCRA-TSDF 0.500 0 0 0 NR NR 0 Federal RCRA generators list RCRA-LQG 0.250 0 0 NR NR NR 0 RCRA-SQG 0.250 1 0 0 NR NR NR 1 RCRA-CESQG 0.250 0 0 NR NR NR 0 Federal institutional controls / engineering controls registries LUCIS 0.500 0 0 0 NR NR 0 US ENG CONTROLS 0.500 1 0 0 NR NR 1 US INST CONTROL 0.500 1 0 0 NR NR 1 Federal ERNS list ERNS 0.001 3 0 NR NR NR NR 3 State- and tribal - equivalent CERCLIS SHWS 1.000 1 0 0 1 4 NR 6 State and tribal landfill and/or solid waste disposal site lists SWF/LF 0.500 0 0 0 NR NR 0 State and tribal leaking storage tank lists LAST 0.500 1 0 0 0 NR NR 1 LUST 0.500 2 4 3 9 NR NR 18 INDIAN LUST 0.500 0 0 0 NR NR 0 State and tribal registered storage tank lists FEMA UST 0.250 0 0 NR NR NR 0

TC5092548.2s Page 4 MAP FINDINGS SUMMARY

Search Distance Target Total Database(Miles) Property < 1/8 1/8 - 1/4 1/4 - 1/2 1/2 - 1 > 1 Plotted

UST 0.250 3 3 3 NR NR NR 9 AST 0.250 0 0 NR NR NR 0 INDIAN UST 0.250 0 0 NR NR NR 0 State and tribal institutional control / engineering control registries INST CONTROL 0.500 0 0 0 NR NR 0 State and tribal voluntary cleanup sites INDIAN VCP 0.500 0 0 0 NR NR 0 VCP 0.500 0 0 0 NR NR 0 State and tribal Brownfields sites BROWNFIELDS 0.500 0 0 1 NR NR 1

ADDITIONAL ENVIRONMENTAL RECORDS

Local Brownfield lists US BROWNFIELDS 0.500 0 0 0 NR NR 0 Local Lists of Landfill / Solid Waste Disposal Sites SWRCY 0.500 0 0 0 NR NR 0 INDIAN ODI 0.500 0 0 0 NR NR 0 DEBRIS REGION 9 0.500 0 0 0 NR NR 0 ODI 0.500 0 0 0 NR NR 0 IHS OPEN DUMPS 0.500 0 0 0 NR NR 0 Local Lists of Hazardous waste / Contaminated Sites US HIST CDL 0.001 0 NR NR NR NR 0 US CDL 0.001 0 NR NR NR NR 0 Local Lists of Registered Storage Tanks HIST UST 0.250 1 2 1 NR NR NR 4 HIST AST 0.001 0 NR NR NR NR 0 Local Land Records LIENS 2 0.001 0 NR NR NR NR 0 Records of Emergency Release Reports HMIRS 0.001 0 NR NR NR NR 0 SPILLS 0.001 0 NR NR NR NR 0 SPILLS 90 0.001 0 NR NR NR NR 0 SPILLS 80 0.001 0 NR NR NR NR 0 Other Ascertainable Records RCRA NonGen / NLR 0.250 0 0 NR NR NR 0 FUDS 1.000 0 0 0 1 NR 1 DOD 1.000 0 0 0 0 NR 0

TC5092548.2s Page 5 MAP FINDINGS SUMMARY

Search Distance Target Total Database(Miles) Property < 1/8 1/8 - 1/4 1/4 - 1/2 1/2 - 1 > 1 Plotted

SCRD DRYCLEANERS 0.500 0 0 0 NR NR 0 US FIN ASSUR 0.001 0 NR NR NR NR 0 EPA WATCH LIST 0.001 0 NR NR NR NR 0 2020 COR ACTION 0.250 0 0 NR NR NR 0 TSCA 0.001 0 NR NR NR NR 0 TRIS 0.001 0 NR NR NR NR 0 SSTS 0.001 0 NR NR NR NR 0 ROD 1.000 1 0 0 0 NR 1 RMP 0.001 0 NR NR NR NR 0 RAATS 0.001 0 NR NR NR NR 0 PRP 0.001 1 NR NR NR NR 1 PADS 0.001 0 NR NR NR NR 0 ICIS 0.001 1 0 NR NR NR NR 1 FTTS 0.001 1 0 NR NR NR NR 1 MLTS 0.001 1 0 NR NR NR NR 1 COAL ASH DOE 0.001 0 NR NR NR NR 0 COAL ASH EPA 0.500 0 0 0 NR NR 0 PCB TRANSFORMER 0.001 0 NR NR NR NR 0 RADINFO 0.001 0 NR NR NR NR 0 HIST FTTS 0.001 1 0 NR NR NR NR 1 DOT OPS 0.001 0 NR NR NR NR 0 CONSENT 1.000 0 0 0 0 NR 0 INDIAN RESERV 0.001 0 NR NR NR NR 0 FUSRAP 1.000 0 0 0 0 NR 0 UMTRA 0.500 0 0 0 NR NR 0 LEAD SMELTERS 0.001 1 NR NR NR NR 1 US AIRS 0.001 1 0 NR NR NR NR 1 US MINES 0.250 0 0 NR NR NR 0 ABANDONED MINES 0.001 0 NR NR NR NR 0 FINDS 0.001 1 0 NR NR NR NR 1 DOCKET HWC 0.001 0 NR NR NR NR 0 UXO 1.000 0 0 0 0 NR 0 ECHO 0.001 1 0 NR NR NR NR 1 FUELS PROGRAM 0.250 0 0 NR NR NR 0 AIRS 0.001 1 0 NR NR NR NR 1 DRYCLEANERS 0.250 0 0 NR NR NR 0 Financial Assurance 0.001 0 NR NR NR NR 0 NPDES 0.001 1 0 NR NR NR NR 1 TIER 2 0.001 1 0 NR NR NR NR 1 UIC 0.001 0 NR NR NR NR 0

EDR HIGH RISK HISTORICAL RECORDS

EDR Exclusive Records EDR MGP 1.000 0 0 0 0 NR 0 EDR Hist Auto 0.125 6 NR NR NR NR 6 EDR Hist Cleaner 0.125 2 NR NR NR NR 2

EDR RECOVERED GOVERNMENT ARCHIVES

Exclusive Recovered Govt. Archives RGA HWS 0.001 1 0 NR NR NR NR 1

TC5092548.2s Page 6 MAP FINDINGS SUMMARY

Search Distance Target Total Database(Miles) Property < 1/8 1/8 - 1/4 1/4 - 1/2 1/2 - 1 > 1 Plotted

RGA LUST 0.001 6 0 NR NR NR NR 6

- Totals -- 30 24 7 12 6 0 79

NOTES: TP = Target Property NR = Not Requested at this Search Distance Sites may be listed in more than one database

TC5092548.2s Page 7 Map ID MAP FINDINGS Direction Distance EDR ID Number Elevation Site Database(s) EPA ID Number

A1 VA AUXILIARY POWER BLDG LUST S105954381 Target 4101 WOOLWORTH, HEATING PLANT N/A Property OMAHA, NE

Site 1 of 20 in cluster A

Actual: LUST: 1223 ft. Facility Status: BACKLOGGED - NOT YET INVESTIGATED Incident Type: UNDERGROUND STORAGE TANK - REGULATED UNDER FEDERAL RULES File Number: 012203-QK-1630 Owner/RP: VETERANS ADMINISTRATION SFM Num: 8007 Owner Mailing Address: 4101 WOOLWORT AVE Owner Mailing City: OMAHA Owner Mailing State: NE Owner Mailing Zip: 68105 Discovery Date: 01/21/2003 Material Released: DIESEL, FOR GENERATOR

Facility Status: BACKLOGGED - NOT YET INVESTIGATED Incident Type: UNDERGROUND STORAGE TANK - REGULATED UNDER FEDERAL RULES File Number: 012203-QK-1630 Owner/RP: VETERANS ADMINISTRATION SFM Num: 8007 Owner Mailing Address: 4101 WOOLWORT AVE Owner Mailing City: OMAHA Owner Mailing State: NE Owner Mailing Zip: 68105 Discovery Date: 01/21/2003 Material Released: DIESEL, FOR GENERATOR

A2 VA AUXILIARY POWER RGA LUST S115146823 Target 4101 WOOLWORTH, HE N/A Property OMAHA, NE

Site 2 of 20 in cluster A

Actual: RGA LUST: 1223 ft. 2012 VA AUXILIARY POWER 4101 WOOLWORTH, HE

2011 VA AUXILIARY POWER 4101 WOOLWORTH, HE

2010 VA AUXILIARY POWER 4101 WOOLWORTH, HE

A3 UNI OF NEBRASKA/OMAHA MED CTRUST U004124530 Target MOTOR POOL - BLDG 402 708 S 40TH ST N/A Property OMAHA, NE 68198

Site 3 of 20 in cluster A

Actual: UST: 1223 ft. Facility: Facility ID: 6681 Owner Name: UNO MED CTR Owner Address: 987100 NEBRASKA MEDICAL CENTER Owner City,St,Zip: OMAHA, NE 68198 Tanks Currently In Use: 0 Tanks Temp Out Of Use: 0

TC5092548.2s Page 8 Map ID MAP FINDINGS Direction Distance EDR ID Number Elevation Site Database(s) EPA ID Number

UNI OF NEBRASKA/OMAHA MED CTR (Continued) U004124530 Tanks Perm Out Of Use: 0 Tanks Closed In Place: 0 Tanks Removed: 2

Owner: UNO MED CTR Owner Address: 987100 NEBRASKA MEDICAL CENTER Owner City,St,Zip: OMAHA, NE 68198 Owner Phone: Not reported Tank Corrosion Protection: Not reported Tank Id/Tank Status: 1 / Not Reported Tank Contents: Not reported Tank Size: Not reported Tank Date Installed: Not reported Tank Type: Not reported Tank Construction: Not reported Tank Internal Protection: Not reported Tank External Protection: Not reported Tank Secondary Containment: Not reported Piping Construction Material: Not reported

A4 OMAHA VA MEDICAL CENTER ICIS 1000214310 Target 4101 WOOLWORTH AVE US AIRS N/A Property OMAHA, NE 68105 FINDS ECHO Site 4 of 20 in cluster A

Actual: ICIS: 1223 ft. Enforcement Action ID: 07-2013-0305 FRS ID: 110001508084 Action Name: UNITED STATES DEPARTMENT OF VETERANS AFFAIRS NEBRASKA-WESTERN IOWA HEALTH CARE Facility Name: OMAHA VA MEDICAL CENTER Facility Address: 4101 WOOLWORTH AVE OMAHA, NE 68105-1873 Enforcement Action Type: RCRA 3008A AO For Comp And/Or Penalty Facility County: DOUGLAS Program System Acronym: RCRAINFO Enforcement Action Forum Desc: Administrative - Formal EA Type Code: 3008A Facility SIC Code: Not reported Federal Facility ID: Not reported Latitude in Decimal Degrees: 41.24496 Longitude in Decimal Degrees: -95.97489 Permit Type Desc: Not reported Program System Acronym: NE3360010315 Facility NAICS Code: Not reported Tribal Land Code: Not reported

US AIRS (AFS): Envid: 1000214310 Region Code: 07 County Code: NE055 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 D and B Number: Not reported Facility Site Name: OMAHA VA MEDICAL CENTER

TC5092548.2s Page 9 Map ID MAP FINDINGS Direction Distance EDR ID Number Elevation Site Database(s) EPA ID Number

OMAHA VA MEDICAL CENTER (Continued) 1000214310 Primary SIC Code: 8062 NAICS Code: 622110 Default Air Classification Code: SMI Facility Type of Ownership Code: FDF Air CMS Category Code: SMI HPV Status: Not reported US AIRS (AFS): Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 2003-03-12 00:00:00 Activity Status Date: 2016-08-12 09:31:42 Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Active

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 2003-04-18 00:00:00 Activity Status Date: 2016-08-12 09:31:42 Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Active

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 2005-01-26 00:00:00 Activity Status Date: 2016-08-12 09:31:42 Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Active

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 2006-03-14 00:00:00 Activity Status Date: 2016-08-12 09:31:42 Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Active

Region Code: 07 Programmatic ID: AIR NECOO0003105500037

TC5092548.2s Page 10 Map ID MAP FINDINGS Direction Distance EDR ID Number Elevation Site Database(s) EPA ID Number

OMAHA VA MEDICAL CENTER (Continued) 1000214310 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 2007-05-01 00:00:00 Activity Status Date: 2016-08-12 09:31:42 Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Active

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 2008-03-07 00:00:00 Activity Status Date: 2016-08-12 09:31:42 Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Active

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 2008-12-23 00:00:00 Activity Status Date: 2016-08-12 09:31:43 Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Active

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 2010-04-21 00:00:00 Activity Status Date: 2010-05-13 18:13:41 Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Active

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 2010-04-21 00:00:00 Activity Status Date: 2016-08-12 09:31:43 Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Active

TC5092548.2s Page 11 Map ID MAP FINDINGS Direction Distance EDR ID Number Elevation Site Database(s) EPA ID Number

OMAHA VA MEDICAL CENTER (Continued) 1000214310 Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 2011-06-09 00:00:00 Activity Status Date: 2016-08-12 09:31:42 Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Active

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 2012-06-04 00:00:00 Activity Status Date: 2016-08-12 09:31:43 Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Active

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 2013-12-11 00:00:00 Activity Status Date: 2016-08-12 09:31:43 Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Active

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1975-10-08 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1976-07-23 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring

TC5092548.2s Page 12 Map ID MAP FINDINGS Direction Distance EDR ID Number Elevation Site Database(s) EPA ID Number

OMAHA VA MEDICAL CENTER (Continued) 1000214310 Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1976-08-03 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1976-09-07 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1976-11-29 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1976-12-23 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

TC5092548.2s Page 13 Map ID MAP FINDINGS Direction Distance EDR ID Number Elevation Site Database(s) EPA ID Number

OMAHA VA MEDICAL CENTER (Continued) 1000214310 Activity Date: 1977-01-27 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1977-02-28 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1977-03-03 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1977-04-06 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1978-07-21 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084

TC5092548.2s Page 14 Map ID MAP FINDINGS Direction Distance EDR ID Number Elevation Site Database(s) EPA ID Number

OMAHA VA MEDICAL CENTER (Continued) 1000214310 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1978-08-31 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1978-10-12 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1978-12-21 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1979-02-26 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1981-09-29 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

TC5092548.2s Page 15 Map ID MAP FINDINGS Direction Distance EDR ID Number Elevation Site Database(s) EPA ID Number

OMAHA VA MEDICAL CENTER (Continued) 1000214310 Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1981-10-27 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1981-11-23 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1981-12-23 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1982-01-29 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1982-02-17 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring

TC5092548.2s Page 16 Map ID MAP FINDINGS Direction Distance EDR ID Number Elevation Site Database(s) EPA ID Number

OMAHA VA MEDICAL CENTER (Continued) 1000214310 Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1982-03-24 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1982-04-13 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1982-05-12 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1982-07-28 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

TC5092548.2s Page 17 Map ID MAP FINDINGS Direction Distance EDR ID Number Elevation Site Database(s) EPA ID Number

OMAHA VA MEDICAL CENTER (Continued) 1000214310 Activity Date: 1982-08-26 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1982-09-30 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1982-10-27 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1982-11-29 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1982-12-14 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084

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OMAHA VA MEDICAL CENTER (Continued) 1000214310 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1983-01-21 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1983-03-10 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1983-06-21 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1983-08-09 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1983-11-21 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

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OMAHA VA MEDICAL CENTER (Continued) 1000214310 Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1983-12-23 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1984-01-31 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1984-10-04 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1984-11-20 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1985-01-29 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring

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OMAHA VA MEDICAL CENTER (Continued) 1000214310 Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1986-01-27 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1988-02-23 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1988-07-06 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1989-10-25 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

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OMAHA VA MEDICAL CENTER (Continued) 1000214310 Activity Date: 1990-09-13 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1991-02-14 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1992-01-17 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1992-12-18 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1993-11-23 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084

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OMAHA VA MEDICAL CENTER (Continued) 1000214310 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1994-12-06 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1995-12-14 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1997-01-06 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 1998-01-20 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 2000-01-20 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

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OMAHA VA MEDICAL CENTER (Continued) 1000214310 Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 2001-03-13 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 2003-03-12 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 2003-04-18 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 2005-01-26 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 2006-03-14 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring

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OMAHA VA MEDICAL CENTER (Continued) 1000214310 Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 2007-05-01 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 2008-03-07 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 2008-12-23 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 2010-04-21 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

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OMAHA VA MEDICAL CENTER (Continued) 1000214310 Activity Date: 2011-06-09 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 2012-06-04 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

Region Code: 07 Programmatic ID: AIR NECOO0003105500037 Facility Registry ID: 110001508084 Air Operating Status Code: OPR Default Air Classification Code: SMI Air Program: State Implementation Plan for National Primary and Secondary Ambient Air Quality Standards Activity Date: 2013-12-11 00:00:00 Activity Status Date: Not reported Activity Group: Compliance Monitoring Activity Type: Inspection/Evaluation Activity Status: Not reported

FINDS:

Registry ID: 110001508084

Environmental Interest/Information System AFS (Aerometric Information Retrieval System (AIRS) Facility Subsystem) replaces the former Compliance Data System (CDS), the National Emission Data System (NEDS), and the Storage and Retrieval of Aerometric Data (SAROAD). AIRS is the national repository for information concerning airborne pollution in the United States. AFS is used to track emissions and compliance data from industrial plants. AFS data are utilized by states to prepare State Implementation Plans to comply with regulatory programs and by EPA as an input for the estimation of total national emissions. AFS is undergoing a major redesign to support facility operating permits required under Title V of the Clean Air Act.

NCDB (National Compliance Data Base) supports implementation of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Toxic Substances Control Act (TSCA). The system tracks inspections in regions and states with cooperative agreements, enforcement actions, and settlements.

AIR SYNTHETIC MINOR

AIR EMISSIONS CLASSIFICATION UNKNOWN

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OMAHA VA MEDICAL CENTER (Continued) 1000214310 FEDERAL FACILITY HAZARDOUS WASTE DOCKET

RCRAInfo is a national information system that supports the Resource Conservation and Recovery Act (RCRA) program through the tracking of events and activities related to facilities that generate, transport, and treat, store, or dispose of hazardous waste. RCRAInfo allows RCRA program staff to track the notification, permit, compliance, and corrective action activities required under RCRA.

STATE MASTER

ICIS (Integrated Compliance Information System) is the Integrated Compliance Information System and provides a database that, when complete, will contain integrated Enforcement and Compliance information across most of EPA’s programs. The vision for ICIS is to replace EPA’s independent databases that contain Enforcement data with a single repository for that information. Currently, ICIS contains all Federal Administrative and Judicial enforcement actions. This information is maintained in ICIS by EPA in the Regional offices and it Headquarters. A future release of ICIS will replace the Permit Compliance System (PCS) which supports the NPDES and will integrate that information with Federal actions already in the system. ICIS also has the capability to track other activities occurring in the Region that support Compliance and Enforcement programs. These include; Incident Tracking, Compliance Assistance, and Compliance Monitoring.

Click this hyperlink while viewing on your computer to access additional FINDS: detail in the EDR Site Report.

ECHO: Envid: 1000214310 Registry ID: 110001508084 DFR URL: http://echo.epa.gov/detailed-facility-report?fid=110001508084

A5 VA MEDICAL CENTER - OMAHA SEMS-ARCHIVE 1015735226 Target 4101 WOOLWORTH AVE RCRA-SQG NE3360010315 Property OMAHA, NE 68105

Site 5 of 20 in cluster A

Actual: SEMS-ARCHIVE: 1223 ft. Site ID: 702024 EPA ID: NE3360010315 Federal Facility: Y NPL: Not on the NPL Non NPL Status: NFRAP-Site does not qualify for the NPL based on existing information

Following information: was gathered from the prior CERCLIS update completed in 10/2013: Site ID: 0702024 Federal Facility: Federal Facility NPL Status: Not on the NPL Non NPL Status: NFRAP-Site does not qualify for the NPL based on existing information

CERCLIS-NFRAP Site Contact Details: Contact Sequence ID: 7372607.00000 Person ID: 7271615.00000

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VA MEDICAL CENTER - OMAHA (Continued) 1015735226

CERCLIS-NFRAP Assessment History: Action: PRELIMINARY ASSESSMENT Date Started: 04/01/84 Date Completed: 04/01/84 Priority Level: NFRAP-Site does not qualify for the NPL based on existing information

Action: ARCHIVE SITE Date Started: / / Date Completed: 04/01/84 Priority Level: Not reported

Action: DISCOVERY Date Started: / / Date Completed: 08/01/80 Priority Level: Not reported

RCRA-SQG: Date form received by agency: 11/19/2012 Facility name: US DEPARTMENT OF VETERANS AFFAIRS NEBRASKA-WESTERN IOWA HEALTH CARE SYSTEM Facility address: 4101 WOOLWORTH OMAHA, NE 68105 EPA ID: NE3360010315 Mailing address: WOOLWORTH OMAHA, NE 68105 Contact: ROBIN M FRIED Contact address: WOOLWORTH OMAHA, NE 68105 Contact country: US Contact telephone: 402-995-4442 Contact email: Not reported EPA Region: 07 Land type: Federal Classification: Small Small Quantity Generator Description: Handler: generates more than 100 and less than 1000 kg of hazardous waste during any calendar month and accumulates less than 6000 kg of hazardous waste at any time; or generates 100 kg or less of hazardous waste during any calendar month, and accumulates more than 1000 kg of hazardous waste at any time

Owner/Operator Summary: Owner/operator name: VETERANS HEALTH ADMINISTRATION Owner/operator address: Not reported Not reported Owner/operator country: US Owner/operator telephone: Not reported Owner/operator email: Not reported Owner/operator fax: Not reported Owner/operator extension: Not reported Legal status: Federal Owner/Operator Type: Operator Owner/Op start date: 01/01/1950 Owner/Op end date: Not reported

Owner/operator name: US DEPT OF VETERANS AFFAIRS Owner/operator address: Not reported

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VA MEDICAL CENTER - OMAHA (Continued) 1015735226 Not reported Owner/operator country: US Owner/operator telephone: Not reported Owner/operator email: Not reported Owner/operator fax: Not reported Owner/operator extension: Not reported Legal status: Federal Owner/Operator Type: Owner Owner/Op start date: 01/01/1950 Owner/Op end date: Not reported

Handler Activities Summary: U.S. importer of hazardous waste: No Mixed waste (haz. and radioactive): No Recycler of hazardous waste: No Transporter of hazardous waste: No Treater, storer or disposer of HW: No Underground injection activity: No On-site burner exemption: No Furnace exemption: No Used oil fuel burner: No Used oil processor: No User oil refiner: No Used oil fuel marketer to burner: No Used oil Specification marketer: No Used oil transfer facility: No Used oil transporter: No

. Waste code: D001 . Waste name: IGNITABLE WASTE

. Waste code: D002 . Waste name: CORROSIVE WASTE

. Waste code: D003 . Waste name: REACTIVE WASTE

. Waste code: D005 . Waste name: BARIUM

. Waste code: D007 . Waste name: CHROMIUM

. Waste code: D008 . Waste name: LEAD

. Waste code: D009 . Waste name: MERCURY

. Waste code: D011 . Waste name: SILVER

. Waste code: D022 . Waste name: CHLOROFORM

. Waste code: D024 . Waste name: M-CRESOL

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VA MEDICAL CENTER - OMAHA (Continued) 1015735226 . Waste code: D028 . Waste name: 1,2-DICHLOROETHANE

. Waste code: D035 . Waste name: METHYL ETHYL KETONE

. Waste code: D038 . Waste name: PYRIDINE

. Waste code: F003 . Waste name: THE FOLLOWING SPENT NONHALOGENATED SOLVENTS: XYLENE, ACETONE, ETHYL ACETATE, ETHYL BENZENE, ETHYL ETHER, METHYL ISOBUTYL KETONE, N-BUTYL ALCOHOL, CYCLOHEXANONE, AND METHANOL; ALL SPENT SOLVENT MIXTURES/BLENDS CONTAINING, BEFORE USE, ONLY THE ABOVE SPENT NONHALOGENATED SOLVENTS; AND ALL SPENT SOLVENT MIXTURES/BLENDS CONTAINING, BEFORE USE, ONE OR MORE OF THE ABOVE NONHALOGENATED SOLVENTS, AND A TOTAL OF TEN PERCENT OR MORE (BY VOLUME) OF ONE OR MORE OF THOSE SOLVENTS LISTED IN F001, F002, F004, AND F005; AND STILL BOTTOMS FROM THE RECOVERY OF THESE SPENT SOLVENTS AND SPENT SOLVENT MIXTURES.

. Waste code: P001 . Waste name: 2H-1-BENZOPYRAN-2-ONE, 4-HYDROXY-3-(3-OXO-1-PHENYLBUTYL)-, & SALTS, WHEN PRESENT AT CONCENTRATIONS GREATER THAN 0.3% (OR) WARFARIN, & SALTS, WHEN PRESENT AT CONCENTRATIONS GREATER THAN 0.3%

. Waste code: P023 . Waste name: ACETALDEHYDE, CHLORO- (OR) CHLOROACETALDEHYDE

. Waste code: P042 . Waste name: 1,2-BENZENEDIOL, 4-[1-HYDROXY-2-(METHYLAMINO)ETHYL]-, (R)- (OR) EPINEPHRINE

. Waste code: P075 . Waste name: NICOTINE, & SALTS (OR) PYRIDINE, 3-(1-METHYL-2-PYRROLIDINYL)-,(S)-, & SALTS

. Waste code: P081 . Waste name: 1,2,3-PROPANETRIOL, TRINITRATE (R) (OR) NITROGLYCERINE (R)

. Waste code: P087 . Waste name: OSMIUM OXIDE OSO4, (T-4)- (OR) OSMIUM TETROXIDE

. Waste code: P098 . Waste name: POTASSIUM CYANIDE (OR) POTASSIUM CYANIDE K(CN)

. Waste code: P106 . Waste name: SODIUM CYANIDE (OR) SODIUM CYANIDE NA(CN)

. Waste code: U001 . Waste name: ACETALDEHYDE (I) (OR) ETHANAL (I)

. Waste code: U002 . Waste name: 2-PROPANONE (I) (OR) ACETONE (I)

. Waste code: U007 . Waste name: 2-PROPENAMIDE (OR) ACRYLAMIDE

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VA MEDICAL CENTER - OMAHA (Continued) 1015735226 . Waste code: U010 . Waste name: AZIRINO [2’,3’:3,4]PYRROLO[1,2-A]INDOLE-4,7-DIONE, 6-AMINO-8-[[(AMINOCARBONYL)OXY]METHYL]-1,1A,2,8,8A,8B-HEXAHYDRO-8A-MET HOXY-5-METHYL-, [1AS-(1AALPHA, 8BETA, 8AALPHA, 8BALPHA)]- (OR) MITOMYCIN C

. Waste code: U035 . Waste name: BENZENEBUTANOIC ACID, 4-[BIS(2-CHLOROETHYL)AMINO]- (OR) CHLORAMBUCIL

. Waste code: U044 . Waste name: CHLOROFORM (OR) METHANE, TRICHLORO-

. Waste code: U050 . Waste name: CHRYSENE

. Waste code: U058 . Waste name: 2H-1,3,2-OXAZAPHOSPHORIN-2-AMINE, N,N-BIS(2-CHLOROETHYL)TETRAHYDRO-, 2-OXIDE (OR) CYCLOPHOSPHAMIDE

. Waste code: U059 . Waste name: 5,12-NAPHTHACENEDIONE, 8-ACETYL-10-[(3-AMINO-2,3,6-TRIDEOXY)-ALPHA-L-LYXO-HEXOPYRANOSYL)OXY]- 7,8,9,10-TETRAHYDRO-6,8,11-TRIHYDROXY-1-METHOXY-, (8S-CIS)- (OR) DAUNOMYCIN

. Waste code: U080 . Waste name: METHANE, DICHLORO- (OR) METHYLENE CHLORIDE

. Waste code: U122 . Waste name: FORMALDEHYDE

. Waste code: U150 . Waste name: L-PHENYLALANINE, 4-[BIS(2-CHLOROETHYL)AMINO]- (OR) MELPHALAN

. Waste code: U151 . Waste name: MERCURY

. Waste code: U162 . Waste name: 2-PROPENOIC ACID, 2-METHYL-, METHYL ESTER (I,T) (OR) METHYL METHACRYLATE (I,T)

. Waste code: U165 . Waste name: NAPHTHALENE

. Waste code: U170 . Waste name: P-NITROPHENOL (I,T) (OR) PHENOL, 4-NITRO-

. Waste code: U188 . Waste name: PHENOL

. Waste code: U200 . Waste name: RESERPINE (OR) YOHIMBAN-16-CARBOXYLIC ACID, 11,17-DIMETHOXY-18-[(3,4,5-TRIMETHOXYBENZOYL)OXY]-, METHYL ESTER, (3BETA, 16BETA, 17ALPHA, 18BETA, 20ALPHA)-

. Waste code: U203 . Waste name: 1,3-BENZODIOXOLE, 5-(2-PROPENYL)- (OR) SAFROLE

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VA MEDICAL CENTER - OMAHA (Continued) 1015735226 . Waste code: U205 . Waste name: SELENIUM SULFIDE (OR) SELENIUM SULFIDE SES2 (R,T)

. Waste code: U206 . Waste name: D-GLUCOSE, 2-DEOXY-2-[[(METHYLNITROSOAMINO)-CARBONYL]AMINO]- (OR) GLUCOPYRANOSE, 2-DEOXY-2-(3-METHYL-3-NITROSOUREIDO)-,D- (OR) STREPTOZOTOCIN

. Waste code: U237 . Waste name: 2,4-(1H,3H)-PYRIMIDINEDIONE, 5-[BIS(2-CHLOROETHYL)AMINO]- (OR) URACIL MUSTARD

. Waste code: U328 . Waste name: BENZENAMINE, 2-METHYL- (OR) O-TOLUIDINE

Historical Generators: Date form received by agency: 07/25/2012 Site name: US DEPARTMENT OF VETERANS AFFAIRS NEBRASKA-WESTERN IOWA HEALTH CARE SYSTEM Classification: Large Quantity Generator

. Waste code: D001 . Waste name: IGNITABLE WASTE

. Waste code: D002 . Waste name: CORROSIVE WASTE

. Waste code: D003 . Waste name: REACTIVE WASTE

. Waste code: D005 . Waste name: BARIUM

. Waste code: D007 . Waste name: CHROMIUM

. Waste code: D008 . Waste name: LEAD

. Waste code: D009 . Waste name: MERCURY

. Waste code: D011 . Waste name: SILVER

. Waste code: D022 . Waste name: CHLOROFORM

. Waste code: D024 . Waste name: M-CRESOL

. Waste code: D028 . Waste name: 1,2-DICHLOROETHANE

. Waste code: D035 . Waste name: METHYL ETHYL KETONE

TC5092548.2s Page 32 Map ID MAP FINDINGS Direction Distance EDR ID Number Elevation Site Database(s) EPA ID Number

VA MEDICAL CENTER - OMAHA (Continued) 1015735226 . Waste code: D038 . Waste name: PYRIDINE