Appendix C XRF Results, Explanation of XRF Data

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1 Appendix C XRF Results, Explanation of XRF Data Youth s Benefit Elementary School-Preliminary Hazardous Material Findings Harford County Public Schools F&R Project Number 75S May 2, 2014

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7 Appendix D TCLP Laboratory Results Youth s Benefit Elementary School-Preliminary Hazardous Material Findings Harford County Public Schools F&R Project Number 75S May 2, 2014

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13 Appendix E Licenses Youth s Benefit Elementary School-Preliminary Hazardous Material Findings Harford County Public Schools F&R Project Number 75S May 2, 2014

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18 Youth s Benefit Elementary School Fallston, Maryland Harford County Public Schools F&R Project # 75S0002 May 2, 2014 SECTION LEAD CONTAINING PAINT HAZARD REDUCTION PART 1 - GENERAL 1.1 REFERENCES A. The publications listed below form a part of this specification to the extent referenced. The publications are referred within the text by the basic designation only. AMERICAN NATIONAL STANDARDS INSTITUTE (ANSI) ANSI Z9.2 ANSI Z88.2 (1979; R 1991) Fundamentals Governing the Design and Operation of Local Exhaust Systems (1992) Respiratory Protection CODE OF FEDERAL REGULATIONS (CFR) 29 CFR Safety Training and Education 29 CFR Access to Employee Exposure and Medical Records 29 CFR Gases, Vapors, Fumes, Dusts, and Mists 29 CFR Hazard Communication 29 CFR Lead Exposure in Construction 29 CFR Hazardous Waste Operations and Emergency Response 29 CFR Respiratory Protection 40 CFR 260 Hazardous Waste Management Systems: General 40 CFR 261 Identification and Listing of Hazardous Waste 40 CFR 262 Generators of Hazardous Waste 40 CFR 263 Transporters of Hazardous Waste 40 CFR 264 Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities LEAD CONTAINING PAINT HAZARD REDUCTION

19 Youth s Benefit Elementary School Fallston, Maryland Harford County Public Schools F&R Project # 75S0002 May 2, CFR 265 Interim Status Standard for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities 40 CFR 268 Land Disposal Restrictions 49 CFR 172 Hazardous Materials, Tables, and Hazardous Materials Communications Regulations 49 CFR 178 Shipping Container Specification UNDERWRITERS LABORATORIES INC. (UL) UL 586 (1996) High-Efficiency, Particulate, Air Filter Units 1.2 DEFINITIONS A. Action Level Employee exposure, without regard to use of respirators, to an airborne concentration of lead of 30 micrograms per cubic meter of air averaged over an 8 hour period in an occupational/industrial environment. B. Area Sampling Sampling of lead concentrations within the lead control area and inside the physical boundaries that is representative of the airborne lead concentrations but is not collected in the breathing zone of personnel. C. Competent Person (CP) As used in this section, refers to a person employed by the Contractor who is trained in the recognition and control of lead hazards in accordance with current federal, State, and local regulations. D. Contaminated Room Room for removal of contaminated personal protective equipment (PPE). E. Decontamination Shower Facility That facility that encompasses a clean clothing storage room, and a contaminated clothing storage and disposal rooms, with a shower facility in between. F. Eight-Hour Time Weighted Average (TWA) Airborne concentration of lead to which an employee is exposed, averaged over an 8 hour workday as indicated in 29 CFR LEAD CONTAINING PAINT HAZARD REDUCTION

20 Youth s Benefit Elementary School Fallston, Maryland Harford County Public Schools F&R Project # 75S0002 May 2, 2014 G. High Efficiency Particulate Air (HEPA) Filter Equipment HEPA filtered vacuuming equipment with a UL 586 filter system capable of collecting and retaining lead-contaminated paint dust. A high efficiency particulate filter means percent efficient against 0.3 micron or larger size particles. H. Lead Metallic lead, inorganic lead compounds, and organic lead soaps. I. Lead-Containing Paint (LCP) Lead-based paint or other similar surface coating containing lead or lead compound in excess of 0.06 percent by weight of the total nonvolatile content of the paint. J. Lead-Containing Paint Hazard (LBP Hazard) Any condition that causes exposure to lead from lead-contaminated dust, leadcontaminated soil, and lead-based paint that is deteriorated or present in accessible surfaces, friction surfaces, or impact surfaces that would result in adverse human health effects. K. Lead Control Area An enclosed area or structure, constructed as a temporary containment equipped with HEPA filtered local exhaust, which prevents the spread of lead dust, paint chips, or debris existing as a condition of lead-based paint removal operations. The lead control area is also isolated by physical boundaries to prevent unauthorized entry of personnel. L. Lead Permissible Exposure Limit (PEL) Fifty micrograms per cubic meter of air as an 8 hour time weighted average as determined by 29 CFR If an employee is exposed for more than eight hours in a workday, the PEL shall be determined by the following formula: M. NIOSH PEL (micrograms/cubic meter of air) = 400/No. Hours worked per day The National Institute for Occupational Safety and Health. N. Personal Sampling Sampling of airborne lead concentrations within the breathing zone of an employee to determine the 8 hour time weighted average concentration in accordance with 29 CFR Samples shall be representative of the employees' work tasks. Breathing zone shall be considered an area within a hemisphere, forward of the shoulders, with a radius of 6 to 9 inches and centered at the nose or mouth of an employee. LEAD CONTAINING PAINT HAZARD REDUCTION

21 Youth s Benefit Elementary School Fallston, Maryland Harford County Public Schools F&R Project # 75S0002 May 2, 2014 O. Physical Boundary Area physically roped or partitioned off around an enclosed lead control area to limit unauthorized entry of personnel. As used in this section, "inside boundary" shall mean the same as "outside lead control area but inside boundary." 1.3 LEAD HAZARD AWARENESS AND SCOPE OF WORK The Contractor shall assume that all surfaces contain Lead Containing Paint (LCP). Based on the nature of the project, LCP abatement is not anticipated since disturbance of LCP is expected to be incidental to over-all demolition work. The Contractor shall complete all demolition work in accordance with the requirements found in 29 CFR All personnel that will be involved in demolition activities as part of this project shall receive a minimum 2-Hour Lead in Construction Awareness Training in accordance with 29 CFR PERSONNEL PROTECTION The Contractor shall provide adequate personal protective equipment (PPE) to any employees working on lead coated surfaces if there is a potential for generation of airborne lead dust or fume (e.g., through grinding, cutting, sanding, etc.) above the Permissible Exposure Limit (29 CFR ). Prior to demonstrating through a Negative Initial Determination (NID) as defined in 29 CFR (d)(3) that workers are not exposed to lead above 50 micrograms per cubic meter (ug/m 3 ) over an 8-hour time weighted average (TWA), the Contractor shall provide the following minimum respiratory protection for the following activities: A NIOSH approved half-face respirator for manual demolition of structures, manual scraping, manual sanding, heat gun applications, and power tool cleaning with dust collection systems. A NIOSH approved full-face respirator for rivet busing; power tool cleaning without dust collection systems; cleanup activities where dry expendable abrasives are used; and abrasive blasting enclosure movement and removal. A NIOSH approved Powered Air Purifying Respirator for abrasive blasting, welding, cutting, and torch burning. The Contractor shall also provide workers in demolition areas with coveralls or similar full-body work clothing; gloves, hats, and shoes or disposable shoe coverlets; and face shields, vented goggles, or other appropriate protective equipment which complies with 29 CFR EXPOSURE MONITORING Should the Contractor wish to eliminate the PPE described in Section 1.4 of this specification, then they shall perform a NID as described in 29 CFR (d)(3). LEAD CONTAINING PAINT HAZARD REDUCTION

22 Youth s Benefit Elementary School Fallston, Maryland Harford County Public Schools F&R Project # 75S0002 May 2, 2014 This NID will include breathing zone sampling of workers who are performing a specific task. The results of the NID will be compared to the OSHA Permissible Exposure Limit (PEL) for lead of 50 ug/m 3 as an 8-hour TWA. Should the results of the air sampling be below the PEL for lead, then the Contractor may discontinue the use of PPE as described in Section 1.4. Should the results of the air monitoring demonstrate that workers are exposed above the PEL, then they shall continue to utilize the PPE described in Section 1.4. The Contractor shall also provide exposure monitoring at least every 6 months until at least two consecutive measurements, taken at least 7 days apart, are below the Action Level of 30 ug/m 3 as an 8-hour TWA at which time the employer may discontinue monitoring for that employee unless there has been a change of equipment, process, control, personnel or a new task has been initiated that may result in additional employees being exposed to lead at or above 30 ug/m 3. The Contractor should make allowances in the bid price for the cost of environmental and personnel monitoring, along with costs for provision of all other related services, monitoring, equipment, etc. needed to comply with requirements found within 29 CFR The Contractor shall be required to conduct personnel air monitoring to establish personal exposure levels. This monitoring information will be used by the Contractor to determine the levels of personnel protection and environmental controls (if necessary) required to be used by the Contractor for this contract. Monitoring shall be performed under the direction of the Competent Person. The costs for PPE, monitoring, decontamination facilities, etc. shall be borne by the Contractor. The Contractor shall also be required to conduct air monitoring during the course of the project to document airborne lead levels. 1.6 WASTE DISPOSAL It is expected that waste debris will be generated by this project, which contains lead coated surfaces. Based on the lead content identified on surfaces, it is unlikely that demolition debris from this project will need to be disposed of as hazardous waste based on its lead content. A Toxic Characteristic Leaching Procedure (TCLP) test of the waste stream to determine its leachable lead content in accordance with EPA hazardous waste disposal requirements found in 40 CFR was performed for each Building by F&R with all of the results revealing a leachable lead content below 5 ppm. It is our opinion that this waste can be disposed of as general demolition debris. The Contractor is responsible for notifying all other parties who may receive this waste that it may have lead-coated surfaces. PART 2 - PRODUCTS Section not used. LEAD CONTAINING PAINT HAZARD REDUCTION

23 Youth s Benefit Elementary School Fallston, Maryland Harford County Public Schools F&R Project # 75S0002 May 2, 2014 PART 3 - EXECUTION 3.1 GENERAL HOUSEKEEPING Clean-up of floors and other surfaces where lead accumulates shall wherever possible, be cleaned by vacuuming or other methods that minimize the likelihood of lead becoming airborne. Shoveling, dry or wet sweeping, and brushing may be used only where vacuuming or other equally effective methods have been tried and found not to be effective. Where vacuuming methods are selected, the vacuums shall be equipped with High Efficiency Particulate Air (HEPA) filters and used and emptied in a manner which minimizes the reentry of lead into the workplace. Compressed air shall not be used to remove lead from any surface unless the compressed air is used in conjunction with a ventilation system designed to capture the airborne dust created by the compressed air. 3.2 HYGIENE FACILITIES AND PRACTICES A. Prohibited Practices The Contractor shall assure that in areas where employees are exposed to lead above the PEL without regard to the use of respirators, food or beverage is not present or consumed, tobacco products are not present or used, and cosmetics are not applied. B. Change Areas The Contractor shall assure the following for employees whose airborne exposure to lead is known or assumed to be above the PEL, without regard to the use of respirators: Shall provide clean change areas The change areas shall be equipped with separate storage facilities for protective work clothing and equipment and for street clothes which prevent crosscontamination. Employees do not leave the workplace wearing any protective clothing or equipment that is required to be worn during the work shift. C. Showers The Contractor shall provide shower facilities, where feasible, for use by employees whose airborne exposure to lead is known or assumed to be above the PEL. Employees shall shower at the end of the work shift. An adequate supply of cleansing agents and towels for use by affected employees shall be provided. Where showers cannot be provided, the Contractor shall at a minimum provide hand washing facilities. Affected employees must wash their hands and face at the end of the shift and prior to entering non-contaminated areas LEAD CONTAINING PAINT HAZARD REDUCTION

24 Youth s Benefit Elementary School Fallston, Maryland Harford County Public Schools F&R Project # 75S0002 May 2, 2014 D. Eating Facilities The Contractor shall provide lunchroom facilities or eating areas for employees whose airborne exposure to lead is known or assumed to be above the PEL. The lunchroom facilities shall be as free as practicable from lead contamination and are readily accessible to employees. Employees whose airborne exposure to lead is known or assumed to be above the PEL shall wash their hands and face prior to eating, drinking, smoking or applying cosmetics. The Contractor shall assure that employees do not enter lunchroom facilities or eating areas with protective work clothing or equipment unless surface lead dust has been removed by vacuuming, downdraft booth, or other cleaning method that limits dispersion of lead dust. E. Warning Signs The Contractor shall post the following warning signs in each work area where an employee's exposure to lead is known or assumed to be above the PEL: DANGER LEAD WORK AREA MAY DAMAGE FERTILITY OR THE UNBORN CHILD CAUSES DAMAGE TO THE CENTRAL NERVOUS SYSTEM DO NOT EAT, DRINK OR SMOKE IN THIS AREA END OF SECTION LEAD CONTAINING PAINT HAZARD REDUCTION

25 Youth s Benefit Elementary School Fallston, Maryland Harford County Public Schools F&R Project # 75S0002 May 2, 2014 SECTION PCB AND MERCURY EQUIPMENT REMOVAL PART 1 - GENERAL 1.1 REFERENCES A. The publications listed below form a part of this specification to the extent referenced. The publications are referred to within the text by the basic designation only. CODE OF FEDERAL REGULATIONS (CFR) 29 CFR Air Contaminants 40 CFR 761 Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce, and Use Prohibitions 40 CFR 261 Resource Conservation and Recovery Act 40 CFR 262 Generators of Hazardous Waste 40 CFR 263 Transporters of Hazardous Waste 49 CFR 172 Hazardous Materials, Table, and Hazardous Materials Communications Regulations 49 CFR 178 Shipping Container Specification 1.2 REQUIREMENTS Removal and disposal of non-pcb and PCB containing light ballasts, associated mercury-containing lamps, and mercury-containing thermometers/thermostats that will be impacted by renovation activities at Ballou Senior High School. A. Scope of Work The Contractor will be responsible for having a valid EPA Identification Number site specific for Youth s Benefit Elementary School. The Contractor will be the GENERATOR of all hazardous waste generated and be subject to regulations set forth by the United States Environmental Protection Agency. If the generation of hazardous waste is greater than 2,200 lbs in a month, the generator is considered a Large Quantity Generator. Generation of less than 2,200 lbs in a month is classified as a Small Quantity Generator. The Contractor will manage, handle, ship, and dispose of all hazardous waste in accordance with all applicable regulations. PCB AND MERCURY EQUIPMENT REMOVAL

26 Youth s Benefit Elementary School Fallston, Maryland Harford County Public Schools F&R Project # 75S0002 May 2, 2014 The Contractor has the responsibility for determining actual quantities of materials to be removed and reviewing the scope of work. No additional contract price adjustments will be allowed due to variances between actual quantities and the estimated quantities listed herein (unless otherwise specified in this document). The Contractor should allow under their base bid for the removal of all materials as described in the survey report and/or referenced in this specification. The Contractor shall be responsible for removal of the following as part of the base bid: 1. Non-PCB containing light ballasts (approximately 1,000) 2. Mercury containing fluorescent light lamps (approximately 3,000) 3. Mercury-containing thermostats/thermometers (approximately 100) Note: The Abatement Contractor shall coordinate with the Electrical and General Contractors to ensure that all appropriate systems that will be impacted by demolition have been properly decommissioned prior to the start of any work. 1.3 DEFINITIONS A. Certified Industrial Hygienist (CIH) An industrial hygienist who shall be certified by the American Board of Industrial Hygiene. B. Leak Leak or leaking means any instance in which PCB or mercury-containing equipment has any PCBs or mercury on any portion of its external surface. C. Mercury-Containing Equipment As used in this specification shall mean all fluorescent bulbs and non-digital thermostats and thermometers scheduled for demolition and/or removal as indicated in the Contract documents that: 1. Fails the TCLP test for mercury, or 2. According to the Manufacturer, would fail the TCLP test for mercury 3. By calculation of equivalent TCLP mercury level from total metal analysis would fail the TCLP test for mercury. PCB AND MERCURY EQUIPMENT REMOVAL

27 Youth s Benefit Elementary School Fallston, Maryland Harford County Public Schools F&R Project # 75S0002 May 2, 2014 D. Polychlorinated Biphenyls (PCBs) PCBs as used in this specification shall mean the same as PCBs, PCB containing lighting ballast, and PCB container, as defined in 40 CFR 761, Section 3, Definitions. E. Spill Spill means both intentional and unintentional spills, leaks, and other uncontrolled discharges when the release results in any quantity of PCBs or mercury running off or about to run off the external surface of the equipment or other PCB or mercury source, as well as the contamination resulting from those releases. F. Generator Any person, by site, whose action or process produces hazardous waste identified or listed in [40 CFR part 261] or whose act first causes a hazardous waste to become subject to regulation. 1.4 QUALITY ASSURANCE A. Regulatory Requirements Perform PCB related work in accordance with 40 CFR 761. Perform mercurycontaining equipment storage and transport in accordance with 40 CFR 262 and 40 CFR 263. B. Training All workers shall have training in accordance with 29 CFR (HAZWOPER). The instruction shall include: The dangers of PCB and mercury exposure, decontamination, safe work practices, and applicable OSHA and EPA regulations. The Owner or their representative shall review and approve the PCB and Mercury-Containing Equipment Removal Work Plans. C. Regulation Documents Maintain at all times one copy each at the office and one copy each in view at the job site of 29 CFR , 40 CFR 761, 40 CFR 262, 40 CFR 263 and of the Contractor removal work plan and disposal plan for PCB and mercurycontaining equipment. 1.5 SUBMITTALS Submit two copies of the following documentation: A. Certificates 1. Training Certification PCB AND MERCURY EQUIPMENT REMOVAL

28 Youth s Benefit Elementary School Fallston, Maryland Harford County Public Schools F&R Project # 75S0002 May 2, PCB and Mercury-Containing Equipment Removal Work Plan 3. PCB and Mercury-Containing Equipment Disposal Work Plan B. Closeout Submittals 1. Transporter certification of notification to EPA of their PCB and mercury waste activities and EPA ID numbers 2. Certification of Decontamination 3. Certificate of Disposal and/or recycling. Submit to The Owner before application for payment within 30 days of the date that the disposal of the PCB and mercury-containing waste identified on the manifest was completed. 1.6 ENVIRONMENTAL REQUIREMENTS Use special clothing: A. Disposable gloves (polyethylene) B. Eye protection C. PPE 1.7 SCHEDULING Notify The Owner 20 days prior to the start of PCB and mercury-containing equipment removal work. 1.8 QUALITY ASSURANCE A. PCB and Mercury-Containing Equipment Removal Work Plan Submit a job-specific plan within 20 calendar days after award of contract of the work procedures to be used in the removal, packaging, and storage of PCB-containing lighting ballasts, associated mercury-containing lamps and mercury-containing thermostats. Include in the plan: Requirements for U.C. Personal Protective Equipment (PPE), spill cleanup procedures and equipment, eating, smoking and restroom procedures. Obtain approval of the plan by The Owner prior to the start of PCB and mercury-containing equipment removal work. B. PCB and Mercury-Containing Equipment Disposal Plan Submit two copies of a PCB and mercury-containing equipment Disposal Plan within 20 calendar days after award of contract. The PCB and Mercury- PCB AND MERCURY EQUIPMENT REMOVAL

29 Youth s Benefit Elementary School Fallston, Maryland Harford County Public Schools F&R Project # 75S0002 May 2, 2014 Containing Equipment Disposal Plan shall comply with applicable requirements of federal, state, and local PCB and RCRA waste regulations and address: 1. Estimated quantities of wastes to be generated, disposed of, and recycled. 2. Names and qualifications of each Contractor that will be transporting, storing, treating, and disposing of the wastes. Include the facility location. Furnish two copies of EPA and state PCB and mercury-containing equipment waste permit applications and EPA identification numbers. 3. Names and qualifications (experience and training) of personnel who will be working on-site with PCB and mercury-containing equipment wastes. 4. Spill prevention, containment, and cleanup contingency measures to be implemented. 5. Work plan and schedule for PCB and mercury-containing equipment waste removal, containment, storage, transportation, disposal and or recycling. Wastes shall be cleaned up and containerize daily. PART 2 - PRODUCTS Not used. PART 3 - EXECUTION 3.1 WORK PROCEDURE Furnish labor, materials, services, and equipment necessary for the removal of PCB containing lighting ballasts, associated mercury-containing fluorescent lamps, mercury vapor bulbs, and mercury-containing thermostats in accordance with local, state, or federal regulations. Do not expose PCBs to open flames or other high temperature sources since toxic decomposition by-products may be produced. Do not break mercury containing equipment. A. Work Operations Ensure that work operations or processes involving PCB or PCB-contaminated materials are conducted in accordance with 40 CFR 761, 40 CFR CFR 263, and the applicable requirements of this section, including but not limited to: 1. Obtaining suitable PCB and mercury-containing equipment storage sites. PCB AND MERCURY EQUIPMENT REMOVAL

30 Youth s Benefit Elementary School Fallston, Maryland Harford County Public Schools F&R Project # 75S0002 May 2, Notifying the Owner prior to commencing the operation. 3. Reporting leaks and spills to the Owner. 4. Cleaning up spills. 5. Inspecting PCB and PCB-contaminated items and waste containers for leaks and forwarding two copies of inspection reports to the Owner. 6. Maintaining inspection, inventory and spill records. 3.2 PCB SPILL CLEANUP REQUIREMENTS A. PCB Spills Immediately report to the Contracting Officer any PCB spills. B. PCB Spill Control Area Rope off an area around the edges of a PCB leak or spill and post a "PCB Spill Authorized Personnel Only" caution sign. Immediately transfer leaking items to a drip pan or other container. C. PCB Spill Cleanup 40 CFR 761, subpart G. Initiate cleanup of spills as soon as possible, but no later than 24 hours of its discovery. Mop up the liquid with rags or other conventional absorbent. The spent absorbent shall be properly contained and disposed of as solid PCB waste. D. Records and Certification Document the cleanup with records of decontamination in accordance with 40 CFR 761, Section 125, Requirements for PCB Spill Cleanup. Provide two copies of test results of cleanup and certification of decontamination. 3.3 MERCURY THERMOSTAT/THERMOMETER SPILL CLEANUP REQUIREMENTS A. Mercury Thermostat/Thermometer Spills Immediately report to the Contracting Officer any spills. B. Mercury Thermostat/Thermometer Spill Control Area Rope off an area around the edges of a mercury thermostat leak or spill and post a "Mercury Spill Authorized Personnel Only" caution sign. Immediately transfer leaking items to a drip pan or other container. PCB AND MERCURY EQUIPMENT REMOVAL

31 Youth s Benefit Elementary School Fallston, Maryland Harford County Public Schools F&R Project # 75S0002 May 2, 2014 C. Mercury Spill Cleanup Initiate cleanup of spills as soon as possible, but no later than 24 hours of its discovery. Mop up the liquid with rags or other conventional absorbent. The spent absorbent shall be properly contained and disposed of as mercury waste. D. Records and Certification Document the cleanup with records of decontamination in accordance with 40 CFR Provide two copies of test results of cleanup and certification of decontamination. 3.4 REMOVAL A. Ballasts As ballast is removed from the lighting fixture, inspect label on ballast. Ballasts without a No PCB label shall be assumed to contain PCBs and containerized and disposed of as required under paragraphs STORAGE FOR DISPOSAL and DISPOSAL. Ballasts with a No PCB label may be disposed of as normal construction debris. B. Lighting Lamps Remove lighting tubes/lamps from the lighting fixture and carefully place (unbroken) into appropriate containers (original transport boxes or equivalent). In the event of a lighting tube/lamp breaking, sweep and place waste in double plastic taped bags and dispose of as hazardous waste as specified herein. C. Thermostats/Thermometers Remove thermostats/thermometers intact and carefully place (unbroken) into appropriate containers. In the event of a thermostat breaking, follow the procedures in Section 3.3 of this specification. 3.5 STORAGE FOR DISPOSAL A. Storage Containers for PCBs 49 CFR 178. Store PCB in containers approved by DOT for PCB. B. Storage Containers for Lamps and Thermostats Store mercury-containing lamps in appropriate DOT containers. The boxes shall be stored and labeled for transport in accordance with 40 CFR 262 and 40 CFR 263. PCB AND MERCURY EQUIPMENT REMOVAL

32 Youth s Benefit Elementary School Fallston, Maryland Harford County Public Schools F&R Project # 75S0002 May 2, 2014 C. Labeling of Waste Containers Label with the following: 1. Date the item was placed in storage and the name of the cognizant activity/building. 2. "Caution Contains PCB," conforming to 40 CFR 761, CFR Subpart C. Affix labels to PCB waste containers. 3. Label mercury-containing equipment waste in accordance with 49 CFR 172, 40 CFR 262, and 40 CFR 263. Affix labels to all lighting waste containers. 3.5 DISPOSAL Intact PCB ballasts and mercury containing equipment will be transported and disposed of by the Contractor. Broken or leaking ballasts, lamps, and thermostats will be treated as hazardous waste and disposed of by the Contractor according to all applicable regulations. A. Identification Number Federal regulations 40 CFR 761 and 40 CFR 263 require that generators, transporters, commercial stores, and disposers of PCB and mercurycontaining waste posses U.S. EPA identification numbers. The contractor shall verify that the activity has a U.S. EPA generator identification number for use on the Uniform Hazardous Waste manifest. If not, the contractor shall advise the activity that it must file and obtain an I.D. number with EPA prior to commencement of removal work. B. Transporter Certification Comply with disposal and transportation requirements outlined in 40 CFR 761 and 40 CFR 263. Before transporting the PCB and mercury waste, sign and date the manifest-acknowledging acceptance of the PCB and mercurycontaining waste from The Owner. Return two signed copies to The Owner before leaving the job site. Ensure that the manifest accompanies the PCB and mercury waste at all times. Submit transporter certification of notification to EPA of their PCB and mercury waste activities (EPA Form ). C. Certificate of Disposal and/or Recycling Certificate for the PCB waste disposed shall include: 1. The identity of the disposal and or recycling facility, by name, address, and EPA identification number. PCB AND MERCURY EQUIPMENT REMOVAL

33 Youth s Benefit Elementary School Fallston, Maryland Harford County Public Schools F&R Project # 75S0002 May 2, The identity of the PCB waste affected by the Certificate of Disposal including reference to the manifest number for the shipment. 3. A statement certifying the fact of disposal and or recycling of the identified PCB waste, including the date(s) of disposal, and identifying the disposal process used. 4. A certification as defined in 40 CFR 761. END OF SECTION PCB AND MERCURY EQUIPMENT REMOVAL

34 FROEHLING & ROBERTSON, INC. Engineering Stability Since Dumbarton Road Richmond, Virginia T I F May 2, 2014 Mr. Charles A. Grebe Assistant Supervisor in Planning and Construction Harford County Public Schools Planning & Construction Department 102 South Hickory Avenue Bel Air, Maryland Re: Hazardous Materials Survey - Report of Findings Youth s Benefit Elementary School Primary Building 1901 Fallston Road Fallston, Maryland F&R Project #75S-0002 Dear Mr. Grebe: Froehling & Robertson, Inc. (F&R) performed a survey for hazardous materials at Youth s Benefit Elementary School s Primary Building in preparation for the scheduled demolition of the existing facility. The Primary Building is an approximately 39,256 square foot school structure built in The survey was performed by Blaine Owens and Matt Emery of F&R on April 21, A copy of Mr. Owens and Mr. Emery s Maryland asbestos and lead-based paint licenses are attached in Appendix E. The survey included the following: A review of existing asbestos-containing material (ACM) documentation; Supplemental sampling of suspect building components for ACM; Screening of surface coatings that may contain lead-based paint (LBP); Non-invasive inventory of suspect PCB-containing light ballasts and mercury-containing components. ASBESTOS-CONTAINING MATERIALS (ACM) For this project, a survey using limited intrusive sampling techniques for suspect ACMs was conducted at the above referenced site. F&R reviewed the Asbestos Management Plan for the facility prepared by Spots, Stevens, and McCoy, Inc. (SSM) and dated January 15, Samples were collected by F&R in general accordance with EPA-AHERA protocols and submitted to SanAir Technologies Laboratory, Inc. located in Powhatan, Virginia. SanAir is accredited for the analysis of bulk asbestos samples by the National Voluntary Laboratory Accreditation Program (NVLAP). A total of thirty-two (32) samples were collected by F&R and analyzed using Polarized Light Microscopy (PLM) following EPA Method 600/R- 93/116. Corporate HQ: 3015 Dumbarton Road Richmond, Virginia T F VIRGINIA NORTH CAROLINA SOUTH CAROLINA MARYLAND DISTRICT OF COLUMBIA A Minority-Owned Business

35 RESULTS (Refer to Appendix A for laboratory reports) The following table presents the results of F&R s supplemental sampling performed at the subject site. For a listing of previous identified ACMs, refer to the SSM Management Plan on file at Harford County Public Schools Division of Planning and Construction. Table 1: ACM Laboratory Results April 21, 2014 Sample ID Location Material Type % Asbestos 1 Primary Building - bathroom Ceramic tile NAD 2 Primary Building bathroom Ceramic tile grout NAD 3-tile Primary Building interior 12 x12 brown floor tile NAD 3-mastic Primary Building interior Brown floor tile mastic NAD 4-tile Primary Building interior 12 x12 green floor tile NAD 4-mastic Primary Building interior Green floor tile mastic NAD 5-tile Primary Building interior 12 x12 tan floor tile NAD 5-mastic Primary Building interior Tan floor tile mastic NAD 6 Primary Building interior 2 x4 ceiling tile w/ holes NAD 7-tile Primary Building interior 12 x12 white floor tile NAD 7-mastic Primary Building interior White floor tile mastic NAD 8-tile Primary Building interior 9 x9 gray floor tile ~15,000 SF 8-mastic Primary Building interior Gray floor tile mastic ~15,000 SF 5% Chrysotile 5% Chrysotile 9 Primary Building interior 2 x2 ceiling tile NAD 10 Primary Building interior 2 x4 textured ceiling tile NAD Youth s Benefit Elementary School-Hazardous Material Findings Harford County Public Schools F&R Project Number 75S May 2, 2014

36 Table 1: ACM Laboratory Results April 21, Primary Building interior 2 x4 ceiling tile w/ ½ fissures NAD 12 Primary Building crawlspace TSI jacket NAD 13 Primary Building multi-purpose room Stage curtain NAD 14 Primary Building office Cove base NAD 15 Primary Building hatch to roof Mastic NAD 16 Primary Building interior ceiling deck Fiberboard NAD 17 Primary Building B-side exterior Exterior window glazing <1% Chrysotile 18 Primary Building D-side exterior Exterior window glazing <1% Chrysotile 19 Primary Building exterior Exterior door caulk NAD 20-rough Primary Building exterior porch ceiling Plaster rough coat NAD 20-skim Primary Building - exterior porch ceiling Plaster skim coat <1% Chrysotile 21 Primary Building exterior Window/brick chase insulation NAD 22 Primary Building roof Silver roof flashing NAD 23 Primary Building roof Black roof flashing NAD 24- insulation Primary Building roof Roof core insulation NAD 24-foam Primary Building roof Roof core foam NAD 24-core Primary Building roof Roof core NAD 24-tar Primary Building - roof Roof core tar NAD During the conduct of this survey, sampling was limited to those materials which were safely accessible during F&R s limited intrusive survey. As such, some materials should be presumed to be positive, Youth s Benefit Elementary School-Hazardous Material Findings Harford County Public Schools F&R Project Number 75S May 2, 2014

37 unless or until sampling is conducted and they are shown to be negative. Such presumed asbestos containing materials (PACMS) include, but are not limited to: Fire door interiors, Chalk board mastic, Approximately 16 vibration collars/dampers, All boiler and pipe gaskets, Gaskets and packing materials in plumbing or hydraulic systems, where present, Electrical panel backing/arc deflectors/spark arresters, Chimneys and flues or other cementitious pipes or panels, Fire suppression curtains or blankets. Based on the information provided in the SSM report and the results of F&R s supplemental sampling and on-site observations, the following recommendations are made regarding ACM s within the facility: Per EPA s National Emission Standard for Hazardous Air Pollutants (NESHAP) regulation, all asbestos-containing pipe fitting insulation; which are defined as Regulated ACM (RACM), should be removed in a Negative Pressure Containment by a Maryland Licensed Asbestos Abatement Contractor prior to the demolition of the building. Per the NESHAP regulation, asbestos-containing fire doors; and miscellaneous asbestoscontaining caulks and sealants, which are defined as a Category II Non-Friable ACM, should be removed intact by a Maryland Asbestos Abatement Contractor prior to the demolition of the building. These materials can be removed without the use of a Negative Pressure Containment provided that they can be removed intact. Per NESHAP, the asbestos-containing vinyl floor tile and associated mastics, which are defined as Category I Non-Friable ACM, can stay in place during demolition of the building. However if these materials remain in-place during demolition, then all demolition debris will need to be disposed of as Category I Non-Friable ACM. Due to the large quantity of this material, Harford County Public Schools should receive confirmation that this is acceptable from the Maryland Department of the Environment (MDE). If Harford County Public Schools decides to remove this material prior to demolition, then it can be done so without the use of a Negative Pressure Containment provided that the material is removed intact without the use of mechanical means and area is limited to Maryland Licensed Asbestos Abatement Contractor/Personnel F&R recommends that a 3 rd party Industrial Hygienist perform on-site project monitoring during the removal of ACM s to verify that this work is performed in accordance with NESHAP and MDE regulations and that hidden areas of ACM s are revealed and abated prior to demolition of the building. F&R is available to provide 3 rd party on-site project monitoring during the removal of ACM s within the facility. Youth s Benefit Elementary School-Hazardous Material Findings Harford County Public Schools F&R Project Number 75S May 2, 2014

38 LEAD-BASED PAINT A screening survey for lead based paint was conducted by using a RMD LPA-1 X-Ray Fluorometer (XRF) Lead Paint Analyzer. The XRF contains a small radioisotopic source and operates on the principle of x-ray fluorescence, whereby lead atoms in paint are stimulated to emit characteristic x-rays, which are then detected by the instrument. The XRF can measure surface or non-surface concentrations of lead with 95% accuracy at the Maryland action level of 0.7 mg/cm 2. Levels of lead are reported in units of milligrams per square centimeter (mg/cm 2 ). The XRF is able to accurately detect as little as 0.1 mg/cm 2 of lead. The XRF classifies painted surfaces as positive or negative for lead content based on the Maryland action level (0.7 mg/cm 2 ) and the performance characteristics of the XRF. Positive: Negative: Lead is present at or above the Maryland standard of 0.7 mg/cm 2 on one or more of the components. Lead is not present at or above the Maryland standard of 0.7 mg/cm 2 on any of the components. Lead based paint or lead based glazing was detected on the following representative painted surfaces: Glazing on interior ceramic tile Exterior window systems Exterior door systems Baseboards Bright green chalkboards As per EPA s Resource Conservation and Recovery Act (RCRA) regulation, 40 CFR Part 261, F&R collected a composite sample of the proposed waste stream of building materials. The sample was submitted to SanAir Technologies Laboratory, Inc. to be analyzed for a Toxic Characteristic Leaching Procedure (TCLP) test for leachable lead content. The leachable lead content for the Primary Building was <0.20 ppm. Leachable lead content less than 5 parts per million (ppm), can be disposed of as non-hazardous waste (excluding other hazardous materials). Leachable lead content of 5 ppm or greater requires either segregating painted components and disposing of them as hazardous lead waste or disposal of the entire demolition waste stream as hazardous lead waste. PCB and MERCURY-CONTAINING BUILDING COMPONENTS F&R conducted an inventory of fluorescent light ballasts with the potential to contain poly-chlorinated biphenyls (PCB s) and potential mercury-containing building components including fluorescent light bulbs, fire alarms, exit signs, thermostats, and mechanical thermometers and gauges. During our survey of the building, F&R observed the following suspect materials throughout the facility: Approximately 2,000 mercury-containing fluorescent light bulbs Approximately 500 non-pcb-containing fluorescent light ballasts Suspect mercury-containing mechanical thermometers and gauges in the boiler room Suspect mercury-containing fire alarms Youth s Benefit Elementary School-Hazardous Material Findings Harford County Public Schools F&R Project Number 75S May 2, 2014

39 Suspect mercury-containing exit signs Suspect mercury-containing thermostats During demolition activities, F&R recommends that all fluorescent light ballasts be inspected for a label that states Non-PCBs. All ballasts that contain this label can be disposed of as municipal solid waste while the ballasts that do not contain this label should be disposed of as Universal Waste as defined by the EPA and the MDE. These materials should be removed intact and be disposed of or recycled at a facility that accepts these materials. Due to the amount of this material that may be encountered within the buildings (greater than 5,000 kilograms or 11,000 pounds), the entity handling this waste may be considered a large quantity handler. Should the amount of Universal Waste encountered reach the large quantity generator threshold, then the entity handling this waste will be required to notify appropriate regulatory agencies and retain documentation regarding handling and disposal of these materials. LIMITATIONS This letter has been prepared for the exclusive use of Harford County Public Schools or their agents. This report has been prepared in accordance with generally accepted environmental practices. No other warranty, expressed or implied, is made. Our conclusions and findings are based, in part, upon information provided to us by others and our site observations. We have not verified the completeness or accuracy of the information provided by others. Our findings are based upon information provided by others and current accepted industry standards. The scope of services performed was limited to those requested by the client and does not constitute a full hazardous materials assessment of the site. Professional services and scientific analyses have been performed, and recommendations prepared in accordance with customary principles in the fields of engineering and analytical science. This warranty is in lieu of all other warranties expressed or implied. The work performed in conjunction with this assessment and the data developed is intended as a description of available information at the dates and locations given. This letter does not warrant against future operations or conditions, nor does it warrant against extant, or future, conditions of a type or at a location not investigated. F&R, by virtue of providing the services described in this report, does not assume the responsibility of the person(s) in charge of the site, or otherwise undertake responsibility for reporting to any local, state, or federal public agencies any conditions at the site that may present a potential danger to public health, safety, or the environment. In areas that require notification of local, state, or federal agencies as required by law, it is the client s responsibility to so notify. Under this scope of services, F&R assumes no responsibility regarding any response actions or additional studies, which may be required as a result of these findings. Response actions are the sole responsibility of the Client and should be conducted in accordance with local, state, and/or federal requirements, and should be performed by appropriate trained and qualified personnel, as warranted. Youth s Benefit Elementary School-Hazardous Material Findings Harford County Public Schools F&R Project Number 75S May 2, 2014

40 Sincerely, FROEHLING & ROBERTSON, INC. Matt Emery Environmental Scientist Blaine Owens I.H Project Manager Attachments: Appendix A Asbestos Documentation, Laboratory Reports Appendix B - Sample Location Map Appendix C - XRF, Explanation of XRF data Appendix D TCLP laboratory Report Appendix E Licenses Youth s Benefit Elementary School-Hazardous Material Findings Harford County Public Schools F&R Project Number 75S May 2, 2014

41 Appendix A ASBESTOS DOCUMENTATION, LABORATORY REPORTS Youth s Benefit Elementary School-Preliminary Hazardous Material Findings Harford County Public Schools F&R Project Number 75S May 2, 2014

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56 Appendix B Sample Location Map Youth s Benefit Elementary School-Preliminary Hazardous Material Findings Harford County Public Schools F&R Project Number 75S May 2, 2014

57 Sample #18 Sample # 1-2 Sample #13 Sample #19 Sample #20 Samples #3, 4,5 Sample #8, 15, 16 Sample #17, 21 Sample #7 Samples #22-24 were collected from the roof-top Sample #6, 9, 10, 11, 14 Sample # 12 was collected from the crawlspace Primary Building Sample Location Map 1901 Fallston Road Fallston, MD Project No.: 75S-0002 Scale: NTS Date: 30-APR-2014 Drawn: ME Drawing No.: 1 Checked: APS

58 Appendix C XRF Results, Explanation of XRF Data Youth s Benefit Elementary School-Preliminary Hazardous Material Findings Harford County Public Schools F&R Project Number 75S May 2, 2014

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65 Appendix D TCLP Laboratory Results Youth s Benefit Elementary School-Preliminary Hazardous Material Findings Harford County Public Schools F&R Project Number 75S May 2, 2014

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76 FROEHLING & ROBERTSON, INC. Engineering Stability Since Dumbarton Road Richmond, Virginia T I F May 2, 2014 Mr. Charles A. Grebe Assistant Supervisor in Planning and Construction Harford County Public Schools Planning & Construction Department 102 South Hickory Avenue Bel Air, Maryland Re: Hazardous Materials Survey - Report of Findings Youth s Benefit Elementary School Intermediate Building 1901 Fallston Road Fallston, Maryland F&R Project #75S-0002 Dear Mr. Grebe: Froehling & Robertson, Inc. (F&R) performed a survey for hazardous materials at Youth s Benefit Elementary School s Intermediate Building in preparation for the scheduled demolition of the existing facility. The Intermediate Building is an approximately 52,775 square foot school structure built in The survey was performed by Blaine Owens and Matt Emery of F&R on April 21, A copy of Mr. Owens and Mr. Emery s Maryland asbestos and Lead-based paint licenses are attached in Appendix E. The survey included the following: A review of existing asbestos-containing material (ACM) documentation; Supplemental sampling of suspect building components for ACM; Screening of surface coatings that may contain lead-based paint (LBP); Non-invasive inventory of suspect PCB-containing light ballasts and mercury-containing components. ASBESTOS-CONTAINING MATERIALS (ACM) For this project, a survey using limited intrusive sampling techniques for suspect ACMs was conducted at the above referenced site. F&R reviewed the Asbestos Management Plan for the facility prepared by Spots, Stevens, and McCoy, Inc. (SSM) and dated January 15, Samples were collected by F&R in general accordance with EPA-AHERA protocols and submitted to SanAir Technologies Laboratory, Inc. located in Powhatan, Virginia. SanAir is accredited for the analysis of bulk asbestos samples by the National Voluntary Laboratory Accreditation Program (NVLAP). A total of sixty (60) samples were collected and analyzed using Polarized Light Microscopy (PLM) following EPA Method 600/R-93/116. Corporate HQ: 3015 Dumbarton Road Richmond, Virginia T F VIRGINIA NORTH CAROLINA SOUTH CAROLINA MARYLAND DISTRICT OF COLUMBIA A Minority-Owned Business

77 RESULTS (Refer to Appendix A for laboratory reports) The following table presents the results of F&R s supplemental sampling performed at the subject site. For a listing of previous identified ACMs, refer to the SSM Management Plan on file at Harford County Public Schools Division of Planning and Construction. Table 1: ACM Laboratory Results April 21, 2014 Sample ID Location Material Type % Asbestos 1 Intermediate Building Interior 12 x12 ceiling tile w/ ½ fissures NAD 2 Intermediate Building Interior 12 x12 ceiling tile w/ lines NAD 3 Intermediate Building Interior 12 x12 ceiling tile w/ holes NAD 4 Intermediate Building Library 2 x4 ceiling tile NAD 5 Intermediate Building Interior 12 x12 ceiling tile w/ 1 fissures NAD 6 Intermediate Building Interior Brown cove base NAD 6-mastic Intermediate Building Interior Brown cove base mastic NAD 7 Intermediate Building Interior Blue cove base NAD 7-mastic Intermediate Building Interior Blue cove base mastic NAD 8 Intermediate Building Interior Black cove base NAD 8-mastic Intermediate Building Interior Black cove base mastic NAD 9-tile Intermediate Building Interior 12 x12 off-white floor tile ~14,000 SF 3% Chrysotile 9-mastic Intermediate Building Interior Off-white floor tile mastic NAD 10-tile Intermediate Building Interior 12 x12 off-white/brown floor tile ~14,000 SF 3% Chrysotile 10-mastic Intermediate Building Interior Off-white/brown floor tile mastic NAD 11-tile Intermediate Building Interior 12 x12 brown floor tile NAD Youth s Benefit Elementary School Hazardous Material Findings Harford County Public Schools F&R Project Number 75S May 2, 2014