If you have any questions, please contact the undersigned at (781) Division Manager, Environmental Services

Transcription

1 ASSOCIATES INC. 600 West Cummings Park, Suite 5450 Woburn, MA Phone Fax April 13, 2012 Kim Tisa, PCB Coordinator U.S. Environmental Protection Agency, Region 1 5 Post Office Square, Suite 100 Mail Code: OSRR07-2 Boston, Massachusetts via Overnight Mail Re: Request for Approval of TSCA Risk-Based Clean-up of PCBs under 40 CFR 761 Brockton Public Schools Green Repair Program Brockton High School 470 Forest Avenue Brockton, Massachusetts ATC Project No Dear Ms. Tisa: Please find enclosed a Request for Approval of a Risk-Based Clean-Up of PCBs under the Toxic Substances Control Act (TSCA), 40 CFR (c), submitted on behalf of the City of Brockton Public Schools, for the Brockton High School. This submittal documents the plan for clean-up of PCB-impacted building materials at the Brockton High School during window and door replacement activities. If you have any questions, please contact the undersigned at (781) Sincerely, ATC Associates Inc. Jason M. Roback, CHMM Project Manager Michael Gitten, LSP, PE Division Manager, Environmental Services cc: Kenneth Kimmell, Commissioner, MassDEP, One Winter St., Boston, MA Mary Brophy, Board of Health Director, Brockton Board of Health, 45 School Street, Brockton, MA Kaja Martin-Savasta, CSS Architects Inc., 107 Audubon Road, Bldg. 2, Suite 300, Wakefield, MA Michael Thomas, City of Brockton Public Schools

2 REQUEST FOR APPROVAL OF TSCA RISK-BASED CLEAN-UP OF PCBS BROCKTON PUBLIC SCHOOLS GREEN REPAIR PROGRAM BROCKTON HIGH SCHOOL 470 FOREST AVENUE BROCKTON, MASSACHUSETTS APRIL 9, 2012 Prepared for: Brockton Public Schools 43 Crescent Street Brockton, Massachusetts (508) Prepared by: ATC Associates Inc. 600 West Cummings Park, Suite 5450 Woburn, Massachusetts (781) ATC Project No

3 Request for Approval of TSCA Risk-Based Clean-up of PCBs Brockton High School Brockton, Massachusetts April 9, 2012 TABLE OF CONTENTS 1 Introduction Site Background and History General Location Site History and Description PCB Characterization Sampling PCB Laboratory Analysis Results Glazing Sampling Caulk Sampling Textured Concrete Surround Sampling Smooth Exterior Concrete Sill Sampling Exterior Mortar Sampling CMU Sampling Plaster (Sheetrock) Sampling Wipe Sampling Data Usability Review Nature and Extent of PCBs Risk Assessment PCB Source Potential Human Receptors Potential Exposure Points, Pathways and Controls Risk-Based Clean-Up Plan Assignment of Work Procedures for Implementation Communication Plan Initial Indoor Air Sampling Window/Door Unit and Sealant Removal Masonry Surround Surface Repair Encapsulant Application Dust Monitoring Confirmatory Wipe Sampling Confirmatory Indoor Air Sampling Annual Inspections Deed Notice Waste Management Schedule for Implementation State or Local Permits and Approvals Owner Certification FIGURES Figure 1 Site Vicinity Map Figure 2 Site Plan-Elevations 4, 8, 9, 12, 13, and 14 Figure 3 Site Plan-Elevations 1, 3, 5D, and 7A Figure 4 Site Plan-Elevations 16, 17, and 18

4 Request for Approval of TSCA Risk-Based Clean-up of PCBs Brockton High School Brockton, Massachusetts April 9, 2012 TABLE Table 1 PCB Analytical Results APPENDICES Appendix A Appendix B Appendix C Appendix D Appendix E Photographs Laboratory Analytical Reports Technical Specification Section Selective Demolition Section Asbestos Abatement Section Lead-Containing Paint Considerations Section Removal and Disposal of PCBs Section Painting Abatement Contractor Workplan Encapsulant Information

5 Request for Approval of TSCA Risk-Based Clean-up of PCBs Brockton High School Brockton, Massachusetts April 9, INTRODUCTION ATC Associates Inc. (ATC) has prepared this Request for Approval of a Risk-Based Clean-Up of Polychlorinated Biphenyls (PCBs) (Request) in accordance with the Toxic Substances Control Act (TSCA), on behalf of the City of Brockton Public Schools (Brockton). The Request is provided for planned exterior window and door replacement activities associated with the Brockton Public Schools Green Repair Program at the Brockton High School, 470 Forest Avenue, Brockton, Massachusetts. The Brockton High School is hereinafter referred to as the Site. Multiple interior and exterior glazing material samples around exterior windows and doors have been identified as containing PCBs at concentrations >/= 50 parts per million (ppm). It is believed that the glazing was manufactured containing PCBs in a non-liquid state and since the concentration at the time of designation for disposal is >/= 50 ppm PCBs this material is defined by 40 CFR 761 as PCB Bulk Product Waste. Limited amounts of materials abutting PCB Bulk Product Waste containing PCBs have also been identified and therefore are defined by TSCA as PCB Remediation Waste. This Request is provided to support the window and door replacement activities where PCB Bulk Product Waste and PCB Remediation Waste have been identified. In summary, all PCB Bulk Product Waste will be removed, and PCB Remediation Waste removed or encapsulated. This Request has been prepared in general accordance with TSCA requirements for a risk-based clean-up plan, as outlined at 40 CFR (c). 40 CFR (c) indicates that all the information outlined in 40 CFR (a) (Self-Implementing Clean-up) must be provided. Therefore various references are made throughout this document to 40 CFR (a), even though this submittal is for a risk-based clean-up under 40 CFR (c). The following is information regarding the entity submitting this Request: Entity: Address: Contact: Telephone: The City of Brockton Public Schools 43 Crescent Street Brockton, Massachusetts Michael Thomas Chief of Operations (508) michael.thomas@bpsma.org 2 SITE BACKGROUND AND HISTORY This Section provides Site information, including Site location, history and description. Section 2.3 includes information on PCB characterization sampling, as required by 40 CFR (a)(3)(i)(B). 2.1 GENERAL LOCATION The Site is located to the south of Belmont Street (Route 123) and Angus Beaton Drive, and to the west of Memorial Drive in the western portion of Brockton, Massachusetts. Site access is provided from the north via Angus Beaton Drive and the east via Memorial Drive. Residential

6 Request for Approval of TSCA Risk-Based Clean-up of PCBs Brockton High School Brockton, Massachusetts April 9, 2012 properties are located to the east, south, and west of the Site. Commercial properties are located to the north of the Site. Photographs of the Site are included in Appendix A. A locus map showing the location of the Site is included as Figure SITE HISTORY AND DESCRIPTION The Site is owned by the City of Brockton and improved with three contiguous buildings which compromise the Brockton High School. The buildings are 1) main academic; 2) gymnasium/pool and 3) fine arts. These buildings vary from one to three stories. The primary Site use is as a school. Building uses include classrooms, theater, gyms, child day care center, mechanical areas, administrative offices and other school related uses. The gymnasium/pool and fine arts building are attached to the academic building via second story connector corridors. According to the City of Brockton Assessor s Office, the Site building was initially constructed circa The majority of the Site buildings are constructed of steel and reinforced concrete framing, slabon-grade foundation, concrete masonry unit (CMU) and mortar facades and walls with flat rubber roofs. Some first floor exteriors include glazed brick or natural stone facades. Exterior window and door units are steel framed. Exterior windows and doors are situated above pre-cast smooth (e.g. administrative offices in academic building) or textured concrete sills. Generally, exterior portions of window/door units located above the first floor of the Site building are not accessible to Site building occupants. Figures 2 through 4 show existing conditions. Window/door units associated with connecting corridors are not included in the window/door replacement activities. These units were reportedly replaced in PCB CHARACTERIZATION SAMPLING This section outlines the building material PCB characterization sampling that has been conducted at the Site. Sampling evaluated items identified by Brockton as to be disturbed during proposed window and door replacement activities. Sampling was completed over three (3) events in the following phased manner: September 29, 2011: Initial suspect sealant sampling to determine if PCB Bulk Product Waste is present at windows and doors to be replaced; November 4-11, 2011: Additional suspect sealant sampling to delineate extent of PCB Bulk Product Waste. Initial concrete, brick, CMU, mortar, natural stone, plaster, and wipe sampling to identify if these materials had been impacted by PCB Bulk Product Waste and therefore PCB Remediation Waste is associated with identified PCB Bulk Product Waste; and February 24, 2012: Additional sealant, concrete, and CMU sampling to delineate extent of PCB Remediation Waste and fill data gaps from previous sampling. Sealant samples were collected with hand and power hand tools. Concrete, brick, CMU, mortar, natural stone, and plaster samples were collected in general accordance with Region I, EPA-New England, Standard Operating Procedure for Sampling Porous Surfaces for PCBs (May 5, 2011). Sample collection tools were decontaminated between samples by wiping with a hexane-wetted rag. ATC ASSOCIATES INC. PAGE 2

7 Request for Approval of TSCA Risk-Based Clean-up of PCBs Brockton High School Brockton, Massachusetts April 9, 2012 Wipe samples were collected from non-porous samples. These include window/door frames and panes and glazed brick. Wipe samples were collected per standard wipe test protocols in accordance with 40 CFR utilizing the applicable procedures identified in Wipe Sampling and Double Wash/Rinse Cleanup as Recommended by the Environmental Protection Agency PCB Spill Cleanup Policy (June 23, 1987 Revised and Clarified on April 18, 1991). A one-use template was used to delineate each 100 square centimeters (cm 2 ) sampling area. All samples were transported under chain-of-custody to Contest Analytical Laboratory, Inc. (Contest) of East Longmeadow, Massachusetts for laboratory analysis. Samples were analyzed following EPA Method 3540C for soxhlet extraction with analysis by EPA Method A total of 143 samples, including duplicates, were submitted for PCB laboratory analysis, as summarized below: 29 glazing samples; 29 caulk samples; 28 textured concrete samples; 3 smooth concrete samples; 6 mortar samples; 18 CMU samples; 3 plaster samples; and 27 non-porous surface wipe samples. Approximate sample locations are shown on Figures 2-4. The photographs in Appendix A show representative sample locations. Note that ATC also characterized the presence of asbestos and lead-based paint at the Site to facilitate window/door replacement. ATC confirmed that the interior and exterior window glazing contains asbestos, and yellow and green painted door frames contain lead. 2.4 PCB LABORATORY ANALYSIS RESULTS PCBs were identified in some of the materials analyzed. The following subsections are organized by building material type. The laboratory analytical reports are attached in Appendix B, and laboratory results are tabulated in Table Glazing Sampling ATC analyzed 29 glazing samples from between metal window/door frames and glass panes. Ten (10) samples were collected from the interior and 19 from the exterior. Interior and exterior glazing was observed on the exterior windows. Total PCB concentrations in the glazing samples ranged from 2.2 to 3,000 ppm (Sample ID 116). When PCBs were detected, it was typically at concentrations greater than 50 ppm. For interior glazing samples, total PCB concentrations ranged from 9.1 to 450 ppm (Sample ID 5). ATC ASSOCIATES INC. PAGE 3

8 Request for Approval of TSCA Risk-Based Clean-up of PCBs Brockton High School Brockton, Massachusetts April 9, 2012 For exterior glazing samples, total PCB concentrations ranged from 2.2 to 3,000 ppm (Sample ID 116). The predominant Aroclor observed was Aroclor One sample (Sample ID 9) also contained Aroclor 1248, which was reported at a higher concentration than Aroclor Caulk Sampling ATC analyzed 29 caulk samples from between metal window/door frames and masonry surrounds. Eleven (11) samples were collected from the interior and 18 from the exterior. Total PCB concentrations in the caulk samples ranged from 1.4 to 81 ppm (Sample ID 8). The predominant Aroclor observed was Aroclor Aroclor 1248 was also observed in some caulking samples. For interior caulk samples, total PCB concentrations ranged from 3 to 81 ppm (Sample ID 8). For exterior caulk samples, total PCB concentrations ranged from 1.4 to 39 ppm (Sample ID 10B) Textured Concrete Surround Sampling ATC analyzed 28 textured concrete samples. A large number of the window and doors are set in textured concrete surrounds on one or more sides. In some cases the vertical texture concrete extends into the building and textured concrete sills are present. Figures 2 through 4 show where textured concrete is present. Twelve (12) samples were collected from the interior surrounds and 16 from the exterior. Samples were collected from the surface to a depth of approximately ½ inch in sets at varying distances from a sealant. For most locations a sample was collected adjacent to the surround sealant, 6-inches from the sealant and 12-inches from the sealant. Distances from samples to sealant are noted in Table 1. Total PCB results ranged from ND (< ppm) to 280 ppm (Sample ID 45 adjacent to interior surround caulk). Only one sample had a concentration greater than 50 ppm and this sample was collected adjacent to a window and may include a small amount of sealant. At most locations, the higher PCB concentrations were observed adjacent to the sealant. The predominant Aroclor observed was Aroclor Aroclor 1242 and 1260 were also observed in some samples. For interior textured concrete samples, total PCB results ranged from ND (< ppm) to 280 ppm (Sample ID 45). For exterior textured concrete samples, total PCB results ranged from ND (< ppm) to 44 ppm (Sample ID 45) Smooth Exterior Concrete Sill Sampling ATC analyzed three (3) smooth concrete sill samples. These sills are present at the exterior of the administrative windows in the academic building. Samples were collected ATC ASSOCIATES INC. PAGE 4

9 Request for Approval of TSCA Risk-Based Clean-up of PCBs Brockton High School Brockton, Massachusetts April 9, 2012 from the surface to a depth of approximately ½ inch adjacent to the surround caulk, 6- inches away and 12-inches away. Total PCB results in the smooth concrete samples were each ND with laboratory detection limits 0.10 ppm or less Exterior Mortar Sampling ATC analyzed six (6) mortar samples from the exterior glazed brick surrounds of the windows/doors. Three (3) were collected from the interior and 3 from the exterior. Glazed brick samples were analyzed via wipe samples discussed below. Mortar samples were collected from the vertical surfaces to a depth of approximately ½ inch adjacent to the surround sealant and 6-inches away. This material is only present on the building exterior. PCBs in the mortar samples were all reported as ND (< 0.10 ppm) CMU Sampling ATC analyzed 18 vertical surround CMU samples. Eleven (11) were collected from the interior and 7 from the exterior. CMU samples were collected from the vertical surfaces to a depth of approximately ½ inch in sets at varying distances from a sealant-containing window/door surround caulk. Distances from samples to sealant-containing window/door joints are noted in Table 1. Total PCB results ranged from ND (< ppm) to 26 ppm (Sample ID 95). When PCBs were detected, it was generally at concentrations less than one (1) ppm. The predominant Aroclor observed was Aroclor Aroclor 1248 was also observed in some CMU samples. The predominant Aroclor observed was Aroclor Aroclor 1248 was also observed in some samples. PCB concentrations in CMU samples collected adjacent to a surround sealant ranged from ND to 26 ppm. ATC does not believe that the one sample at 26ppm is representative since it was collected adjacent to surround caulk and was the only result > 0.47 ppm. ATC believes that some surround caulk was present in the sample. Results from samples 6-inches and 12-inches from sealant joints ranged from ND (<0.095) ppm to 0.89 ppm; all < 1 ppm PCBs. For interior CMU samples, total PCB results ranged from ND (< ppm) to 26 ppm (Sample ID 95). ATC suspects that some caulk may have been present in Sample 95 based upon sampling of similar areas and the atypical concentration. For exterior CMU samples, PCB results ranged from ND (< ppm) to 0.89 ppm (Sample ID 58) Plaster (Sheetrock) Sampling ATC analyzed a total of three (3) plaster (sheetrock) samples. Interior sheetrock walls are present adjacent to some windows. Samples were collected from the vertical surfaces to a depth of approximately ½ inch in sets at varying distances from a sealant-containing window/door joint. Distances from samples to sealant-containing window/door joints are noted in Table 1. ATC ASSOCIATES INC. PAGE 5

10 Request for Approval of TSCA Risk-Based Clean-up of PCBs Brockton High School Brockton, Massachusetts April 9, 2012 Total PCB concentrations ranged from 0.39 ppm to 0.55 ppm (Sample ID 104). The only Aroclor observed in the plaster samples was Aroclor Wipe Sampling ATC analyzed 27 wipe samples from non-porous surfaces. These surfaces are metal window/door frames and glass panes associated with the window/door units and nonporous surrounds (glazed bricks and stone). Eight (8) samples were collected from the interior and 19 were collected from the exterior of the Site building. Total PCB results ranged from ND (< 0.20 micrograms per 100 square centimeters (ug/100 cm 2 )) to 2.5 ug/100 cm 2 (Sample ID 126). PCBs were only observed above laboratory detection limits in 9 samples. The only Aroclor observed in the wipe samples was Aroclor For interior wipe samples, total PCB results ranged from ND (< 0.20 ug/100 cm 2 ) to 0.76 ug/100 cm 2 (Sample ID 31). For exterior wipe samples, total PCB results ranged from ND (< 0.20 ug/100 cm 2 ) to 2.5 ug/100 cm 2 (Sample ID 126). Only two (2) samples had results > 1 ug/100 cm 2. These samples were from metal surfaces and had results of 1.8 and 2.5 ug/100 cm 2. The 2 stone and 10 glazed brick results were all ND (< 0.20 ug/100 cm 2 ). 2.5 DATA USABILITY REVIEW ATC reviewed the laboratory narratives associated with the samples to evaluate the data s usability. This included reviewing detection limits and surrogate recoveries for each sample. As summarized in Table 1, for some samples, surrogate recovery targets were not met, surrogates were obscured or diluted out due to matrix interference or dilutions, or detection limits were elevated due to matrix interference. ATC believes that these QA/QC issues do not significantly impact data quality or usability. This is primarily due to the fact that many of these issues are associated with samples where PCBs were reported to be present at concentrations > 50 ppm or there are multiple samples associated with the material in question. 3 NATURE AND EXTENT OF PCBS This Section summarizes the media impacted by PCBs and its extent as required by 40 CFR (a)(3)(i)(A) and 40 CFR (a)(3)(i)(C). When two or more similar materials were found in similar locations and had similar physical properties the highest PCB concentration observed in any sample associated with the material was assumed to be present in all similar materials. Based upon the data and field observations, ATC concludes the following: Interior and Exterior Window/Door Glazing: This material is located throughout the Site façade and is considered a PCB Bulk Product Waste. Although not all glazing samples analyzed contain PCBs >/= 50 ppm, as a conservative measure, all interior and exterior glazing is considered PCB Bulk Product Waste. ATC estimates there is approximately 54,000 linear feet of this material present. The glazing is also an asbestos containing material. ATC ASSOCIATES INC. PAGE 6

11 Request for Approval of TSCA Risk-Based Clean-up of PCBs Brockton High School Brockton, Massachusetts April 9, 2012 The window glazing does impact some adjacent surfaces, resulting in these materials being PCB Remediation Waste, as discussed below. Window/door interior and exterior caulking: This material is located between metal window/door frames and masonry (i.e., glazed brick, plaster, mortar, CMU, and concrete) surrounds. Total PCB concentrations in the caulk samples ranged from 1.4 to 81 ppm. As a conservative measure, all interior and exterior window/door caulk is considered PCB Remediation Waste containing PCBs >/= 50 ppm. Textured concrete: Many window and doors are set in textured concrete surrounds on 1 or more sides. In some cases the vertical textured concrete extends into the building and textured concrete exterior sills are present. PCB analytical results for textured concrete samples ranged from ND (< ppm) to 280 ppm. Only one of 29 samples had a concentration greater than 50 ppm and this sample was collected adjacent to a window and may include a small amount of sealant. Sampling did not fully delineate the extent of impact. It is therefore assumed that all interior textured concrete surrounds, exterior vertical columns and exterior sills are impacted. Samples of other porous materials that were in direct contact with the above sealants were analyzed to determine if they contain PCBs at concentrations >/= 1 ppm. Samples were collected at varying distances from a sealant-containing window/door joint and PCB results ranged from ND (< ppm) to 26 ppm as summarized below. ATC does not believe that any of these materials are PCB Remediation Waste. Interior plaster: PCBs were detected in all samples from 0.39 ppm to 0.55 ppm. CMU (interior/exterior): PCB analytical results ranged from ND (< ppm) to 26 ppm. Only one sample (Sample 95) had a concentration greater than 0.89 ppm at 26 ppm. ATC suspects that some caulk may have been present in this sample based upon sampling of an area similar to Sample 95 and the atypical concentration. Glazed Bick Mortar (exterior). PCBs were not detected in any of the 6 exterior glazed brick mortar samples. Smooth Concrete Sills (exterior): PCBs were not detected in any of the 3 samples. Samples of non-porous materials (i.e., glazed brick, metal frames, glass panes, and natural stone) that were in direct contact with the above sealants were analyzed to determine if they contain PCBs at concentrations greater than 1 ug/100 cm 2. Window/Door Frames/Glass (window/door units): Of the 27 wipe samples from metal window/door frames and glass, PCBs were detected in 9 samples at concentrations ranging from 0.22 to 2.5 ug/100 cm 2. PCBs were only observed at > 1 ug/100 cm 2 in two (2) samples which are associated with metal frames (Samples 69 and 126) with concentrations of 1.8 and 2.5 ug/100 cm 2, respectively. If the glazing and caulking can be fully removed from the window and glass the area where these sealants are present decontaminated, the frames and glass can be managed as demolition debris. ATC ASSOCIATES INC. PAGE 7

12 Request for Approval of TSCA Risk-Based Clean-up of PCBs Brockton High School Brockton, Massachusetts April 9, 2012 Due to the fact that the glazing which is a PCB Bulk Product Waste is integral to the window/door frame units and the glazing also contains asbestos, it may not be practicable or cost effective to disassemble the window/door units. If managed a unit they would meet PCB Bulk Product Waste definition in 40 CFR (example (1): Non-liquid bulk wastes or debris from the demolition of buildings and other manmade structures coated with PCBs. ) and could be managed as PCB Bulk Product Waste with PCBs >/= 50 ppm at a TSCA or state-permitted landfill that can accept these materials. Glazed Brick / Stone: The majority of the windows on the ground floor have one or more of their surround sides comprised of glazed brick. The surrounds at the administrative office in the academic building include a hard stone that is considered non-porous. When detected in wipe samples, all results were ND (0.20 ug/100 cm 2 ). The locations of PCB-containing building materials are depicted on Figures 2-4. Note that ATC was unaware during the initial sampling event that the connecting corridor windows were not being replaced. ATC collected four (4) caulk samples from the Gym and Fine Art connector corridor windows (Sample IDs 11, 21, 22, and 23). PCB concentrations ranged from 2.2 to 12 ppm. These materials are classified as Excluded PCB Product based upon their unique locations, relatively low PCB concentrations and fact that these materials were installed separately from the rest of the Site building in RISK ASSESSMENT In accordance with 40 CFR (c) a human health risk assessment was completed. The purpose of this risk assessment is to evaluate Site exposures and provide a justification for the controls proposed to address these exposures. The assessment is intended to place the Site in the context of its environmental setting and the regulatory categories of environmental media set forth in the CFR. A risk assessment is required because it is ATC s opinion that removal of all PCB Remediation Waste > 1 ppm (i.e. textured concrete surrounds) it is not feasible due to the following reasons: It is anticipated that the proposed abatement program will adequately control exposure to textured concrete that represents a PCB Remediation Waste. PCB Bulk Product Waste will be removed; With PCB Bulk Product Waste ( source material) removed and the relatively low PCBs present in the texture concrete, < 50 ppm in 27 of 28 samples, an encapsulant is anticipated to be as protective as removal; Impact on building use. The current plan is to complete the majority of the planned abatement during the summer while the school is only partially occupied. A full abatement program could not be completed during this limited period and would be more disruptive to students. Costs associated with extra work. The City does not have funds available to do more than what is currently proposed; and The potential risk associated with the short term exposure to workers and building occupants during textured concrete removal. ATC ASSOCIATES INC. PAGE 8

13 Request for Approval of TSCA Risk-Based Clean-up of PCBs Brockton High School Brockton, Massachusetts April 9, PCB Source As described in Section 3 of this Request, the PCB source is the interior and exterior window glazing. This PCB Bulk Product Waste has impacted adjacent window/door frame caulk and textured concrete surrounds. As discussed in Section 5, all glazing (PCB Bulk Product Waste) and window/door frame caulk will be removed. Impacted textured concrete surrounds will be encapsulated. 4.2 Potential Human Receptors Current human receptors present at the Site or in the surrounding environment, and who as a result, may be exposed to the identified PCBs are considered to be students, faculty, visitors, construction and utility workers, and trespassers. The current likelihood of humans coming in contact with PCBs is considered to be moderate. This is because the PCB containing sealants are in good condition (not falling out) and impacted materials are located in areas not regularly contacted (windows and doors). In addition, the vast majority of exterior PCB containing materials located above the first floor of the Site building are not accessible to human receptors. The proposed PCB Bulk Product removal and encapsulation system is believed to control future human exposure to PCBs at the Site. 4.3 Potential Exposure Points, Pathways and Controls Potential human exposure points are direct contact with (touching or ingesting PCB containing materials) or indirect contact (inhalation of PCBs that might be in air). The potential human exposure pathways are dermal absorption, ingestion, inhalation of PCB. Window/door unit glazing and caulking represent a potential exposure point. Their removal will eliminate this exposure point. Interior and exterior textured concrete surrounds have been impacted by the window/door glazing and represent a potential exposure point. The primary exposure pathway would be via direct contact. Secondary exposure pathways may include inhalation if residual PCBs were to off-gas or ingestion. ATC does not believe either of these routes would be significant since PCB levels in the textured concrete were less than 50 ppm in all but one sample, the material is not amendable to ingestion and the proposed abatement approach. Exposure to textured concrete will be controlled as follows: All interior textured concrete associated with window/door surrounds will be encapsulated or covered by new window/door frames: Exterior textured concrete vertical surrounds, doorways and first floor sills will be encapsulated or covered by new window/door frames. Because textured concrete above the first floor is not accessible, there is no exposure pathway and it will not be encapsulated. The removal activities and encapsulant systems will be shown to be performing adequately to manage residual PCBs in accessible textured concrete surrounds if future wipe samples of encapsulated accessible surfaces have concentrations no greater than 1 ug/100 cm 2 and indoor air levels are below the EPA s public health target of 450 nanograms per cubic meter (ng/m 3 ) value for 12 to 15 year olds (middle school population) and adults, with the more restrictive 70 ng/m 3 ATC ASSOCIATES INC. PAGE 9

14 Request for Approval of TSCA Risk-Based Clean-up of PCBs Brockton High School Brockton, Massachusetts April 9, 2012 for 1 to 3 year olds in daycare area. Because the adult value of 450 ng/m 3 is lower than the 600 ng/m 3 15 to 19 year old (high school) value, ATC is conservatively proposing that the 450 ng/m 3 value be used. If these values are exceeded, additional evaluations will be performed to determine if these levels present an actual risk to building users and if additional PCB abatement activities are required. Refer to Section 5.2 for additional information. 5 RISK-BASED CLEAN-UP PLAN This Section details the clean-up plan, as required by 40 CFR (a)(3)(i)(D). The primary components of the risk-based clean-up plan are: 1) Removing sealants (interior and exterior glazing (PCB Bulk Product Waste) and interior and exterior surround caulk (PCB Remediation Waste)) and associated window/doors units containing PCBs throughout the Site building. The window/door units will either be disposed of as a. PCB Bulk Product Waste units containing >/= 50 ppm PCBs, or b. The windows/doors will be disabled, the glazing and caulk separated and managed as a PCB Bulk Product Waste >/= 50 ppm and the glass and metal frames decontaminated and managed as general demolition debris. (note that the glazing also contains asbestos and some door frames lead based paint). 2) Encapsulating interior and exterior textured concrete surrounds as detailed herein. The PCB abatement work is a part of the Green Repair Program Window Replacement project. The associated Technical Specifications from this program related to PCB abatement activities are included in Appendix C. The Technical Specifications were prepared prior to the completion of the sampling described herein and preparation of this Request. When there is a conflict between the information between the Request and Technical Specifications, the Request requirements shall prevail. The contractor proposes the following sequence of work: 1. Secure area 2. Install critical barrier on building interior to isolate work area from building interior 3. Remove window/door units 4. Clean surrounds by removing caulk and wiping surface with hexane or other suitable solvent 5. Install new window/door units 6. Remove critical barrier 7. Place encapsulant 8. Place new window surround sealants Work will be performed in accordance with the procedures outlined in this document. Due to the fact that the interior and exterior glazing compound contains asbestos, federal Occupational Safety and Health Administration (OSHA) 29 CFR , Massachusetts Department of Labor and Industry (DLWD) 453 CMR 6.0 and Massachusetts Department of Environmental Protection (MassDEP) 310 CMR 7.15 also apply. Yellow and green door frames have been identified to contain lead, consequently, work performed on these doors that must comply with OSHA standard 29 CFR for worker ATC ASSOCIATES INC. PAGE 10

15 Request for Approval of TSCA Risk-Based Clean-up of PCBs Brockton High School Brockton, Massachusetts April 9, 2012 protection. Disposal of these materials will also need to comply with EPA and MassDEP requirements. ATC believes that the work plan outlined in this submittal is adequate to properly manage PCB Bulk Product Waste and PCB Remediation Waste, and control future exposures to PCB Remediation Waste that may remain after these abatement activities. 5.1 ASSIGNMENT OF WORK The City has hired Paul Rogan Co. Inc. (Rogan) of Braintree, Massachusetts as the general contractor. Rogan has retained Safe Environment of America from Ludlow, Massachusetts as their PCB and asbestos abatement subcontractor. Rogan and Safe Environment of America have been provided with this Request, associated Technical Specification. They will be provided any forthcoming approvals and conditions issued by the EPA. The contractor will be required to provide written certification that they understand and will comply with the provided documents. The contractor shall perform the project work in a manner to meet or exceed the means and methods presented in this Request. The abatement contractor s work plan for performing the work is attached as Appendix D. Note that this workplan applies to both the Brockton High School and Downey Elementary School. PCB abatement at the Downey Elementary School will be performed in accordance with a separately submitted Self-Implementing Clean-Up of PCBs under the Toxic Substances Control Act (TSCA), 40 CFR (a). It is important to note that asbestos abatement will occur in conjunction with PCB abatement that will bring its own worker safety, dust and waste management controls to the project. In addition, some door frames also contain lead based paint. The asbestos abatement and lead paint management requirements are detailed in the Technical Specifications (Appendix C). Third-party environmental oversight and review of the clean-up plan activities prior to, during, and after their performance will be performed by ATC. ATC will monitor compliance with this Request, visually confirm that identified PCB-containing sealants and associated window/door units are removed, and collect confirmatory samples. 5.2 PROCEDURES FOR IMPLEMENTATION The primary components of the risk-based clean-up plan are detailed in the following subsections. The components will be performed generally in the order in which they are listed. Refer to the attached Technical Specifications for additional details (Appendix C) and contractor s workplan (Appendix D) Communication Plan The building is currently occupied by students and faculty. To the extent possible, abatement will occur while school is not in session and building use reduced. The contractor will secure and post the work area prior to starting work to keep the public out of these areas. Appropriate Brockton staff will be briefed on the project scope prior to the initiation of clean-up activities. A summary of planned work will be provided to faculty, staff and parents via a posting on the Brockton High School website. A copy of this Request will be maintained at the High School administrative offices for review by any interested party. ATC ASSOCIATES INC. PAGE 11

16 Request for Approval of TSCA Risk-Based Clean-up of PCBs Brockton High School Brockton, Massachusetts April 9, Initial Indoor Air Sampling Initial indoor air PCB sampling will be performed within the building to provide a baseline to support evaluating the effectiveness of abatement activities. Samples will be collected using a Polyurethane Foam (PUF) Media cartridge following EPA Method TO- 10A, Determination of Pesticides and PCBs in Ambient Air Using Low Volume. Samples will be submitted for PCB homologue analysis by EPA Method 680 Modified. Prior to use sampling pumps will be calibrated. The PUF cartridges will be attached to a stand located in the middle of the room being sampled and at a height of approximately 3-5 feet above the floor. The pumps will be allowed to draw air through the cartridges at an approximate flow rate of two (2) liters per minute for approximately seven (7) hours each. A total of 11 samples from the following locations will be included in the baseline program: 2 exterior rooms academic building first and second floor (4 samples) Gymnasium, exterior rooms first and top floor Fine arts building, exterior rooms first and top floor Day care center Trip blank ambient Window/Door Unit and Sealant Removal The window and door units and associated surround caulk will be removed per Section 3.01 of enclosed Technical Specification It discusses window and associated sealant removal and surround cleaning. After the surround caulk is removed, the work area will be HEPA vacuumed and surrounds within 6-inches of either side of the caulk joint will be wiped down with a hexane, or other appropriate solvent, wetted rag. The one modification created by this Request is that the contractor will have the option to manage the window/door units as a system and therefore as a PCB Bulk Product Waste, or to fully remove the glazing and caulking from the window and glass and the area where these sealants are present decontaminated. If the windows are dissembled, the glazing would be managed as PCB Bulk Product Waste and asbestos containing material, the surround caulk as a PCB Remediation Waste with a PCB concentration >/= 50 ppm and the remaining material as demolition debris. Prior to disposal as demolition debris, the glass and metal frames would be double wiped with a hexane, or other suitable solvent, rag and visually inspected to confirm that all sealants are removed Masonry Surround Surface Repair If encountered, damaged masonry surround surfaces will be repaired prior to encapsulant application. When working within areas identified as being impacted by the PCBcontaining sealants, as detailed in Section 3, grinding or chipping power tools will only occur after it is determined that work cannot be satisfactorily completed with non-power tools. If required, grinding/chipping with power tools will only occur after existing surround sealant is removed. If utilized, grinders will be equipped with shrouds and Bosch Airsweep vacuums or similar with HEPA filters or other means to capture dust and small debris in the grinding ATC ASSOCIATES INC. PAGE 12

17 Request for Approval of TSCA Risk-Based Clean-up of PCBs Brockton High School Brockton, Massachusetts April 9, 2012 zone. When using the pneumatic chipping gun, a two person crew will be used. One will operate the chipping gun and the other will wet the work area and use a HEPA vacuum to capture dust and small debris in the chipping zone. Vacuums, hoses, bags, and the associated grinding/chipping tools will be inspected regularly to ensure that the equipment is functioning appropriately. Grinding activities with power tools will be stopped immediately upon observation of dust or debris emissions. All work will be performed within the same type of containment used for sealant removal. If this containment spans an area significantly greater than the sealant removal containment area, a second containment will be constructed to further contain debris Encapsulant Application The encapsulant will be a two coat system. The proposed encapsulant is provided in Appendix E. The based layer is the first product (Hi-Build Epoxoline II N69) the top coat is the second product (Enduratone Series 1029). Based upon a review of existing surface conditions, it has been determined that surface preparation (e.g. washing) is not required. The encapsulant will be applied to textured concrete as summarized below: Exterior vertical window surrounds Exterior accessible (first floor) horizontal window sills; Entire interior window surrounds Doorways The encapsulant will consist of two layers with contrasting colors. This encapsulant system s intent is to maintain surface PCB levels at 1 ppm or less Dust Monitoring During the first week of window/door unit and sealant removal activities are being conducted, total dust monitoring will be performed. The objective of the monitoring will be to determine the air exposure impact during these removal activities. Real-time PM 10 readings will be collected utilizing a TSI Model 8520 DustTrak Aerosol Monitor (DustTrak) or similar. Monitoring will at the building exterior and building interior. Exterior dust monitoring will not occur when there is precipitation. Work will stop and additional engineering controls deployed if total dust levels exceed 150 micrograms per cubic meter (ug/m 3 ) over background conditions. Background will be established by monitoring total dust levels prior to the start of removal work. In addition to total dust sampling, periodic asbestos fiber sampling will be performed due to the presence of asbestos in the glazing compound. An absence of asbestos fibers would be indicator that all dust is being contained within the work zone Confirmatory Wipe Sampling To confirm that the encapsulant is meeting performance requirements, confirmatory wipe sampling will be performed at locations regularly accessible to building users. Wipe ATC ASSOCIATES INC. PAGE 13

18 Request for Approval of TSCA Risk-Based Clean-up of PCBs Brockton High School Brockton, Massachusetts April 9, 2012 samples will be collected immediately adjacent to (within 6 inches of the edge) the window/door frames where PCB Remediation Waste sealant was removed. The wipe sampling will be conducted encapsulants have cured. Wipe samples will be collected per standard wipe test protocols in accordance with 40 CFR The samples will be collected utilizing the applicable procedures identified in Wipe Sampling and Double Wash/Rinse Cleanup as recommended by the Environmental Protection Agency PCB Spill Cleanup Policy (June 23, 1987, Revised and Clarified on April 18, 1991). A one-use template will be used to delineate the 100 cm 2 sampling area. The samples will be analyzed at a certified laboratory for PCBs via EPA Method 8082 and extracted via EPA Method 3540C. The encapsulant will be shown to be performing adequately if all wipe samples have concentrations of less than 1 ug/100 cm 2. This level was selected because the encapsulants will form a non-porous surface after application. The following confirmatory wipe sampling program is proposed: 4 interior locations in each of 3 buildings (12 total) 2 within daycare center 2 exterior locations on each side of each of 3 buildings from accessible areas (24 samples) Trip blank Duplicate In total, 38 surface samples and 2 quality assurance samples will be submitted for laboratory analysis. If any of the confirmatory wipe samples indicates a PCB concentration greater than 1 ug/100 cm 2, Brockton will undertake an expanded wipe sampling program. The objective of the expanded wipe sampling program would be to confirm that PCB concentrations do not exceed 1 ug/100 cm 2. Following the receipt of results from the expanded wipe sampling program, Brockton will evaluate extent of exceedances. This may include sampling with an alternate wetting agent to further evaluate the ability for PCBs to transfer via direct human contact. Depending upon the extent of the exceedance, and with input from the EPA, Brockton may prepare a more detailed site specific risk assessment to determine if the exposure pathway is complete and the 1 ug/100 cm 2 action level is appropriate or if re-coating and sampling is appropriate Confirmatory Indoor Air Sampling To support evaluating effectiveness of abatement program, indoor air sampling will be completed as work is completed. Samples will be collected from the same locations and utilizing the same methods from the baseline program outlined in Section The removal activities and encapsulant systems will be shown to be performing adequately to manage residual PCBs in accessible textured concrete surrounds if indoor air levels are below the EPA s public health target of 450 nanograms per cubic meter (ng/m 3 ) value for 12 to 15 year olds (middle school population) and adults, with the more ATC ASSOCIATES INC. PAGE 14

19 Request for Approval of TSCA Risk-Based Clean-up of PCBs Brockton High School Brockton, Massachusetts April 9, 2012 restrictive 70 ng/m 3 for 1 to 3 year olds in daycare area. If these values are exceeded, additional evaluations will be performed. This will include reviewing surface wipe sample results, determining if HVAC system is optimizing fresh air exchanges and the potential for there to be other PCB sources within the school Annual Inspections On an annual schedule, beginning one year following the confirmatory wipe sampling, Brockton will perform an inspection of encapsulated surfaces, focusing on those areas that would be directly accessible to building occupants. The inspections will be primarily visual in nature, and will be intended to confirm that the coated surfaces are in good condition. The inspector will visually observe all coated surfaces at the Site. Evidence of deterioration of the encapsulants, including wear, chipping, or flaking, should be apparent due to the contrasting colors of the two layers. As part of each annual inspection, Brockton will also conduct wipe sampling to confirm that the encapsulant is effectively sealing PCBs over time. The annual wipe sampling will follow the same procedures, including accessible sample locations, as the confirmatory round of wipe sampling described in Section 5.2.7, until modified with EPA concurrence. Annual wipe sample results will be evaluated as presented in Section If encapsulant deterioration (minor chipping, flaking, or wear spots) are noted through visual inspection, Brockton will arrange to have those areas re-coated with a single layer of the appropriate product within one month of the inspection date, weather permitting. The annual inspections, and any necessary repairs to the coated surfaces, will be documented on an official inspection form, and the forms will be maintained by Brockton for the life of the Site building. The inspection form, along with a cover letter outlining any repair of the coated surfaces Brockton intends to undertake, will be submitted to the EPA annually within one month of the inspection date. An associated Long-Term Monitoring and Maintenance Implementation Plan(MMIP) will be submitted at a later date Deed Notice Brockton will record a deed notice for the Site after completion of PCB remedial activities. The deed notice will follow the TSCA requirements outlined at 40 CFR (a)(8), and will inform any potential future purchaser of the Site that: 1) Where PCB Remediation Waste and other PCB containing materials remain; 2) On-going sampling and monitoring of conditions related to residual PCBs at the Site building are required; 3) Implementation of SOPs are required for certain activities taking place at the Site building; and 4) Proper removal and disposal of remaining PCB-impacted materials is required upon demolition of all or portions of the Site building. ATC ASSOCIATES INC. PAGE 15

20 Request for Approval of TSCA Risk-Based Clean-up of PCBs Brockton High School Brockton, Massachusetts April 9, 2012 Following recording of the deed notice, a copy, along with certification that the deed notice has been recorded with the registry of deeds, will be provided to the EPA. 5.3 Waste Management All waste management will be in accordance with applicable state and federal regulations. This includes 40 CFR or and waste being sent to a licensed facility that will receive and retain PCB Bulk Product Waste and PCB Remediation Waste in accordance with EPA regulations. Details on waste management are provided in the Technical Specification in Appendix C. The types of waste that will be generated during the risk-based clean-up plan include: 1) Interior and exterior glazing associated with the proposed window/door replacement activities; 2) Window/door units, including metal frames and glass panes, and associated surround caulking; 3) PPE, containment materials and tools not decontaminated;. Due to their asbestos content, interior and exterior glazing associated with the proposed window/door replacement activities will be double bagged, containerized and labeled as PCB Bulk Product Waste for disposal. As discussed previously, the contractor has the option of managing the entire window/door units and surround caulk as PCB Bulk Product Waste, or dissembling the units, separating the sealants from the metal and glass, and decontaminated the metal and glass. If this second option is taken, the glazing will be managed as PCB Bulk Product Waste, the surround sealant as PCB Remediation >/= 50 ppm and the metal and glass as demolition debris. PCB waste containers will be placed in a secure location on a portion of the Site (to be determined). This area will be approved by Brockton and will be placarded as containing PCB waste with markings meeting the EPA requirements of 40 CRF and If these wastes are to be managed at an out of state facility in accordance with TSCA, exemption to the Massachusetts Hazardous Waste Regulations requirement to use a Uniform Hazardous Waste Manifest may be requested from the Massachusetts Department of Environmental Protection (MassDEP). PPE and containment materials, that has debris that might contain PCBs removed, will be classified as non-regulated wastes, properly containerized and managed in accordance with (a)(5)(v). The container(s) will be labeled per 40 CFR and Once full, the container(s) will be transported off-site for disposal under a non-hazardous waste manifest. Tools may be decontaminated in accordance with 40 CFR (b) or (c). A fence with proper signage will be constructed around the Waste Storage Area to further restrict access. Copies of all bills of landing, waste shipment records, and certificates of disposal will be provided as proof of proper disposal. ATC ASSOCIATES INC. PAGE 16

21 Request for Approval of TSCA Risk-Based Clean-up of PCBs Brockton High School Brockton, Massachusetts April 9, SCHEDULE FOR IMPLEMENTATION In accordance with the TSCA regulations at 40 CFR (a)(3), implementation of the plan outlined in this Request is anticipated to start June 11, 2012, contingent upon approval by the U.S. EPA - Region 1 PCB coordinator. Brockton estimates that the work outlined in Sections through of this Request will take approximately three (3) months. The initial confirmatory wipe sampling will be conducted approximately one month after application of the encapsulants (weather permitting). Annual inspections will begin approximately one year following the initial confirmatory wipe sampling, with results of the annual inspections submitted to EPA within one month of each annual inspection. 5.5 STATE OR LOCAL PERMITS AND APPROVALS State and/or local permits and/or inspections will not be necessary during implementation of the clean-up plan beyond the building permit for general construction, MassDEP notifications for abating asbestos containing material(anf-001) and building construction (BWP AQ-06). The MassDEP and the Brockton Board of Health have been copied on this Request. ATC ASSOCIATES INC. PAGE 17

22

23 Request for Approval of TSCA Risk-Based Clean-up of PCBs Brockton High School Brockton, Massachusetts April 9, 2012 Figures ATC ASSOCIATES INC.

24 Site Site Vicinity Map Source: MASS GIS USGS 7.5 Minute Brockton, MA Quadrangle Map Scale: 1:25,000 (1987) Request for Approval of TSCA Risk-Based Clean-up of PCBs Brockton High School 470 Forest Avenue Brockton, Massachusetts 02302

25 LEGEND GLZ ND (0.095) ND (0.10) GLZ CLK 12" 6" 0" MT 6" SP CON WIPE STAIRWELL NEAR ROOM F305 INT B 84B GLZ CLK ELEV. 12 INT. 2nd FLOOR, NORTH ND (0.095) 86 ND (0.10) ND (0.20) 90 CLK 12" 6" 0" MT 6" SP 0" SP CON WIPE WIPE STAIRWELL NEAR ROOM F305 INT. ND (0.20) 90 0" SP SAMPLE LOCATION D 84D GLZ CLK ELEV. 12 INT. 2nd FLOOR, MIDDLE C 84C 87B GLZ CLK 0" CON ELEV. 12 INT. 2nd FLOOR, MIDDLE GLZ CLK ELEV. 12 EXT. 2nd FLOOR, MIDDLE SAMPLE MATERIAL: GLZ=GLAZING CLK=CAULKING CON=CONCRETE CMU=CONCRETE MASONRY UNIT PLA=PLASTER MOR=MORTAR FOR GLAZED BRICK SURFACE WIPE: GL=GLASS WINDOW MT=METAL FRAME GB=GLAZED BRICK RK=ROCK FACE SP=SILL PLATE DISTANCE FROM SEALANT GLZ LIBRARY EXT. SAMPLE ID DATES SAMPLED AND UP TO ITALICS GLZ CLK ND (0.20) ND (0.20) ND (0.20) " 6" 0" 6" GB 0" GB GL ND (0.20) 39 MT CON WIPE ROOM F141 EXT C 35C GLZ CLK ELEV. 15 EXT. MIDDLE B 35B 42B GLZ CLK 0" CON ELEV. 15 EXT. EAST ND (0.20) ND (0.20) GLZ CLK 6" 0" CON ROOM Y154 INT. CONCENTRATION UNITS MATERIALS PPM WIPES ug/100 CM² ND(0.10) = NON DETECT FOR PCB AT NOTED LABORATORY DETECTION LIMIT Project Number: GLZ MATERIAL LEGEND: CLK " CMU CLK CONNECTOR INT ND (0.20) " 0" 6" GB ND (0.20) 76 0" GB ND (0.20) 77 GL 1 78 MT CON WIPE WIPE COURTYARD NEAR ROOM Y154 EXT. GLAZED BRICK TEXTURED STONE Date: Revisions Number Description GLZ CLK ELEV. 14 INT. Scale: B 10B GLZ CLK 203 0" CON ELEV. 13 EXT. EAST GLZ CLK ELEV. 8 INT.

26 LEGEND GLZ ROOM R119 EXT ND (0.095) 86 ND (0.10) ND (0.20) 90 GLZ CLK 12" 6" 0" MT 6" SP 0" SP CON WIPE WIPE STAIRWELL NEAR ROOM F305 INT. SAMPLE LOCATION C ND (0.10) 116 GLZ 117 CLK " ND (0.10) 111 CLK " 113 6" CMU ND (0.095) 119 6" CMU ND (0.10) 114 6" ND (0.091) 120 0" MT WIPE ROOM ND (0.095) " C16 ND (0.091) 122 6" SMOOTH CON EXT. ND (0.10) 123 0" ND (0.20) ND (0.20) " RK 0" RK WIPE 126 WIPE MT 0" CMU ELEV. 3 INT. 2nd FLOOR NORTH ROOM C16 INT ND (0.095) 131 ND (0.091) 132 ND (0.20) ND (0.20) ND (0.20) GLZ CLK 12" 6" 0" 6" 0" 6" GB 0" GB GL MT CON MOR WIPE WIPE ROOM R117 EXT. SAMPLE MATERIAL: GLZ=GLAZING CLK=CAULKING CON=CONCRETE CMU=CONCRETE MASONRY UNIT PLA=PLASTER MOR=MORTAR FOR GLAZED BRICK SURFACE WIPE: GL=GLASS WINDOW MT=METAL FRAME GB=GLAZED BRICK RK=ROCK FACE SP=SILL PLATE DISTANCE FROM SEALANT SAMPLE ID DATES SAMPLED AND UP TO ITALICS CONCENTRATION UNITS MATERIALS PPM WIPES ug/100 CM² ND(0.10) = NON DETECT FOR PCB AT NOTED LABORATORY DETECTION LIMIT Project Number: GLZ CLK ELEV. 3 INT GLZ CLK ELEV. 3 EXT GLZ CLK ELEV. 3 EXT B 0" CMU ELEV. 3 INT. 1st FLOOR MIDDLE/SOUTH MATERIAL LEGEND: CMU GLZ CLK ELEV. 7A EXT. ND(0.095) 202A 0" CMU ELEV. 3 INT. 1st FLOOR MIDDLE/NORTH ND (0.10) 0.12 ND (0.20) " 6" 0" 6" 0" GL MT GLZ CLK CON CMU WIPE ROOM G318 EXT. GLAZED BRICK TEXTURED STONE Date: Revisions Number Description Scale:

27 ND (0.095) 129 ND (0.091) 130 ND (0.20) ND (0.20) ND (0.20) " 6" 0" 6" 0" 6" GB 0" GB GL MT GLZ CLK CON MOR WIPE WIPE ROOM E115 EXT. LEGEND ND (0.095) 86 ND (0.10) ND (0.20) 90 GLZ CLK 12" 6" 0" MT 6" SP 0" SP CON WIPE WIPE STAIRWELL NEAR ROOM F305 INT. SAMPLE LOCATION ND (0.10) ND (0.10) ND (0.20) ND (0.20) " 6" PLA 0" 6" 0" 6" GB 0" GB 6" SP 0" SP MOR WIPE WIPE ROOM E115 INT. SAMPLE MATERIAL: GLZ=GLAZING CLK=CAULKING CON=CONCRETE CMU=CONCRETE MASONRY UNIT PLA=PLASTER MOR=MORTAR FOR GLAZED BRICK SURFACE WIPE: GL=GLASS WINDOW MT=METAL FRAME GB=GLAZED BRICK RK=ROCK FACE SP=SILL PLATE DISTANCE FROM SEALANT SAMPLE ID DATES SAMPLED AND UP TO ITALICS CONCENTRATION UNITS MATERIALS PPM WIPES ug/100 CM² GLZ CLK 12" 6" 0" 12" 6" 0" CON CMU FINE ARTS ENTRANCE EXT " 6" CON 0" 12" 6" CMU 0" MT WIPE FINE ARTS ENTRANCE INT. ND(0.10) = NON DETECT FOR PCB AT NOTED LABORATORY DETECTION LIMIT Project Number: B 0" CMU F.A. ENT. INT GLZ ELEV. 18 EXT. MATERIAL LEGEND: GLZ CLK ELEV. 18 EXT CLK CONNECTOR EXT. 2ND FLOOR CMU GLAZED BRICK TEXTURED Date: Revisions STONE Number Description Scale: GLZ ELEV. 18 EXT CLK CONNECTOR EXT. 1ST FLOOR GLZ CLK ELEV. 18 DOOR EXT.

28 Request for Approval of TSCA Risk-Based Clean-up of PCBs Brockton High School Brockton, Massachusetts April 9, 2012 Table ATC ASSOCIATES INC.

29 Table 1 Building Material PCB Survey Brockton High School 470 Forest Avenue Brockton, Massachusetts draft Sample ID 1 Glaze 2 Caulk 3 Glaze 4 Caulk 5 Glaze 6 Caulk Material Glazing Caulk Glazing Caulk Glazing Caulk (between metal/glass) (between metal/masonry) (between metal/glass) (between metal/masonry) (between metal/glass) (between metal/masonry) Location Exterior, Ground Level, Elevation 3, Exterior, Ground Level, Elevation 3, North Exterior, Ground Level, Elevation 3, North Exterior, Ground Level, Elevation 3, North Interior, Ground Level, Elevation 6, Interior, Ground Level, Elevation 6, North End, West Side End End (patch) End Administration Office Administration Office Characteristics Gray/Gritty/Semi-Hard/Dry/Brittle Light Gray/Smooth/Soft/Dry/Rubbery Black/Smooth/Soft/Dry/Rubbery Black/Smooth/Soft/Sticky/Rubbery Black/Smooth/Soft/Sticky/Rubbery Light Gray/Smooth/Soft/Dry/Rubbery Similar Samples 13, 14, 43, B, 12, 16, 17, 35, 35B, 35C, 44, 54, 62, 71, , 9,33, 79, 83, 83B, 83C, 83D 8, 10, 24, 80, 84, 84B, 84C, 84D, 111 Sample No. 11J J J J J J Date Collected 9/29/2011 9/29/2011 9/29/2011 9/29/2011 9/29/2011 9/29/2011 Prep Method EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C Analytical Method EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 Compound Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Aroclor 1016 ND (85) ND (0.85) ND (3.7) ND (3.4) ND (87) ND (0.92) Aroclor 1221 ND (85) ND (0.85) ND (3.7) ND (3.4) ND (87) ND (0.92) Aroclor 1232 ND (85) ND (0.85) ND (3.7) ND (3.4) ND (87) ND (0.92) Aroclor 1242 ND (85) ND (0.85) ND (3.7) ND (3.4) ND (87) ND (0.92) Aroclor 1248 ND (85) 6.4 ND (3.7) ND (3.4) ND (87) ND (0.92) Aroclor , Aroclor 1260 ND (85) ND (0.85) ND (3.7) ND (3.4) ND (87) ND (0.92) Aroclor 1262 ND (85) ND (0.85) ND (3.7) ND (3.4) ND (87) ND (0.92) Aroclor 1268 ND (85) ND (0.85) ND (3.7) ND (3.4) ND (87) ND (0.92) Total PCBs 1, Associated Source PCB Bulk Product Waste Determination (Management) PCB Bulk Product PCB Remediation Waste PCB Bulk Product PCB Remediation Waste PCB Bulk Product PCB Remediation Waste > 50 ppm Surrogates Compound % Recovery % Recovery % Recovery % Recovery % Recovery % Recovery DCBP (1) * (30-150) 80.0 (30-150) 98.9 (30-150) 92.8 (30-150) * (30-150) 85.5 (30-150) DCBP (2) * (30-150) 121 (30-150) 100 (30-150) 93.9 (30-150) * (30-150) 89.3 (30-150) TCMX (1) * (30-150) 111 (30-150) 111 (30-150) 107 (30-150) * (30-150) 105 (30-150) TCMX (2) * (30-150) 128 (30-150) 103 (30-150) 102 (30-150) * (30-150) 102 (30-150) Notes: All solid/bulk sample concentrations in milligrams per kilogram (mg/kg)(ppm). Surface wipe sample concentrations are in micrograms per 100 cm2 (µg/100cm2) ND (1.0) = Not Detected above associated laboratory method detection limit Bold = Compound detected PCB Bulk Product = Sealants with PCB concentrations 50 ppm. Designation may be made based upon result from similar material(s) PCB Remediation Waste = Materials with PCB concentrations 1ppm which have been impacted by PCB Bulk Product Waste. Designation may be made based upon result from similar material(s) Excluded PCB Product = Sealants with PCB concentrations < 50 ppm and not impacted by a PCB Bulk Product Demo Debris = Manage as general demolition debris with < 1 ppm PCBs * = The surrogate recovery for this sample is not available due to sample dilution below the surrogate reporting limit required from high analyte concentration and/or matrix interferences ** = This surrogate recovery is outside the surrogate reporting limit ATC Associates Inc. 3/25/12 1 of 23 High School - Table 1 - PCB Analytical Data Summary_ Grouped by Series

30 Table 1 Building Material PCB Survey Brockton High School 470 Forest Avenue Brockton, Massachusetts draft Sample ID Material Location Characteristics Similar Samples Sample No. Date Collected Prep Method Analytical Method Compound Aroclor 1016 Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 Aroclor 1262 Aroclor 1268 Total PCBs Associated Source PCB Bulk Product Waste Determination (Management) 7 Glaze 8 Caulk 9 Glaze 9B Glaze 10 Caulk 10B Caulk Glazing Caulk Caulk (between metal/masonry) Glazing (between metal/glass) Glazing (between metal/glass) Caulk (between metal/masonry) (between metal/glass) (between metal/masonry) Interior, Ground Level, Elevation 3, North Interior, Ground Level, Elevation 3, North Exterior, 2nd Floor, Elevation 13, Gym, Interior, 2nd Floor, Elevation 14, Gym, Exterior, 2nd Floor, Elevation 13, Gym, Interior, 2nd Floor, Elevation 14, Gym, West Side End End, West Side East Side West Side East Side Black/Smooth/Soft/Sticky/Rubbery Light Gray/Smooth/Soft/Dry/Rubbery Black/Smooth/Soft/Sticky/Rubbery Black/Smooth/Soft/Sticky/Rubbery Light Gray/Smooth/Soft/Dry/Rubbery Light Gray/Smooth/Soft/Dry/Rubbery 5, 9, 33, 79, 83, 83B, 83C, 83D 6, 10, 24, 80, 84, 84B, 84C, 84D, 111 5, 7, 32, 33, 79, 83, 83B, 83C, 83D 18, 201 6, 8, 24, 80, 84, 84B, 84C, 84D, 111 2, 12, 16, 17, 35, 35B, 35C, 44, 54, 62, 71, J J J B J B /29/2011 9/29/2011 9/29/2011 2/24/2012 9/29/2011 2/24/2012 EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) ND (8.8) ND (17) ND (0.93) ND (9.3) ND (0.89) ND (8.9) ND (8.8) ND (17) ND (0.93) ND (9.3) ND (0.89) ND (8.9) ND (8.8) ND (17) ND (0.93) ND (9.3) ND (0.89) ND (8.9) ND (8.8) ND (17) ND (0.93) ND (9.3) ND (0.89) ND (8.9) ND (8.8) 48 5 ND (9.3) ND (8.9) ND (8.8) ND (17) ND (0.93) ND (9.3) ND (0.89) ND (8.9) ND (8.8) ND (17) ND (0.93) ND (9.3) ND (0.89) ND (8.9) ND (8.8) ND (17) ND (0.93) ND (9.3) ND (0.89) ND (8.9) B PCB Bulk Product PCB Remediation Waste > 50 ppm PCB Bulk Product PCB Bulk Product PCB Remediation Waste > 50 ppm PCB Remediation Waste Surrogates Compound DCBP (1) DCBP (2) TCMX (1) TCMX (2) % Recovery % Recovery % Recovery % Recovery % Recovery % Recovery * (30-150) * (30-150) 71.7 (30-150) * (30-150) 117 (30-150) * (30-150) * (30-150) * (30-150) 76.1 (30-150) * (30-150) 126 (30-150) * (30-150) * (30-150) * (30-150) 87.8 (30-150) * (30-150) 101 (30-150) * (30-150) * (30-150) * (30-150) 84.4 (30-150) * (30-150) 99.6 (30-150) * (30-150) Notes: All solid/bulk sample concentrations in milligrams per kilogram (mg/kg)(ppm). Surface wipe sample concentrations are in micrograms per 100 cm2 (µg/100cm2) ND (1.0) = Not Detected above associated laboratory method detection limit Bold = Compound detected PCB Bulk Product = Sealants with PCB concentrations 50 ppm. Designation may be made based upon result from similar material(s) PCB Remediation Waste = Materials with PCB concentrations 1ppm which have been impacted by PCB Bulk Product Waste. Designation may be made based upon result from similar material(s) Excluded PCB Product = Sealants with PCB concentrations < 50 ppm and not impacted by a PCB Bulk Product Demo Debris = Manage as general demolition debris with < 1 ppm PCBs * = The surrogate recovery for this sample is not available due to sample dilution below the surrogate reporting limit required from high analyte concentration and/or matrix interferences ** = This surrogate recovery is outside the surrogate reporting limit ATC Associates Inc. 3/25/12 2 of 23 High School - Table 1 - PCB Analytical Data Summary_ Grouped by Series

31 Table 1 Building Material PCB Survey Brockton High School 470 Forest Avenue Brockton, Massachusetts draft Sample ID Material Location Characteristics Similar Samples Sample No. Date Collected Prep Method Analytical Method Compound Aroclor 1016 Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 Aroclor 1262 Aroclor 1268 Total PCBs Associated Source PCB Bulk Product Waste Determination (Management) 11 Caulk 12 Caulk 13 Glaze 14 Glaze 15 Glaze 16 Caulk Caulk (between metal/masonry) Caulk (between metal/masonry) Glazing (between metal/glass) Glazing (between metal/glass) Glazing (between metal/glass) Caulk (between metal/masonry) Interior, 2nd Floor, West Gym Connector Exterior, Ground Level, Elevation 16, Exterior, Ground Level, Elevation 16, Exterior, Ground Level, Elevation 17, Fine Exterior, Ground Level, Elevation 17, Fine Exterior, Ground Level, Elevation 17, Fine Administration Courtyard Administration Courtyard Arts, East Arts, East Arts, East Charcoal/Smooth/Soft/Dry/Rubbery Light Gray/Smooth/Soft/Dry/Rubbery Gray/Gritty/Semi-Hard/Dry/Brittle Gray/Gritty/Semi-Hard/Dry/Brittle Black/Gritty/Hard/Dry/Brittle Light Gray/Smooth/Soft/Dry/Rubbery - 2, 10B, 16, 17, 35, 35B, 35C, 44, 54, 62, 71, 2, 10B, 12, 17, 35, 35B, 35C, 44, 54, 62, 71, 1, 14, 43, 116 1, 13, 43, J J J J J J /29/2011 9/29/2011 9/29/2011 9/29/2011 9/29/2011 9/29/2011 EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) ND (3.8) ND (1.7) ND (440) ND (9.6) ND (470) ND (0.95) ND (3.8) ND (1.7) ND (440) ND (9.6) ND (470) ND (0.95) ND (3.8) ND (1.7) ND (440) ND (9.6) ND (470) ND (0.95) ND (3.8) ND (1.7) ND (440) ND (9.6) ND (470) ND (0.95) ND (3.8) 24 ND (440) ND (9.6) ND (470) ND (0.95) , , ND (3.8) ND (1.7) ND (440) ND (9.6) ND (470) ND (0.95) ND (3.8) ND (1.7) ND (440) ND (9.6) ND (470) ND (0.95) ND (3.8) ND (1.7) ND (440) ND (9.6) ND (470) ND (0.95) , , /15 Excluded PCB Product PCB Remediation Waste > 50 ppm PCB Bulk Product PCB Bulk Product PCB Bulk Product PCB Remediation Waste Surrogates Compound DCBP (1) DCBP (2) TCMX (1) TCMX (2) % Recovery % Recovery % Recovery % Recovery % Recovery % Recovery 92.1 (30-150) 81.8 (30-150) * (30-150) * (30-150) * (30-150) 80.0 (30-150) 97.2 (30-150) 123 (30-150) * (30-150) * (30-150) * (30-150) 84.3 (30-150) 101 (30-150) 109 (30-150) * (30-150) * (30-150) * (30-150) 107 (30-150) 93.7 (30-150) 126 (30-150) * (30-150) * (30-150) * (30-150) 98.4 (30-150) Notes: All solid/bulk sample concentrations in milligrams per kilogram (mg/kg)(ppm). Surface wipe sample concentrations are in micrograms per 100 cm2 (µg/100cm2) ND (1.0) = Not Detected above associated laboratory method detection limit Bold = Compound detected PCB Bulk Product = Sealants with PCB concentrations 50 ppm. Designation may be made based upon result from similar material(s) PCB Remediation Waste = Materials with PCB concentrations 1ppm which have been impacted by PCB Bulk Product Waste. Designation may be made based upon result from similar material(s) Excluded PCB Product = Sealants with PCB concentrations < 50 ppm and not impacted by a PCB Bulk Product Demo Debris = Manage as general demolition debris with < 1 ppm PCBs * = The surrogate recovery for this sample is not available due to sample dilution below the surrogate reporting limit required from high analyte concentration and/or matrix interferences ** = This surrogate recovery is outside the surrogate reporting limit ATC Associates Inc. 3/25/12 3 of 23 High School - Table 1 - PCB Analytical Data Summary_ Grouped by Series

32 Table 1 Building Material PCB Survey Brockton High School 470 Forest Avenue Brockton, Massachusetts draft Sample ID Material Location Characteristics Similar Samples Sample No. Date Collected Prep Method Analytical Method Compound Aroclor 1016 Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 Aroclor 1262 Aroclor 1268 Total PCBs Associated Source PCB Bulk Product Waste Determination (Management) 17 Caulk 18 Glaze 19 Glaze 20 Glaze 21 Caulk 22 Caulk Caulk (between metal/masonry) Glazing (between metal/glass) Glazing (between metal/glass) Glazing (between metal/glass) Caulk (between metal/masonry) Caulk (between metal/masonry) Exterior, Ground Level, Elevation 17, Fine Exterior, Ground Level, Elevation 17, Fine Exterior, Ground Level, Elevation 17, Fine Exterior, Ground Level, Fine Arts Exterior, 2nd Floor, Fine Arts Connector, Exterior, Ground Level, Library Arts, East, Door Arts, East, Door Arts, East Connector, East East Light Gray/Smooth/Soft/Dry/Rubbery Black/Smooth/Soft/Sticky/Rubbery Black/Smooth/Soft/Dry/Rubbery Black/Gritty/Hard/Dry/Brittle Black/Smooth/Soft/Sticky/Rubbery Black/Smooth/Soft/Sticky/Rubbery 2, 10B, 12, 16, 35, 35B, 35C, 44, 54, 62, 71, 4, 22, 23 4, 21, 23 9B, , 34B, 34C, 53, J J J J J J /29/2011 9/29/2011 9/29/2011 9/29/2011 9/29/2011 9/29/2011 EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) ND (3.8) ND (97) ND (450) ND (480) ND (0.95) ND (8.7) ND (3.8) ND (97) ND (450) ND (480) ND (0.95) ND (8.7) ND (3.8) ND (97) ND (450) ND (480) ND (0.95) ND (8.7) ND (3.8) ND (97) ND (450) ND (480) ND (0.95) ND (8.7) ND (3.8) ND (97) ND (450) ND (480) ND (0.95) ND (8.7) , ND (3.8) ND (97) ND (450) ND (480) ND (0.95) ND (8.7) ND (3.8) ND (97) ND (450) ND (480) ND (0.95) ND (8.7) ND (3.8) ND (97) ND (450) ND (480) ND (0.95) ND (8.7) , PCB Remediation Waste PCB Bulk Product PCB Bulk Product PCB Bulk Product Excluded PCB Product Excluded PCB Product Surrogates Compound DCBP (1) DCBP (2) TCMX (1) TCMX (2) % Recovery % Recovery % Recovery % Recovery % Recovery % Recovery 127 (30-150) *(30-150) *(30-150) *(30-150) 88.9 (30-150) *(30-150) 134 (30-150) * (30-150) * (30-150) * (30-150) 84.5 (30-150) * (30-150) 113 (30-150) * (30-150) * (30-150) * (30-150) 102 (30-150) * (30-150) 105 (30-150) * (30-150) * (30-150) * (30-150) 91.1 (30-150) * (30-150) Notes: All solid/bulk sample concentrations in milligrams per kilogram (mg/kg)(ppm). Surface wipe sample concentrations are in micrograms per 100 cm2 (µg/100cm2) ND (1.0) = Not Detected above associated laboratory method detection limit Bold = Compound detected PCB Bulk Product = Sealants with PCB concentrations 50 ppm. Designation may be made based upon result from similar material(s) PCB Remediation Waste = Materials with PCB concentrations 1ppm which have been impacted by PCB Bulk Product Waste. Designation may be made based upon result from similar material(s) Excluded PCB Product = Sealants with PCB concentrations < 50 ppm and not impacted by a PCB Bulk Product Demo Debris = Manage as general demolition debris with < 1 ppm PCBs * = The surrogate recovery for this sample is not available due to sample dilution below the surrogate reporting limit required from high analyte concentration and/or matrix interferences ** = This surrogate recovery is outside the surrogate reporting limit ATC Associates Inc. 3/25/12 4 of 23 High School - Table 1 - PCB Analytical Data Summary_ Grouped by Series

33 Table 1 Building Material PCB Survey Brockton High School 470 Forest Avenue Brockton, Massachusetts draft Sample ID Material Location Characteristics Similar Samples Sample No. Date Collected Prep Method Analytical Method Compound Aroclor 1016 Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 Aroclor 1262 Aroclor 1268 Total PCBs Associated Source PCB Bulk Product Waste Determination (Management) 23 Caulk 24 [G318-I-CLK] 25 [G318-I-CON-12] 26 [G318-I-CON-6] 27 [G318-I-CON-0] 28 [G318-I-CMU-6] 29 [G318-I-CMU-0] Caulk (between metal/masonry) Caulk (between metal/masonry) Textured Concrete (12" from Sample 24) Textured Concrete (6" from Sample 24) Textured Concrete (0" from Sample 24) Concrete Masonry Unit (6" from Sample 24) Concrete Masonry Unit (0" from Sample 24) Exterior, 2nd Floor, Fine Arts Connector, East Interior, Room G318, Green Interior, Room G318, Green Interior, Room G318, Green Interior, Room G318, Green Interior, Room G318, Green Interior, Room G318, Green Black/Smooth/Soft/Sticky/Rubbery Light Gray/Smooth/Soft/Dry/Rubbery 4, 21, 22 6, 8, 10, 80, 84, 84B, 84C, 84D, , 96 81, 86, 97 82, 87, 87B, 98 94, , 114, 202A, 202B, 202C 11J K K K K K K /29/ /4/ /4/ /4/ /4/ /4/ /4/2011 EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) ND (0.97) ND(8.5) ND(2.0) ND(2.0) ND(2.0) ND(0.10) ND(0.095) ND (0.97) ND(8.5) ND(2.0) ND(2.0) ND(2.0) ND(0.10) ND(0.095) ND (0.97) ND(8.5) ND(2.0) ND(2.0) ND(2.0) ND(0.10) ND(0.095) ND (0.97) ND(8.5) ND(2.0) ND(2.0) ND(2.0) ND(0.10) ND(0.095) ND (0.97) ND(0.10) ND(0.095) ND(2.0) ND(2.0) ND(2.0) ND(0.10) 0.12 ND (0.97) ND(8.5) ND(2.0) ND(2.0) ND(2.0) ND(0.10) ND(0.095) ND (0.97) ND(8.5) ND(2.0) ND(2.0) ND(2.0) ND(0.10) ND(0.095) ND (0.97) ND(8.5) ND(2.0) ND(2.0) ND(2.0) ND(0.10) ND(0.095) ND(0.10) Excluded PCB Product PCB Remediation Waste > 50 ppm PCB Remediation Waste PCB Remediation Waste PCB Remediation Waste Demo Debris Demo Debris Surrogates Compound DCBP (1) DCBP (2) TCMX (1) TCMX (2) % Recovery % Recovery % Recovery % Recovery % Recovery % Recovery % Recovery 114 (30-150) *(30-150) 108 (30-150) 106 (30-150) 110 (30-150) 93.5 (30-150) 94.9 (30-150) 122 (30-150) * (30-150) 101 (30-150) 115 (30-150) 109 (30-150) 92.5 (30-150) 101 (30-150) 112 (30-150) * (30-150) 107 (30-150) 97.5 (30-150) 101 (30-150) 70.4 (30-150) 75.2 (30-150) 84.3 (30-150) * (30-150) 85.6 (30-150) 113 (30-150) 117 (30-150) 83.9 (30-150) 90.8 (30-150) Notes: All solid/bulk sample concentrations in milligrams per kilogram (mg/kg)(ppm). Surface wipe sample concentrations are in micrograms per 100 cm2 (µg/100cm2) ND (1.0) = Not Detected above associated laboratory method detection limit Bold = Compound detected PCB Bulk Product = Sealants with PCB concentrations 50 ppm. Designation may be made based upon result from similar material(s) PCB Remediation Waste = Materials with PCB concentrations 1ppm which have been impacted by PCB Bulk Product Waste. Designation may be made based upon result from similar material(s) Excluded PCB Product = Sealants with PCB concentrations < 50 ppm and not impacted by a PCB Bulk Product Demo Debris = Manage as general demolition debris with < 1 ppm PCBs * = The surrogate recovery for this sample is not available due to sample dilution below the surrogate reporting limit required from high analyte concentration and/or matrix interferences ** = This surrogate recovery is outside the surrogate reporting limit ATC Associates Inc. 3/25/12 5 of 23 High School - Table 1 - PCB Analytical Data Summary_ Grouped by Series

34 Table 1 Building Material PCB Survey Brockton High School 470 Forest Avenue Brockton, Massachusetts draft Sample ID Material Location Characteristics Similar Samples Sample No. Date Collected Prep Method Analytical Method Compound Aroclor 1016 Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 Aroclor 1262 Aroclor 1268 Total PCBs Associated Source PCB Bulk Product Waste Determination (Management) 30 [G318-I-WGL] 31 [G318-I-WMT] 32 [G318-I-GLZ-M/M] 33 [G318-I-GLZ-M/G] 34 [F141-E-GLZ] 34B 34C wipe - Glass Wipe - Metal Caulk Glazing Glazing Glazing Glazing (0" from Sample 33) (between Samples 24 and 33) (between metal/metal) (between metal/glass) (between metal/glass) (between metal/glass) (between metal/glass) Interior, Room G318, Green Interior, Room G318, Green Interior, Room G318, Green Interior, Room G318, Green Exterior, near Room F141, Gym Exterior, Elevation 15, East, Gym Exterior, Elevation 15, Middle, Gym Black/Smooth/Soft/Sticky/Rubbery Black/Smooth/Soft/Sticky/Rubbery Black/Smooth/Soft/Dry/Rubbery Black/Smooth/Soft/Dry/Rubbery Black/Smooth/Soft/Dry/Rubbery 88, 115 5, 7, 9, 79, 83, 83B, 83C, 83D 19, 34B, 34C, 53, 61 19, 34, 34C, 53, 61 19, 34, 34B, 53, 61 11K K K K K B B /4/ /4/ /4/ /4/ /7/2011 2/24/2012 2/24/2012 EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 Concentration (µg/100 cm2) Concentration (µg/100 cm2) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) ND(0.20) ND(0.20) ND(38) ND(36) ND (9.2) ND (9.3) ND (9.3) ND(0.20) ND(0.20) ND(38) ND(36) ND (9.2) ND (9.3) ND (9.3) ND(0.20) ND(0.20) ND(38) ND(36) ND (9.2) ND (9.3) ND (9.3) ND(0.20) ND(0.20) ND(38) ND(36) ND (9.2) ND (9.3) ND (9.3) ND(0.20) ND(0.20) ND(38) ND(36) ND (9.2) ND (9.3) ND (9.3) ND(0.20) ND(0.20) ND(0.20) ND(38) ND(36) ND (9.2) ND (9.3) ND (9.3) ND(0.20) ND(0.20) ND(38) ND(36) ND (9.2) ND (9.3) ND (9.3) ND(0.20) ND(0.20) ND(38) ND(36) ND (9.2) ND (9.3) ND (9.3) ND(0.20) PCB Remediation Waste PCB Remediation Waste PCB Remediation Waste > 50 ppm PCB Bulk Product PCB Bulk Product PCB Bulk Product PCB Bulk Product Surrogates Compound DCBP (1) DCBP (2) TCMX (1) TCMX (2) % Recovery % Recovery % Recovery % Recovery % Recovery % Recovery % Recovery 71.7 (30-150) 82.6 (30-150) * (30-150) * (30-150) * (30-150) * (30-150) * (30-150) 78.8 (30-150) 92.0 (30-150) * (30-150) * (30-150) * (30-150) * (30-150) * (30-150) 100 (30-150) 92.6 (30-150) * (30-150) * (30-150) * (30-150) * (30-150) * (30-150) 96.3 (30-150) 89.7 (30-150) * (30-150) * (30-150) * (30-150) * (30-150) * (30-150) Notes: All solid/bulk sample concentrations in milligrams per kilogram (mg/kg)(ppm). Surface wipe sample concentrations are in micrograms per 100 cm2 (µg/100cm2) ND (1.0) = Not Detected above associated laboratory method detection limit Bold = Compound detected PCB Bulk Product = Sealants with PCB concentrations 50 ppm. Designation may be made based upon result from similar material(s) PCB Remediation Waste = Materials with PCB concentrations 1ppm which have been impacted by PCB Bulk Product Waste. Designation may be made based upon result from similar material(s) Excluded PCB Product = Sealants with PCB concentrations < 50 ppm and not impacted by a PCB Bulk Product Demo Debris = Manage as general demolition debris with < 1 ppm PCBs * = The surrogate recovery for this sample is not available due to sample dilution below the surrogate reporting limit required from high analyte concentration and/or matrix interferences ** = This surrogate recovery is outside the surrogate reporting limit ATC Associates Inc. 3/25/12 6 of 23 High School - Table 1 - PCB Analytical Data Summary_ Grouped by Series

35 Table 1 Building Material PCB Survey Brockton High School 470 Forest Avenue Brockton, Massachusetts draft Sample ID Material Location Characteristics Similar Samples Sample No. Date Collected Prep Method Analytical Method Compound Aroclor 1016 Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 Aroclor 1262 Aroclor 1268 Total PCBs Associated Source PCB Bulk Product Waste Determination (Management) 35 [F141-E-CLK] 35B 35C 36 [F141-E-WGB-6] 37 [141-E-WGB-0] 38 [F141-E-WGL] Caulk Caulk Caulk Wipe - Glazed Brick Wipe - Glazed Brick Wipe - Glass (between metal/masonry) (between metal/masonry) (between metal/masonry) (6" from Sample 35) (0" from Sample 35) (0" from Sample 34) Exterior, near Room F141, Gym Exterior, Elevation 15, East, Gym Exterior, Elevation 15, East, Gym Exterior, near Room F141, Gym Exterior, near Room F141, Gym Exterior, near Room F141, Gym Light Gray/Smooth/Soft/Dry/Rubbery Light Gray/Smooth/Soft/Dry/Rubbery Light Gray/Smooth/Soft/Dry/Rubbery 2, 10B, 12, 16, 17, 35B, 35C, 44, 54, 62, 71, 2, 10B, 12, 16, 17, 35, 35C, 44, 54, 62, 71, 2, 10B, 12, 16, 17, 35, 35B, 44, 54, 62, 71, , 66, 75 49, 67, 76 50, 68, 77 11K B B K K K /7/2011 2/24/2012 2/24/ /7/ /7/ /7/2011 EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (µg/100 cm2) Concentration (µg/100 cm2) Concentration (µg/100 cm2) <0.88 ND (0.93) ND (0.92) ND(0.20) ND(0.20) ND(0.20) 6 ND (0.93) ND (0.92) ND(0.20) ND(0.20) ND(0.20) <0.88 ND (0.93) ND (0.92) ND(0.20) ND(0.20) ND(0.20) <0.88 ND (0.93) ND (0.92) ND(0.20) ND(0.20) ND(0.20) <0.88 ND (0.93) ND (0.92) ND(0.20) ND(0.20) ND(0.20) ND(0.20) ND(0.20) ND(0.20) <0.88 ND (0.93) ND (0.92) ND(0.20) ND(0.20) ND(0.20) <0.88 ND (0.93) ND (0.92) ND(0.20) ND(0.20) ND(0.20) <0.88 ND (0.93) ND (0.92) ND(0.20) ND(0.20) ND(0.20) ND(0.20) ND(0.20) ND(0.20) - 34B 34C PCB Remediation Waste PCB Remediation Waste PCB Remediation Waste Demo Debris Demo Debris PCB Remediation Waste Surrogates Compound DCBP (1) DCBP (2) TCMX (1) TCMX (2) % Recovery % Recovery % Recovery % Recovery % Recovery % Recovery 94.4 (30-150) 117 (30-150) 58.3 (30-150) 135 (30-150) 135 (30-150) 134 (30-150) 74.6 (30-150) 109 (30-150) 55.0 (30-150) 110 (30-150) 113 (30-150) 114 (30-150) 102 (30-150) 102 (30-150) 99.4 (30-150) 95.2 (30-150) 95.5 (30-150) 94.7 (30-150) 109 (30-150) 105 (30-150) 103 (30-150) 97.9 (30-150) 100 (30-150) 101 (30-150) Notes: All solid/bulk sample concentrations in milligrams per kilogram (mg/kg)(ppm). Surface wipe sample concentrations are in micrograms per 100 cm2 (µg/100cm2) ND (1.0) = Not Detected above associated laboratory method detection limit Bold = Compound detected PCB Bulk Product = Sealants with PCB concentrations 50 ppm. Designation may be made based upon result from similar material(s) PCB Remediation Waste = Materials with PCB concentrations 1ppm which have been impacted by PCB Bulk Product Waste. Designation may be made based upon result from similar material(s) Excluded PCB Product = Sealants with PCB concentrations < 50 ppm and not impacted by a PCB Bulk Product Demo Debris = Manage as general demolition debris with < 1 ppm PCBs * = The surrogate recovery for this sample is not available due to sample dilution below the surrogate reporting limit required from high analyte concentration and/or matrix interferences ** = This surrogate recovery is outside the surrogate reporting limit ATC Associates Inc. 3/25/12 7 of 23 High School - Table 1 - PCB Analytical Data Summary_ Grouped by Series

36 Table 1 Building Material PCB Survey Brockton High School 470 Forest Avenue Brockton, Massachusetts draft Sample ID Material Location Characteristics Similar Samples Sample No. Date Collected Prep Method Analytical Method Compound Aroclor 1016 Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 Aroclor 1262 Aroclor 1268 Total PCBs Associated Source PCB Bulk Product Waste Determination (Management) 39 [F141-E-WMT] 40 [F141-E-CON-12] 41 [F141-E-CON-6] 42 [F141-E-CON-0] 42B 43 [R117-E-GLZ] Wipe - Metal Textured Concrete Textured Concrete Textured Concrete Textured Concrete Glazing (between Samples 34 and 35) (12" from Sample 35) (6" from Sample 35) (0" from Sample 35) (0" from Sample 35B) (between metal/glass) Exterior, near Room F141, Gym Exterior, near Room F141, Gym Exterior, near Room F141, Gym Exterior, near Room F141, Gym Exterior, Elevation 15, East, Gym Exterior, Room R117, Red Gray/Gritty/Semi-Hard/Dry/Brittle 51, 69, 78, , 55, 63, 72, , 56, 64, 73, B, 47, 57, 65, 74, 123, , 47, 57, 65, 74, 123, 203 1, 13, 14, K K K K B K /7/ /7/ /7/ /7/2011 2/24/ /7/2011 EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 Concentration (µg/100 cm2) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) ND(0.20) ND(0.48) ND(2.0) ND(2.0) ND(0.20) ND(86) ND(0.20) ND(0.48) ND(2.0) ND(2.0) ND(0.20) ND(86) ND(0.20) ND(0.48) ND(2.0) ND(2.0) ND(0.20) ND(86) ND(0.20) ND(0.48) ND(2.0) ND(2.0) ND(0.20) ND(86) ND(0.20) ND(86) ND(0.20) ND(0.48) ND(2.0) ND(2.0) ND(0.20) 840 ND(0.20) ND(0.48) ND(2.0) ND(2.0) 0.23 ND(86) ND(0.20) ND(0.48) ND(2.0) ND(2.0) ND(0.20) ND(86) ND(0.20) ND(0.48) ND(2.0) ND(2.0) ND(0.20) ND(86) ND(0.20) B - PCB Remediation Waste PCB Remediation Waste PCB Remediation Waste PCB Remediation Waste PCB Remediation Waste PCB Bulk Product Surrogates Compound DCBP (1) DCBP (2) TCMX (1) TCMX (2) % Recovery % Recovery % Recovery % Recovery % Recovery % Recovery 104 (30-150) 102 (30-150) 107 (30-150) 113 (30-150) 106 (30-150) * (30-150) 88.7 (30-150) 95.4 (30-150) 103 (30-150) 107 (30-150) 98.2 (30-150) * (30-150) 95.0 (30-150) 91.0 (30-150) 93.5 (30-150) 103 (30-150) 103 (30-150) * (30-150) 102 (30-150) 86.6 (30-150) 83.2 (30-150) 89.4 (30-150) 108 (30-150) * (30-150) Notes: All solid/bulk sample concentrations in milligrams per kilogram (mg/kg)(ppm). Surface wipe sample concentrations are in micrograms per 100 cm2 (µg/100cm2) ND (1.0) = Not Detected above associated laboratory method detection limit Bold = Compound detected PCB Bulk Product = Sealants with PCB concentrations 50 ppm. Designation may be made based upon result from similar material(s) PCB Remediation Waste = Materials with PCB concentrations 1ppm which have been impacted by PCB Bulk Product Waste. Designation may be made based upon result from similar material(s) Excluded PCB Product = Sealants with PCB concentrations < 50 ppm and not impacted by a PCB Bulk Product Demo Debris = Manage as general demolition debris with < 1 ppm PCBs * = The surrogate recovery for this sample is not available due to sample dilution below the surrogate reporting limit required from high analyte concentration and/or matrix interferences ** = This surrogate recovery is outside the surrogate reporting limit ATC Associates Inc. 3/25/12 8 of 23 High School - Table 1 - PCB Analytical Data Summary_ Grouped by Series

37 Table 1 Building Material PCB Survey Brockton High School 470 Forest Avenue Brockton, Massachusetts draft Sample ID Material Location Characteristics Similar Samples Sample No. Date Collected Prep Method Analytical Method Compound Aroclor 1016 Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 Aroclor 1262 Aroclor 1268 Total PCBs Associated Source PCB Bulk Product Waste Determination (Management) 44 [R117-E-CLK] 45 [R117-E-CON-12] 46 [R117-E-CON-6] 47 [R117-E-CON-0] 48 [R117-E-WGB-6] 49 [R117-E-WGB-0] Caulk Textured Concrete Textured Concrete Textured Concrete Wipe - Glazed Brick Wipe - Glazed Brick (between metal/masonry) (12" from Sample 44) (6" from Sample 44) (0" from Sample 44) (6" from Sample 44) (0" from Sample 44) Exterior, Room R117, Red Exterior, Room R117, Red Exterior, Room R117, Red Exterior, Room R117, Red Exterior, Room R117, Red Exterior, Room R117, Red Light Gray/Smooth/Soft/Dry/Rubbery 2, 10B, 12, 16, 17, 35, 35B, 35C, 54, 62, 71, , 55, 63, 72, , 56, 64, 73, , 42B, 57, 65, 74, 123, , 66, 75 37, 67, 76 11K K K K K K /7/ /7/ /7/ /7/ /7/ /7/2011 EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (µg/100 cm2) Concentration (µg/100 cm2) ND(8.8) ND(10) ND(5.0) ND(5.0) ND(0.20) ND(0.20) ND(8.8) ND(10) ND(5.0) ND(5.0) ND(0.20) ND(0.20) ND(8.8) ND(10) ND(5.0) ND(5.0) ND(0.20) ND(0.20) ND(8.8) ND(10) ND(5.0) ND(5.0) ND(0.20) ND(0.20) ND(8.8) ND(0.20) ND(0.20) 13 ND(10) ND(5.0) ND(5.0) ND(0.20) ND(0.20) ND(8.8) ND(10) ND(5.0) ND(5.0) ND(0.20) ND(0.20) ND(8.8) ND(10) ND(5.0) ND(5.0) ND(0.20) ND(0.20) ND(8.8) ND(10) ND(5.0) ND(5.0) ND(0.20) ND(0.20) ND(0.20) ND(0.20) PCB Remediation Waste > 50 ppm PCB Remediation Waste PCB Remediation Waste PCB Remediation Waste Demo Debris Demo Debris Surrogates Compound DCBP (1) DCBP (2) TCMX (1) TCMX (2) % Recovery % Recovery % Recovery % Recovery % Recovery % Recovery * (30-150) * (30-150) * (30-150) * (30-150) 110 (30-150) 106 (30-150) * (30-150) * (30-150) * (30-150) * (30-150) 93.6 (30-150) 91.0 (30-150) * (30-150) * (30-150) * (30-150) * (30-150) 95.9 (30-150) 94.6 (30-150) * (30-150) * (30-150) * (30-150) * (30-150) 105 (30-150) 103 (30-150) Notes: All solid/bulk sample concentrations in milligrams per kilogram (mg/kg)(ppm). Surface wipe sample concentrations are in micrograms per 100 cm2 (µg/100cm2) ND (1.0) = Not Detected above associated laboratory method detection limit Bold = Compound detected PCB Bulk Product = Sealants with PCB concentrations 50 ppm. Designation may be made based upon result from similar material(s) PCB Remediation Waste = Materials with PCB concentrations 1ppm which have been impacted by PCB Bulk Product Waste. Designation may be made based upon result from similar material(s) Excluded PCB Product = Sealants with PCB concentrations < 50 ppm and not impacted by a PCB Bulk Product Demo Debris = Manage as general demolition debris with < 1 ppm PCBs * = The surrogate recovery for this sample is not available due to sample dilution below the surrogate reporting limit required from high analyte concentration and/or matrix interferences ** = This surrogate recovery is outside the surrogate reporting limit ATC Associates Inc. 3/25/12 9 of 23 High School - Table 1 - PCB Analytical Data Summary_ Grouped by Series

38 Table 1 Building Material PCB Survey Brockton High School 470 Forest Avenue Brockton, Massachusetts draft Sample ID Material Location Characteristics Similar Samples Sample No. Date Collected Prep Method Analytical Method Compound Aroclor 1016 Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 Aroclor 1262 Aroclor 1268 Total PCBs Associated Source PCB Bulk Product Waste Determination (Management) 50 [R117-E-WGL] 51 [R117-E-WMT] 52 [R119-E-GLZ] 53 [ARTENT-E-GLZ] 54 [ARTENT-E-CLK] 55 [ARTENT-E-CON-12] Wipe - Glass Wipe - Metal Glazing Glazing Caulk Textured Concrete (0" from Sample 43) (between Samples 43 and 44) (between metal/glass) (between metal/glass) (between metal/masonry) (12" from Sample 54) Exterior, Room R117, Red Exterior, Room R117, Red Exterior, Room R119, Red Exterior, Fine Arts, South Entrance Exterior, Fine Arts, South Entrance Exterior, Fine Arts, South Entrance White/Gritty/Hard/Dry/Brittle Black/Smooth/Soft/Dry/Rubbery Light Gray/Smooth/Soft/Dry/Rubbery 38, 68, 77 39, 69, 78, , 34, 34B, 34C, 61 2, 10B, 12, 16, 17, 35, 35B, 35C, 44, 62, 71, , 45, 63, 72, K K K K K K /7/ /7/ /7/ /7/ /7/ /7/2011 EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 Concentration (µg/100 cm2) Concentration (µg/100 cm2) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) ND(0.20) ND(0.20) ND(0.89) ND(36) ND(9.6) ND(1.8) ND(0.20) ND(0.20) ND(0.89) ND(36) ND(9.6) ND(1.8) ND(0.20) ND(0.20) ND(0.89) ND(36) ND(9.6) ND(1.8) ND(0.20) ND(0.20) ND(0.89) ND(36) ND(9.6) ND(1.8) ND(0.20) ND(0.20) ND(0.89) ND(36) ND(9.6) 14 ND(0.20) ND(1.8) ND(0.20) ND(0.20) ND(0.89) ND(36) ND(9.6) ND(1.8) ND(0.20) ND(0.20) ND(0.89) ND(36) ND(9.6) ND(1.8) ND(0.20) ND(0.20) ND(0.89) ND(36) ND(9.6) ND(1.8) ND(0.20) Demo Debris Demo Debris PCB Bulk Product PCB Bulk Product PCB Remediation Waste > 50 ppm PCB Remediation Waste Surrogates Compound DCBP (1) DCBP (2) TCMX (1) TCMX (2) % Recovery % Recovery % Recovery % Recovery % Recovery % Recovery 101 (30-150) 62.9 (30-150) 113 (30-150) * (30-150) * (30-150) 108 (30-150) 86.5 (30-150) 69.4 (30-150) 77.8 (30-150) * (30-150) * (30-150) 109 (30-150) 94.6 (30-150) 62.6 (30-150) 109 (30-150) * (30-150) * (30-150) 120 (30-150) 104 (30-150) 60.8 (30-150) 1047 (30-150) * (30-150) * (30-150) 121 (30-150) Notes: All solid/bulk sample concentrations in milligrams per kilogram (mg/kg)(ppm). Surface wipe sample concentrations are in micrograms per 100 cm2 (µg/100cm2) ND (1.0) = Not Detected above associated laboratory method detection limit Bold = Compound detected PCB Bulk Product = Sealants with PCB concentrations 50 ppm. Designation may be made based upon result from similar material(s) PCB Remediation Waste = Materials with PCB concentrations 1ppm which have been impacted by PCB Bulk Product Waste. Designation may be made based upon result from similar material(s) Excluded PCB Product = Sealants with PCB concentrations < 50 ppm and not impacted by a PCB Bulk Product Demo Debris = Manage as general demolition debris with < 1 ppm PCBs * = The surrogate recovery for this sample is not available due to sample dilution below the surrogate reporting limit required from high analyte concentration and/or matrix interferences ** = This surrogate recovery is outside the surrogate reporting limit ATC Associates Inc. 3/25/12 10 of 23 High School - Table 1 - PCB Analytical Data Summary_ Grouped by Series

39 Table 1 Building Material PCB Survey Brockton High School 470 Forest Avenue Brockton, Massachusetts draft Sample ID Material Location Characteristics Similar Samples Sample No. Date Collected Prep Method Analytical Method Compound Aroclor 1016 Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 Aroclor 1262 Aroclor 1268 Total PCBs Associated Source PCB Bulk Product Waste Determination (Management) 56 [ARTENT-E-CON-6] 57 [ARTENT-E-CON-0] 58 [ARTENT-E-CMU-12] 59 [ARTENT-E-CMU-6] 60 [ARTENT-E-CMU-0] 61 [E115-E-GLZ] Textured Concrete Textured Concrete Concrete Masonry Unit Concrete Masonry Unit Concrete Masonry Unit Glazing (6" from Sample 54) (0" from Sample 54) (12" from Sample 54) (6" from Sample 54) (0" from Sample 54) (between metal/glass) Exterior, Fine Arts, South Entrance Exterior, Fine Arts, South Entrance Exterior, Fine Arts, South Entrance Exterior, Fine Arts, South Entrance Exterior, Fine Arts, South Entrance Exterior, Room E115, Fine Arts Black/Smooth/Soft/Dry/Rubbery 41, 46, 64, 73, , 42B, 47, 65, 74, 123, B, , 34, 34B, 34C, 53 11K K K K K K /7/ /7/ /7/ /7/ /7/ /7/2011 EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) ND(5.0) ND(5.0) ND(0.087) ND(0.10) ND(0.095) ND(19) ND(5.0) ND(5.0) ND(0.087) ND(0.10) ND(0.095) ND(19) ND(5.0) ND(5.0) ND(0.087) ND(0.10) ND(0.095) ND(19) ND(5.0) ND(5.0) ND(0.087) ND(0.10) ND(0.095) ND(19) ND(19) ND(5.0) ND(5.0) ND(0.087) ND(0.10) ND(0.095) 82 ND(5.0) ND(5.0) ND(0.087) ND(0.10) ND(0.095) ND(19) ND(5.0) ND(5.0) ND(0.087) ND(0.10) ND(0.095) ND(19) ND(5.0) ND(5.0) ND(0.087) ND(0.10) ND(0.095) ND(19) PCB Remediation Waste PCB Remediation Waste Demo Debris Demo Debris Demo Debris PCB Bulk Product Surrogates Compound DCBP (1) DCBP (2) TCMX (1) TCMX (2) % Recovery % Recovery % Recovery % Recovery % Recovery % Recovery 130 (30-150) * (30-150) 66.2 (30-150) 65.8 (30-150) 73.1 (30-150) * (30-150) 127 (30-150) * (30-150) 95.9 (30-150) 95.3 (30-150) 89.9 (30-150) * (30-150) 131 (30-150) * (30-150) 103 (30-150) 107 (30-150) 109 (30-150) * (30-150) 130 (30-150) * (30-150) 98.3 (30-150) 102 (30-150) 104 (30-150) * (30-150) Notes: All solid/bulk sample concentrations in milligrams per kilogram (mg/kg)(ppm). Surface wipe sample concentrations are in micrograms per 100 cm2 (µg/100cm2) ND (1.0) = Not Detected above associated laboratory method detection limit Bold = Compound detected PCB Bulk Product = Sealants with PCB concentrations 50 ppm. Designation may be made based upon result from similar material(s) PCB Remediation Waste = Materials with PCB concentrations 1ppm which have been impacted by PCB Bulk Product Waste. Designation may be made based upon result from similar material(s) Excluded PCB Product = Sealants with PCB concentrations < 50 ppm and not impacted by a PCB Bulk Product Demo Debris = Manage as general demolition debris with < 1 ppm PCBs * = The surrogate recovery for this sample is not available due to sample dilution below the surrogate reporting limit required from high analyte concentration and/or matrix interferences ** = This surrogate recovery is outside the surrogate reporting limit ATC Associates Inc. 3/25/12 11 of 23 High School - Table 1 - PCB Analytical Data Summary_ Grouped by Series

40 Table 1 Building Material PCB Survey Brockton High School 470 Forest Avenue Brockton, Massachusetts draft Sample ID Material Location Characteristics Similar Samples Sample No. Date Collected Prep Method Analytical Method Compound Aroclor 1016 Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 Aroclor 1262 Aroclor 1268 Total PCBs Associated Source PCB Bulk Product Waste Determination (Management) 62 [E115-E-CLK] 63 [E115-E-CON-12] 64 [E115-E-CON-6] 65 [E115-E-CON-0] 66 [E115-E-WGB-6] 67 [E115-E-WGB-0] Caulk Textured Concrete Textured Concrete Textured Concrete Wipe - Glazed Brick Wipe - Glazed Brick (between metal/masonry) (12" from Sample 62) (6" from Sample 62) (0" from Sample 62) (6" from Sample 62) (0" from Sample 62) Exterior, Room E115, Fine Arts Exterior, Room E115, Fine Arts Exterior, Room E115, Fine Arts Exterior, Room E115, Fine Arts Exterior, Room E115, Fine Arts Exterior, Room E115, Fine Arts Light Gray/Smooth/Soft/Dry/Rubbery 2, 10B, 12, 16, 17, 35, 35B, 35C, 44, 54, 71, , 45, 55, 72, , 46, 56, 73, , 42B, 47, 57, 74, 123, , 48, 75 37, 49, 76 11K K K K K K /7/ /7/ /7/ /7/ /7/ /7/2011 EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (µg/100 cm2) Concentration (µg/100 cm2) <ND(9.9) <ND(1.0) ND(5.0) <ND(1.0) ND(0.20) ND(0.20) <ND(9.9) <ND(1.0) ND(5.0) <ND(1.0) ND(0.20) ND(0.20) <ND(9.9) <ND(1.0) ND(5.0) <ND(1.0) ND(0.20) ND(0.20) <ND(9.9) <ND(1.0) ND(5.0) <ND(1.0) ND(0.20) ND(0.20) <ND(9.9) ND(0.20) ND(0.20) 10 <ND(1.0) ND(5.0) <ND(1.0) ND(0.20) ND(0.20) <ND(9.9) <ND(1.0) ND(5.0) <ND(1.0) ND(0.20) ND(0.20) <ND(9.9) <ND(1.0) ND(5.0) <ND(1.0) ND(0.20) ND(0.20) <ND(9.9) <ND(1.0) ND(5.0) <ND(1.0) ND(0.20) ND(0.20) ND(0.20) ND(0.20) PCB Remediation Waste > 50 ppm PCB Remediation Waste PCB Remediation Waste PCB Remediation Waste Demo Debris Demo Debris Surrogates Compound DCBP (1) DCBP (2) TCMX (1) TCMX (2) % Recovery % Recovery % Recovery % Recovery % Recovery % Recovery * (30-150) 102 (30-150) * (30-150) 89.3 (30-150) 71.1 (30-150) 72.0 (30-150) * (30-150) 105 (30-150) * (30-150) 92.5 (30-150) 78.0 (30-150) 79.7 (30-150) * (30-150) 120 (30-150) * (30-150) 100 (30-150) 95.0 (30-150) 97.6 (30-150) * (30-150) 120 (30-150) * (30-150) 101 (30-150) 91.9 (30-150) 94.9 (30-150) Notes: All solid/bulk sample concentrations in milligrams per kilogram (mg/kg)(ppm). Surface wipe sample concentrations are in micrograms per 100 cm2 (µg/100cm2) ND (1.0) = Not Detected above associated laboratory method detection limit Bold = Compound detected PCB Bulk Product = Sealants with PCB concentrations 50 ppm. Designation may be made based upon result from similar material(s) PCB Remediation Waste = Materials with PCB concentrations 1ppm which have been impacted by PCB Bulk Product Waste. Designation may be made based upon result from similar material(s) Excluded PCB Product = Sealants with PCB concentrations < 50 ppm and not impacted by a PCB Bulk Product Demo Debris = Manage as general demolition debris with < 1 ppm PCBs * = The surrogate recovery for this sample is not available due to sample dilution below the surrogate reporting limit required from high analyte concentration and/or matrix interferences ** = This surrogate recovery is outside the surrogate reporting limit ATC Associates Inc. 3/25/12 12 of 23 High School - Table 1 - PCB Analytical Data Summary_ Grouped by Series

41 Table 1 Building Material PCB Survey Brockton High School 470 Forest Avenue Brockton, Massachusetts draft Sample ID Material Location Characteristics Similar Samples Sample No. Date Collected Prep Method Analytical Method Compound Aroclor 1016 Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 Aroclor 1262 Aroclor 1268 Total PCBs Associated Source PCB Bulk Product Waste Determination (Management) 68 [E115-E-WGL] 69 [E115-E-WMT] 70 [Y154-E-GLZ] 71 [Y154-E-CLK] 72 [Y154-E-CON-12] 73 [Y154-E-CON-6] Wipe - Glass Wipe - Metal Glazing Caulk Textured Concrete Textured Concrete (0" from Sample 61) (between Samples 61 and 62) (between metal/glass) (between metal/masonry) (12" from Sample 71) (6" from Sample 71) Exterior, Room E115, Fine Arts Exterior, Room E115, Fine Arts Exterior, near Room Y154, Yellow Exterior, near Room Y154, Yellow Exterior, near Room Y154, Yellow Exterior, near Room Y154, Yellow Gray/Gritty/Hard/Dry/Brittle Light Gray/Smooth/Soft/Dry/Rubbery 38, 50, 77 39, 51, 78, 126-2, 10B, 12, 16, 17, 35, 35B, 35C, 44, 54, 62, , 45, 55, 63, , 46, 56, 64, K K K K K K /7/ /7/ /7/ /7/ /7/ /7/2011 EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 Concentration (µg/100 cm2) Concentration (µg/100 cm2) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) ND(0.20) ND(0.20) ND(34) ND(8.5) ND(2.0) ND(5.0) ND(0.20) ND(0.20) ND(34) ND(8.5) ND(2.0) ND(5.0) ND(0.20) ND(0.20) ND(34) ND(8.5) ND(2.0) ND(5.0) ND(0.20) ND(0.20) ND(34) ND(8.5) ND(2.0) ND(5.0) ND(0.20) ND(0.20) ND(34) ND(0.20) ND(8.5) ND(2.0) ND(5.0) ND(0.20) ND(0.20) ND(34) ND(8.5) ND(2.0) ND(5.0) ND(0.20) ND(0.20) ND(34) ND(8.5) ND(2.0) ND(5.0) ND(0.20) ND(0.20) ND(34) ND(8.5) ND(2.0) ND(5.0) ND(0.20) PCB Remediation Waste PCB Remediation Waste PCB Bulk Product PCB Remediation Waste PCB Remediation Waste PCB Remediation Waste Surrogates Compound DCBP (1) DCBP (2) TCMX (1) TCMX (2) % Recovery % Recovery % Recovery % Recovery % Recovery % Recovery 74.9 (30-150) 77.5 (30-150) * (30-150) * (30-150) 98.9 (30-150) * (30-150) 81.3 (30-150) 83.2 (30-150) * (30-150) * (30-150) 100 (30-150) * (30-150) 98.7 (30-150) 99.4 (30-150) * (30-150) * (30-150) 107 (30-150) * (30-150) 95.9 (30-150) 95.9 (30-150) * (30-150) * (30-150) 106 (30-150) * (30-150) Notes: All solid/bulk sample concentrations in milligrams per kilogram (mg/kg)(ppm). Surface wipe sample concentrations are in micrograms per 100 cm2 (µg/100cm2) ND (1.0) = Not Detected above associated laboratory method detection limit Bold = Compound detected PCB Bulk Product = Sealants with PCB concentrations 50 ppm. Designation may be made based upon result from similar material(s) PCB Remediation Waste = Materials with PCB concentrations 1ppm which have been impacted by PCB Bulk Product Waste. Designation may be made based upon result from similar material(s) Excluded PCB Product = Sealants with PCB concentrations < 50 ppm and not impacted by a PCB Bulk Product Demo Debris = Manage as general demolition debris with < 1 ppm PCBs * = The surrogate recovery for this sample is not available due to sample dilution below the surrogate reporting limit required from high analyte concentration and/or matrix interferences ** = This surrogate recovery is outside the surrogate reporting limit ATC Associates Inc. 3/25/12 13 of 23 High School - Table 1 - PCB Analytical Data Summary_ Grouped by Series

42 Table 1 Building Material PCB Survey Brockton High School 470 Forest Avenue Brockton, Massachusetts draft Sample ID Material Location Characteristics Similar Samples Sample No. Date Collected Prep Method Analytical Method Compound Aroclor 1016 Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 Aroclor 1262 Aroclor 1268 Total PCBs Associated Source PCB Bulk Product Waste Determination (Management) 74 [Y154-E-CON-0] 75 [Y154-E-WGB-6] 76 [Y154-E-WGB-0] 77 [Y154-E-WGL] 78 [Y154-E-WMT] 79 [Y154-I-GLZ] Textured Concrete Wipe - Glazed Brick Wipe - Glazed Brick Wipe - Glass Wipe - Metal Glazing (0" from Sample 71) (6" from Sample 71) (0" from Sample 71) (0" from Sample 70) (between Samples 70 and 71) (between metal/glass) Exterior, near Room Y154, Yellow Exterior, near Room Y154, Yellow Exterior, near Room Y154, Yellow Exterior, near Room Y154, Yellow Exterior, near Room Y154, Yellow Interior, near Room Y154, Yellow Black/Smooth/Soft/Sticky/Rubbery 42, 42B, 47, 57, 65, 123, , 48, 66 37, 49, 67 38, 50, 68 39, 51, 69, 126 5, 7, 9, 33, 83, 83B, 83C, 83D 11K K K K K K /7/ /7/ /7/ /7/ /7/ /7/2011 EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 Concentration (mg/kg) Concentration (µg/100 cm2) Concentration (µg/100 cm2) Concentration (µg/100 cm2) Concentration (µg/100 cm2) Concentration (mg/kg) ND(5.0) ND(0.20) ND(0.20) ND(0.20) ND(0.20) ND(8.4) ND(5.0) ND(0.20) ND(0.20) ND(0.20) ND(0.20) ND(8.4) ND(5.0) ND(0.20) ND(0.20) ND(0.20) ND(0.20) ND(8.4) ND(5.0) ND(0.20) ND(0.20) ND(0.20) ND(0.20) ND(8.4) 26 ND(0.20) ND(0.20) ND(0.20) ND(0.20) ND(8.4) ND(5.0) ND(0.20) ND(0.20) ND(0.20) ND(5.0) ND(0.20) ND(0.20) ND(0.20) ND(0.20) ND(8.4) ND(5.0) ND(0.20) ND(0.20) ND(0.20) ND(0.20) ND(8.4) ND(5.0) ND(0.20) ND(0.20) ND(0.20) ND(0.20) ND(8.4) 26 ND(0.20) ND(0.20) ND(0.20) PCB Remediation Waste Demo Debris Demo Debris PCB Remediation Waste PCB Remediation Waste PCB Bulk Product Surrogates Compound DCBP (1) DCBP (2) TCMX (1) TCMX (2) % Recovery % Recovery % Recovery % Recovery % Recovery % Recovery * (30-150) 75.3 (30-150) 73.3 (30-150) 72.6 (30-150) 76.1 (30-150) * (30-150) * (30-150) 81.5 (30-150) 80.2 (30-150) 78.7 (30-150) 82.9 (30-150) * (30-150) * (30-150) 103 (30-150) 102 (30-150) 98.9 (30-150) 97.7 (30-150) * (30-150) * (30-150) 99.6 (30-150) 98.8 (30-150) 95.7 (30-150) 95.0 (30-150) * (30-150) Notes: All solid/bulk sample concentrations in milligrams per kilogram (mg/kg)(ppm). Surface wipe sample concentrations are in micrograms per 100 cm2 (µg/100cm2) ND (1.0) = Not Detected above associated laboratory method detection limit Bold = Compound detected PCB Bulk Product = Sealants with PCB concentrations 50 ppm. Designation may be made based upon result from similar material(s) PCB Remediation Waste = Materials with PCB concentrations 1ppm which have been impacted by PCB Bulk Product Waste. Designation may be made based upon result from similar material(s) Excluded PCB Product = Sealants with PCB concentrations < 50 ppm and not impacted by a PCB Bulk Product Demo Debris = Manage as general demolition debris with < 1 ppm PCBs * = The surrogate recovery for this sample is not available due to sample dilution below the surrogate reporting limit required from high analyte concentration and/or matrix interferences ** = This surrogate recovery is outside the surrogate reporting limit ATC Associates Inc. 3/25/12 14 of 23 High School - Table 1 - PCB Analytical Data Summary_ Grouped by Series

43 Table 1 Building Material PCB Survey Brockton High School 470 Forest Avenue Brockton, Massachusetts draft Sample ID Material Location Characteristics Similar Samples Sample No. Date Collected Prep Method Analytical Method Compound Aroclor 1016 Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 Aroclor 1262 Aroclor 1268 Total PCBs Associated Source PCB Bulk Product Waste Determination (Management) 80 [Y154-I-CLK] 81 [Y154-I-CON-6] 82 [Y154-I-CON-0] 83 [F305-I-GLZ] 83B 83C Textured Concrete Textured Concrete Glazing Glazing (6" from Sample 80) (0" from Sample 80) (between metal/glass) (between metal/glass) Caulk (between metal/masonry) Glazing (between metal/glass) Interior, near Room Y154, Yellow Interior, near Room Y154, Yellow Interior, near Room Y154, Yellow Interior, near Room F305, Gym Interior, Elev. 12, 2nd Floor, North, Gym Interior, Elev. 12, 2nd Floor, North, Gym Light Gray/Smooth/Soft/Dry/Rubbery Black/Smooth/Soft/Sticky/Rubbery Black/Smooth/Soft/Sticky/Rubbery Black/Smooth/Soft/Sticky/Rubbery 6, 8, 10, 24, 84, 84B, 84C, 84D, , 86, 97 27, 87, 87B, 98 5, 7, 9,33, 79, 83B, 83C, 83D 5, 7, 9, 33, 79, 83, 83C, 83D 5, 7, 9, 33, 79, 83, 83B, 83D 11K K K K B B /7/ /7/ /7/ /8/2011 2/24/2012 2/24/2012 EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) ND(8.5) ND(2.0) ND(1.9) ND(9.6) ND(9.0) ND(9.8) ND(8.5) ND(2.0) ND(1.9) ND(9.6) ND(9.0) ND(9.8) ND(8.5) ND(2.0) ND(1.9) ND(9.6) ND(9.0) ND(9.8) ND(8.5) ND(2.0) ND(1.9) ND(9.6) ND(9.0) ND(9.8) ND(9.6) ND(9.0) ND(9.8) ND(8.5) ND(2.0) ND(1.9) ND(8.5) ND(2.0) ND(1.9) ND(9.6) ND(9.0) ND(9.8) ND(8.5) ND(2.0) ND(1.9) ND(9.6) ND(9.0) ND(9.8) ND(8.5) ND(2.0) ND(1.9) ND(9.6) ND(9.0) ND(9.8) PCB Remediation Waste > 50 ppm PCB Remediation Waste PCB Remediation Waste PCB Bulk Product PCB Bulk Product PCB Bulk Product Surrogates Compound DCBP (1) DCBP (2) TCMX (1) TCMX (2) % Recovery % Recovery % Recovery % Recovery % Recovery % Recovery * (30-150) 103 (30-150) 106 (30-150) * (30-150) * (30-150) * (30-150) * (30-150) 105 (30-150) 108 (30-150) * (30-150) * (30-150) * (30-150) * (30-150) 112 (30-150) 109 (30-150) * (30-150) * (30-150) * (30-150) * (30-150) 109 (30-150) 109 (30-150) * (30-150) * (30-150) * (30-150) Notes: All solid/bulk sample concentrations in milligrams per kilogram (mg/kg)(ppm). Surface wipe sample concentrations are in micrograms per 100 cm2 (µg/100cm2) ND (1.0) = Not Detected above associated laboratory method detection limit Bold = Compound detected PCB Bulk Product = Sealants with PCB concentrations 50 ppm. Designation may be made based upon result from similar material(s) PCB Remediation Waste = Materials with PCB concentrations 1ppm which have been impacted by PCB Bulk Product Waste. Designation may be made based upon result from similar material(s) Excluded PCB Product = Sealants with PCB concentrations < 50 ppm and not impacted by a PCB Bulk Product Demo Debris = Manage as general demolition debris with < 1 ppm PCBs * = The surrogate recovery for this sample is not available due to sample dilution below the surrogate reporting limit required from high analyte concentration and/or matrix interferences ** = This surrogate recovery is outside the surrogate reporting limit ATC Associates Inc. 3/25/12 15 of 23 High School - Table 1 - PCB Analytical Data Summary_ Grouped by Series

44 Table 1 Building Material PCB Survey Brockton High School 470 Forest Avenue Brockton, Massachusetts draft Sample ID Material Location Characteristics Similar Samples Sample No. Date Collected Prep Method Analytical Method Compound Aroclor 1016 Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 Aroclor 1262 Aroclor 1268 Total PCBs Associated Source PCB Bulk Product Waste Determination (Management) 83D 84 [F305-I-CLK] 84B 84C 84D 85 [F305-I-CON-12] 86 [F305-I-CON-6] Glazing Caulk Caulk Caulk Caulk Textured Concrete Textured Concrete (between metal/glass) (between metal/masonry) (between metal/masonry) (between metal/masonry) (between metal/masonry) (12" from Sample 84) (6" from Sample 84) Interior, Elev. 12, 2nd Floor, Middle, Gym Interior, near Room F305, Gym Interior, Elev. 12, 2nd Floor, North, Gym Interior, Elev. 12, 2nd Floor, North, Gym Interior, Elev. 12, 2nd Floor, Middle, Gym Interior, near Room F305, Gym Interior, near Room F305, Gym Black/Smooth/Soft/Sticky/Rubbery Light Gray/Smooth/Soft/Dry/Rubbery Light Gray/Smooth/Soft/Dry/Rubbery Light Gray/Smooth/Soft/Dry/Rubbery Light Gray/Smooth/Soft/Dry/Rubbery 5, 7, 9, 33, 79, 83, 83B, 83C 6, 8, 10, 24, 80, 84B, 84C, 84D, 111 6, 8, 10, 24, 80, 84, 84C, 84D, 111 6, 8, 10, 24, 80, 84, 84B, 84D, 111 6, 8, 10, 24, 80, 84, 84B, 84C, , 96 26, 81, 97 12B K B B B K K /24/ /8/2011 2/24/2012 2/24/2012 2/24/ /8/ /8/2011 EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) ND(9.1) ND(0.98) ND(0.99) ND(3.7) ND(8.9) ND(0.095) ND(0.095) ND(9.1) ND(0.98) ND(0.99) ND(3.7) ND(8.9) ND(0.095) ND(0.095) ND(9.1) ND(0.98) ND(0.99) ND(3.7) ND(8.9) ND(0.095) ND(0.095) ND(9.1) ND(0.98) ND(0.99) ND(3.7) ND(8.9) ND(0.095) ND(0.095) ND(9.1) ND(0.095) 50 ND(0.98) ND(0.99) ND(3.7) ND(8.9) ND(0.095) ND(0.095) ND(9.1) ND(0.98) ND(0.99) ND(3.7) ND(8.9) ND(0.095) ND(0.095) ND(9.1) ND(0.98) ND(0.99) ND(3.7) ND(8.9) ND(0.095) ND(0.095) ND(9.1) ND(0.98) ND(0.99) ND(3.7) ND(8.9) ND(0.095) ND(0.095) ND(0.095) B PCB Bulk Product PCB Remediation Waste > 50 ppm PCB Remediation Waste > 50 ppm PCB Remediation Waste > 50 ppm PCB Remediation Waste > 50 ppm PCB Remediation Waste PCB Remediation Waste Surrogates Compound DCBP (1) DCBP (2) TCMX (1) TCMX (2) % Recovery % Recovery % Recovery % Recovery % Recovery % Recovery % Recovery * (30-150) 120 (30-150) 118 (30-150) 131 (30-150) * (30-150) 70.7 (30-150) 71.5 (30-150) * (30-150) 96.5 (30-150) 110 (30-150) 121 (30-150) * (30-150) 104 (30-150) 106 (30-150) * (30-150) 95.2 (30-150) 105 (30-150) 103 (30-150) * (30-150) 101 (30-150) 99.9 (30-150) * (30-150) 99.3 (30-150) 111 (30-150) 107 (30-150) * (30-150) 96.3 (30-150) 95.3 (30-150) Notes: All solid/bulk sample concentrations in milligrams per kilogram (mg/kg)(ppm). Surface wipe sample concentrations are in micrograms per 100 cm2 (µg/100cm2) ND (1.0) = Not Detected above associated laboratory method detection limit Bold = Compound detected PCB Bulk Product = Sealants with PCB concentrations 50 ppm. Designation may be made based upon result from similar material(s) PCB Remediation Waste = Materials with PCB concentrations 1ppm which have been impacted by PCB Bulk Product Waste. Designation may be made based upon result from similar material(s) Excluded PCB Product = Sealants with PCB concentrations < 50 ppm and not impacted by a PCB Bulk Product Demo Debris = Manage as general demolition debris with < 1 ppm PCBs * = The surrogate recovery for this sample is not available due to sample dilution below the surrogate reporting limit required from high analyte concentration and/or matrix interferences ** = This surrogate recovery is outside the surrogate reporting limit ATC Associates Inc. 3/25/12 16 of 23 High School - Table 1 - PCB Analytical Data Summary_ Grouped by Series

45 Table 1 Building Material PCB Survey Brockton High School 470 Forest Avenue Brockton, Massachusetts draft Sample ID Material Location Characteristics Similar Samples Sample No. Date Collected Prep Method Analytical Method Compound Aroclor 1016 Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 Aroclor 1262 Aroclor 1268 Total PCBs Associated Source PCB Bulk Product Waste Determination (Management) 87 [F305-I-CON-0] 87B 88 [F305-I-WMT] 89 [F305-I-WSL-6] 93 [ARTENT-I-CMU-12] 94 [ARTENT-I-CMU-6] Textured Concrete (0" from Sample 84) Textured Concrete (0" from Sample 84C) Wipe - Metal (between Samples 83 and 84) Wipe - Sill Plate (6" from Sample 84) Concrete Masonry Unit (12" from Sample 92) Concrete Masonry Unit (6" from Sample 92) Interior, near Room F305, Gym Interior, Elev. 12, 2nd Floor, North, Gym Interior, near Room F305, Gym Interior, near Room F305, Gym Interior, Fine Arts, South Entrance Interior, Fine Arts, South Entrance 27, 82, 87B, 98 27, 82, 87, 98 31, , K B K K K K /8/2011 2/24/ /8/ /8/ /8/ /8/2011 EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 Concentration (mg/kg) Concentration (mg/kg) Concentration (µg/100 cm2) Concentration (µg/100 cm2) Concentration (mg/kg) Concentration (mg/kg) ND(0.10) ND(48) ND(0.20) ND(0.20) ND(0.10) ND(0.095) ND(0.10) ND(48) ND(0.20) ND(0.20) ND(0.10) ND(0.095) ND(0.10) ND(48) ND(0.20) ND(0.20) ND(0.10) ND(0.095) ND(0.10) 280 ND(0.20) ND(0.20) ND(0.10) ND(0.095) ND(0.10) ND(48) ND(0.20) ND(0.20) ND(0.10) ND(48) ND(0.10) ND(0.095) ND(0.10) ND(48) ND(0.20) ND(0.20) ND(0.10) ND(0.095) ND(0.10) ND(48) ND(0.20) ND(0.20) ND(0.10) ND(0.095) ND(0.10) ND(48) ND(0.20) ND(0.20) ND(0.10) ND(0.095) ND(0.10) PCB Remediation Waste PCB Remediation Waste > 50 PCB Remediation Waste Demo Debris Demo Debris Demo Debris Surrogates Compound DCBP (1) DCBP (2) TCMX (1) TCMX (2) % Recovery % Recovery % Recovery % Recovery % Recovery % Recovery 66.9 (30-150) * (30-150) 74.6 (30-150) 92.7 (30-150) 75.9 (30-150) 69.7 (30-150) 99.4 (30-150) * (30-150) 80.5 (30-150) 101 (30-150) 112 (30-150) 104 (30-150) 102 (30-150) * (30-150) 95.0 (30-150) 96.4 (30-150) 110 (30-150) 99.2 (30-150) 97.5 (30-150) * (30-150) 92.2 (30-150) 93.0 (30-150) 105 (30-150) 94.3 (30-150) Notes: All solid/bulk sample concentrations in milligrams per kilogram (mg/kg)(ppm). Surface wipe sample concentrations are in micrograms per 100 cm2 (µg/100cm2) ND (1.0) = Not Detected above associated laboratory method detection limit Bold = Compound detected PCB Bulk Product = Sealants with PCB concentrations 50 ppm. Designation may be made based upon result from similar material(s) PCB Remediation Waste = Materials with PCB concentrations 1ppm which have been impacted by PCB Bulk Product Waste. Designation may be made based upon result from similar material(s) Excluded PCB Product = Sealants with PCB concentrations < 50 ppm and not impacted by a PCB Bulk Product Demo Debris = Manage as general demolition debris with < 1 ppm PCBs * = The surrogate recovery for this sample is not available due to sample dilution below the surrogate reporting limit required from high analyte concentration and/or matrix interferences ** = This surrogate recovery is outside the surrogate reporting limit ATC Associates Inc. 3/25/12 17 of 23 High School - Table 1 - PCB Analytical Data Summary_ Grouped by Series

46 Table 1 Building Material PCB Survey Brockton High School 470 Forest Avenue Brockton, Massachusetts draft Sample ID Material Location Characteristics Similar Samples Sample No. Date Collected Prep Method Analytical Method Compound Aroclor 1016 Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 Aroclor 1262 Aroclor 1268 Total PCBs Associated Source PCB Bulk Product Waste Determination (Management) 95 [ARTENT-I-CMU-0] 95B 96 [ARTENT-I-CON-12] 97 [ARTENT-I-CON-6] 98 [ARTENT-I-CON-0] 102 [E115-I-PLS-12] Concrete Masonry Unit Concrete Masonry Unit Textured Concrete Textured Concrete Textured Concrete Plaster (adjacent to caulk) (adjacent to Sample 54) (12" from caulk) (6" from caulk) (adjacent to caulk) (12" from caulk) Interior, Fine Arts, South Entrance Exterior, Fine Arts, South Entrance Interior, Fine Arts, South Entrance Interior, Fine Arts, South Entrance Interior, Fine Arts, South Entrance Interior, Room E115, Fine Arts - 29, 114, 202A, 202B, 202C 60, , 85 26, 81, 86 27, 82, 87, 87B 11K B K K K K /8/2011 2/24/ /8/ /8/ /8/ /8/2011 EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) ND(5.0) ND(0.10) ND(10) ND(10) ND(2.0) ND(0.091) ND(5.0) ND(0.10) ND(10) ND(10) ND(2.0) ND(0.091) ND(5.0) ND(0.10) ND(10) ND(10) ND(2.0) ND(0.091) ND(5.0) 0.34 ND(10) ND(10) ND(2.0) ND(0.091) 26 ND(0.10) ND(0.091) ND(5.0) 0.13 ND(10) ND(10) ND(2.0) 0.46 ND(5.0) ND(0.10) ND(10) ND(10) ND(2.0) ND(0.091) ND(5.0) ND(0.10) ND(10) ND(10) ND(2.0) ND(0.091) ND(5.0) ND(0.10) ND(10) ND(10) ND(2.0) ND(0.091) Demo Debris Demo Debris PCB Remediation Waste PCB Remediation Waste PCB Remediation Waste Demo Debris Surrogates Compound DCBP (1) DCBP (2) TCMX (1) TCMX (2) % Recovery % Recovery % Recovery % Recovery % Recovery % Recovery * (30-150) 131 (30-150) * (30-150) * (30-150) 131 (30-150) 99.9 (30-150) * (30-150) 122 (30-150) * (30-150) * (30-150) **151 (30-150) 106 (30-150) * (30-150) 116 (30-150) * (30-150) * (30-150) 118 (30-150) 90.3 (30-150) * (30-150) 122 (30-150) * (30-150) * (30-150) 115 (30-150) 88.4 (30-150) Notes: All solid/bulk sample concentrations in milligrams per kilogram (mg/kg)(ppm). Surface wipe sample concentrations are in micrograms per 100 cm2 (µg/100cm2) ND (1.0) = Not Detected above associated laboratory method detection limit Bold = Compound detected PCB Bulk Product = Sealants with PCB concentrations 50 ppm. Designation may be made based upon result from similar material(s) PCB Remediation Waste = Materials with PCB concentrations 1ppm which have been impacted by PCB Bulk Product Waste. Designation may be made based upon result from similar material(s) Excluded PCB Product = Sealants with PCB concentrations < 50 ppm and not impacted by a PCB Bulk Product Demo Debris = Manage as general demolition debris with < 1 ppm PCBs * = The surrogate recovery for this sample is not available due to sample dilution below the surrogate reporting limit required from high analyte concentration and/or matrix interferences ** = This surrogate recovery is outside the surrogate reporting limit ATC Associates Inc. 3/25/12 18 of 23 High School - Table 1 - PCB Analytical Data Summary_ Grouped by Series

47 Table 1 Building Material PCB Survey Brockton High School 470 Forest Avenue Brockton, Massachusetts draft Sample ID Material Location Characteristics Similar Samples Sample No. Date Collected Prep Method Analytical Method Compound Aroclor 1016 Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 Aroclor 1262 Aroclor 1268 Total PCBs Associated Source PCB Bulk Product Waste Determination (Management) 103 [E115-I-PLS-6] 104 [E115-I-PLS-0] 105 [E115-I-WGB-6] 106 [E115-I-WGB-0] 107 [E115-I-WSL-6] 111 [C16-I-CLK] 112 [C16-I-CMU-12] Plaster Plaster Wipe - Glazed Brick Wipe - Glazed Brick Wipe - Sill Plate Caulk Concrete Masonry Unit (6" from caulk) (0" from caulk) (6" from Sample 101) (0" from Sample 101) (6" from Sample 101) (between metal/masonry) (12" from Sample 111) Interior, Room E115, Fine Arts Interior, Room E115, Fine Arts Interior, Room E115, Fine Arts Interior, Room E115, Fine Arts Interior, Room E115, Fine Arts Interior, Room C16, Administration Interior, Room C16, Administration Light Gray/Smooth/Soft/Dry/Rubbery , 8, 10, 24, 80, 84, 84B, 84C, 84D 93 11K K K K K K K /8/ /8/ /8/ /8/ /8/ /11/ /11/2011 EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 Concentration (mg/kg) Concentration (mg/kg) Concentration (µg/100 cm2) Concentration (µg/100 cm2) Concentration (µg/100 cm2) Concentration (mg/kg) Concentration (mg/kg) ND(0.10) ND(0.10) ND(0.20) ND(0.20) ND(0.20) ND(0.87) ND(0.091) ND(0.10) ND(0.10) ND(0.20) ND(0.20) ND(0.20) ND(0.87) ND(0.091) ND(0.10) ND(0.10) ND(0.20) ND(0.20) ND(0.20) ND(0.87) ND(0.091) ND(0.10) ND(0.10) ND(0.20) ND(0.20) ND(0.20) ND(0.87) ND(0.091) ND(0.10) ND(0.10) ND(0.20) ND(0.20) ND(0.20) 4.6 ND(0.091) ND(0.20) ND(0.20) ND(0.10) ND(0.10) ND(0.20) ND(0.20) ND(0.20) ND(0.87) ND(0.091) ND(0.10) ND(0.10) ND(0.20) ND(0.20) ND(0.20) ND(0.87) ND(0.091) ND(0.10) ND(0.10) ND(0.20) ND(0.20) ND(0.20) ND(0.87) ND(0.091) ND(0.20) ND(0.20) Demo Debris Demo Debris Demo Debris Demo Debris Demo Debris PCB Remediation Waste > 50 ppm Demo Debris Surrogates Compound DCBP (1) DCBP (2) TCMX (1) TCMX (2) % Recovery % Recovery % Recovery % Recovery % Recovery % Recovery % Recovery 94.5 (30-150) 96.2 (30-150) 79.3 (30-150) 74.1 (30-150) 74.1 (30-150) 91.1 (30-150) 68.5 (30-150) 103 (30-150) 105 (30-150) 87.2 (30-150) 80.1 (30-150) 80.1 (30-150) 63.2 (30-150) 81.6 (30-150) 82.5 (30-150) 81.1 (30-150) 99.4 (30-150) 107 (30-150) 101 (30-150) 86.8 (30-150) 89.7 (30-150) 76.1 (30-150) 86.6 (30-150) 106 (30-150) 103 (30-150) 97.2 (30-150) 82.8 (30-150) 86.7 (30-150) Notes: All solid/bulk sample concentrations in milligrams per kilogram (mg/kg)(ppm). Surface wipe sample concentrations are in micrograms per 100 cm2 (µg/100cm2) ND (1.0) = Not Detected above associated laboratory method detection limit Bold = Compound detected PCB Bulk Product = Sealants with PCB concentrations 50 ppm. Designation may be made based upon result from similar material(s) PCB Remediation Waste = Materials with PCB concentrations 1ppm which have been impacted by PCB Bulk Product Waste. Designation may be made based upon result from similar material(s) Excluded PCB Product = Sealants with PCB concentrations < 50 ppm and not impacted by a PCB Bulk Product Demo Debris = Manage as general demolition debris with < 1 ppm PCBs * = The surrogate recovery for this sample is not available due to sample dilution below the surrogate reporting limit required from high analyte concentration and/or matrix interferences ** = This surrogate recovery is outside the surrogate reporting limit ATC Associates Inc. 3/25/12 19 of 23 High School - Table 1 - PCB Analytical Data Summary_ Grouped by Series

48 Table 1 Building Material PCB Survey Brockton High School 470 Forest Avenue Brockton, Massachusetts draft Sample ID Material Location Characteristics Similar Samples Sample No. Date Collected Prep Method Analytical Method Compound Aroclor 1016 Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 Aroclor 1262 Aroclor 1268 Total PCBs Associated Source PCB Bulk Product Waste Determination (Management) 113 [C16-I-CMU-6] 114 [C16-I-CMU-0] 115 [C16-I-WMT] 116 [C16-E-GLZ] 117 [C16-E-CLK] 118 [C16-E-CMU-12] 119 [C16-E-CMU-6] Concrete Masonry Unit (6" from Sample 111) Concrete Masonry Unit (0" from Sample 111) Wipe - Metal (between Samples 110 and 111) Glazing (between metal/glass) Caulk (between metal/masonry) Concrete Masonry Unit (12" from Sample 117) Concrete Masonry Unit (6" from Sample 117) Interior, Room C16, Administration Interior, Room C16, Administration Interior, Room C16, Administration Exterior, Room C16, Administration Exterior, Room C16, Administration Exterior, Room C16, Exterior, Room C16, Administration Administration Gray/Gritty/Semi-Hard/Dry/Brittle Light Gray/Smooth/Soft/Dry/Rubbery 28, 94 29, 95, 202A, 202B, 202C 31, 88 1, 13, 14, 43 2, 10B, 12, 16, 17, 35, 35B, 35C, 44, 54, 62, K K K K K K K /11/ /11/ /11/ /11/ /11/ /11/ /11/2011 EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 Concentration (mg/kg) Concentration (mg/kg) Concentration (µg/100 cm2) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) ND(0.10) ND(0.10) ND(0.20) ND(170) ND(0.95) ND(0.10) ND(0.095) ND(0.10) ND(0.10) ND(0.20) ND(170) ND(0.95) ND(0.10) ND(0.095) ND(0.10) ND(0.10) ND(0.20) ND(170) ND(0.95) ND(0.10) ND(0.095) ND(0.10) ND(0.10) ND(0.20) ND(170) ND(0.95) ND(0.10) ND(0.095) ND(0.10) ND(0.10) ND(0.20) ND(170) 3.1 ND(0.10) ND(0.095) ND(0.10) ND(0.10) ND(0.10) ND(0.095) ND(0.10) ND(0.10) ND(0.20) ND(170) ND(0.95) ND(0.10) ND(0.095) ND(0.10) ND(0.10) ND(0.20) ND(170) ND(0.95) ND(0.10) ND(0.095) ND(0.10) ND(0.10) ND(0.20) ND(170) ND(0.95) ND(0.10) ND(0.095) ND(0.10) ND(0.10) ,000 6 ND(0.10) ND(0.095) Demo Debris Demo Debris PCB Remediation Waste PCB Bulk Product PCB Remediation Waste > 50 ppm Demo Debris Demo Debris Surrogates Compound DCBP (1) DCBP (2) TCMX (1) TCMX (2) % Recovery % Recovery % Recovery % Recovery % Recovery % Recovery % Recovery 71.0 (30-150) 68.7 (30-150) 96.3 (30-150) * (30-150) 92.8 (30-150) 68.7 (30-150) 72.7 (30-150) 86.1 (30-150) 82.5 (30-150) 107 (30-150) * (30-150) 66.3 (30-150) 83.3 (30-150) 87.4 (30-150) 90.9 (30-150) 85.7 (30-150) 76.5 (30-150) * (30-150) 103 (30-150) 91.9 (30-150) 91.5 (30-150) 87.8 (30-150) 83.0 (30-150) 93.7 (30-150) * (30-150) 96.5 (30-150) 88.6 (30-150) 88.7 (30-150) Notes: All solid/bulk sample concentrations in milligrams per kilogram (mg/kg)(ppm). Surface wipe sample concentrations are in micrograms per 100 cm2 (µg/100cm2) ND (1.0) = Not Detected above associated laboratory method detection limit Bold = Compound detected PCB Bulk Product = Sealants with PCB concentrations 50 ppm. Designation may be made based upon result from similar material(s) PCB Remediation Waste = Materials with PCB concentrations 1ppm which have been impacted by PCB Bulk Product Waste. Designation may be made based upon result from similar material(s) Excluded PCB Product = Sealants with PCB concentrations < 50 ppm and not impacted by a PCB Bulk Product Demo Debris = Manage as general demolition debris with < 1 ppm PCBs * = The surrogate recovery for this sample is not available due to sample dilution below the surrogate reporting limit required from high analyte concentration and/or matrix interferences ** = This surrogate recovery is outside the surrogate reporting limit ATC Associates Inc. 3/25/12 20 of 23 High School - Table 1 - PCB Analytical Data Summary_ Grouped by Series

49 Table 1 Building Material PCB Survey Brockton High School 470 Forest Avenue Brockton, Massachusetts draft Sample ID Material Location Characteristics Similar Samples Sample No. Date Collected Prep Method Analytical Method Compound Aroclor 1016 Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 Aroclor 1262 Aroclor 1268 Total PCBs Associated Source PCB Bulk Product Waste Determination (Management) 120 [C16-E-CMU-0] 121 [C16-E-CON-12] 122 [C16-E-CON-6] 123 [C16-E-CON-0] 124 [C16-E-WRK-12] 125 [C16-E-WRK-0] Concrete Masonry Unit (0" from Sample 117) Smooth Concrete (12" from Sample 117) Smooth Concrete (6" from Sample 117) Smooth Concrete (0" from Sample 117) Wipe - Rock (12" from Sample 117) Wipe - Rock (0" from Sample 117) Exterior, Room C16, Administration Exterior, Room C16, Administration Exterior, Room C16, Administration Exterior, Room C16, Administration Exterior, Room C16, Administration Exterior, Room C16, Administration 60, 95B 122, , , K K K K K K /11/ /11/ /11/ /11/ /11/ /11/2011 EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (µg/100 cm2) Concentration (µg/100 cm2) ND(0.091) ND(0.095) ND(0.091) ND(0.10) ND(0.20) ND(0.20) ND(0.091) ND(0.095) ND(0.091) ND(0.10) ND(0.20) ND(0.20) ND(0.091) ND(0.095) ND(0.091) ND(0.10) ND(0.20) ND(0.20) ND(0.091) ND(0.095) ND(0.091) ND(0.10) ND(0.20) ND(0.20) ND(0.091) ND(0.095) ND(0.091) ND(0.10) ND(0.20) ND(0.20) ND(0.091) ND(0.095) ND(0.091) ND(0.10) ND(0.20) ND(0.20) ND(0.091) ND(0.095) ND(0.091) ND(0.10) ND(0.20) ND(0.20) ND(0.091) ND(0.095) ND(0.091) ND(0.10) ND(0.20) ND(0.20) ND(0.091) ND(0.095) ND(0.091) ND(0.10) ND(0.20) ND(0.20) ND(0.091) ND(0.095) ND(0.091) ND(0.10) ND(0.20) ND(0.20) Demo Debris PCB Remediation Waste PCB Remediation Waste PCB Remediation Waste Demo Debris Demo Debris Surrogates Compound DCBP (1) DCBP (2) TCMX (1) TCMX (2) % Recovery % Recovery % Recovery % Recovery % Recovery % Recovery 78.8 (30-150) 77.4 (30-150) 63.8 (30-150) 68.6 (30-150) 99.1 (30-150) 101 (30-150) 98.4 (30-150) 93.0 (30-150) 76.3 (30-150) 82.6 (30-150) 103 (30-150) 105 (30-150) 92.6 (30-150) 97.8 (30-150) 92.2 (30-150) 93.2 (30-150) 79.6 (30-150) 79.7 (30-150) 89.5 (30-150) 92.6 (30-150) 87.6 (30-150) 88.8 (30-150) 94.1 (30-150) 94.7 (30-150) Notes: All solid/bulk sample concentrations in milligrams per kilogram (mg/kg)(ppm). Surface wipe sample concentrations are in micrograms per 100 cm2 (µg/100cm2) ND (1.0) = Not Detected above associated laboratory method detection limit Bold = Compound detected PCB Bulk Product = Sealants with PCB concentrations 50 ppm. Designation may be made based upon result from similar material(s) PCB Remediation Waste = Materials with PCB concentrations 1ppm which have been impacted by PCB Bulk Product Waste. Designation may be made based upon result from similar material(s) Excluded PCB Product = Sealants with PCB concentrations < 50 ppm and not impacted by a PCB Bulk Product Demo Debris = Manage as general demolition debris with < 1 ppm PCBs * = The surrogate recovery for this sample is not available due to sample dilution below the surrogate reporting limit required from high analyte concentration and/or matrix interferences ** = This surrogate recovery is outside the surrogate reporting limit ATC Associates Inc. 3/25/12 21 of 23 High School - Table 1 - PCB Analytical Data Summary_ Grouped by Series

50 Table 1 Building Material PCB Survey Brockton High School 470 Forest Avenue Brockton, Massachusetts draft Sample ID Material Location Characteristics Similar Samples Sample No. Date Collected Prep Method Analytical Method Compound Aroclor 1016 Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 Aroclor 1262 Aroclor 1268 Total PCBs Associated Source PCB Bulk Product Waste Determination (Management) 126 [C16-E-WMT] 127 [E115-I-MOR-6] 128 [E115-I-MOR-0] 129 [E115-E-MOR-6] 130 [E115-E-MOR-0] 131 [R117-E-MOR-6] 132 [R117-E-MOR-0] Wipe - Metal Glazed Brick Mortar Glazed Brick Mortar Glazed Brick Mortar Glazed Brick Mortar Glazed Brick Mortar Glazed Brick Mortar (between Samples 116 and 117) (6" from Sample 101) (0" from Sample 101) (6" from Sample 62) (0" from Sample 62) (6" from Sample 44) (0" from Sample 44) Exterior, Room C16, Administration Interior, Room E115, Fine Arts Interior, Room E115, Fine Arts Exterior, Room E115, Fine Arts Exterior, Room E115, Fine Arts Exterior, Room R117, Red Exterior, Room R117, Red 39, 51, 69, 78 11K K K K K K K /11/ /11/ /11/ /11/ /11/ /11/ /11/2011 EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 Concentration (µg/100 cm2) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) ND(0.40) ND(0.10) ND(0.10) ND(0.095) ND(0.091) ND(0.095) ND(0.091) ND(0.40) ND(0.10) ND(0.10) ND(0.095) ND(0.091) ND(0.095) ND(0.091) ND(0.40) ND(0.10) ND(0.10) ND(0.095) ND(0.091) ND(0.095) ND(0.091) ND(0.40) ND(0.10) ND(0.10) ND(0.095) ND(0.091) ND(0.095) ND(0.091) ND(0.40) ND(0.10) ND(0.10) ND(0.095) ND(0.091) ND(0.095) ND(0.091) 2.5 ND(0.10) ND(0.10) ND(0.095) ND(0.091) ND(0.095) ND(0.091) ND(0.40) ND(0.10) ND(0.10) ND(0.095) ND(0.091) ND(0.095) ND(0.091) ND(0.40) ND(0.10) ND(0.10) ND(0.095) ND(0.091) ND(0.095) ND(0.091) ND(0.40) ND(0.10) ND(0.10) ND(0.095) ND(0.091) ND(0.095) ND(0.091) 2.5 ND(0.10) ND(0.10) ND(0.095) ND(0.091) ND(0.095) ND(0.091) PCB Remediation Waste > 50 ppm Demo Debris Demo Debris Demo Debris Demo Debris Demo Debris Demo Debris Surrogates Compound DCBP (1) DCBP (2) TCMX (1) TCMX (2) % Recovery % Recovery % Recovery % Recovery % Recovery % Recovery % Recovery 86.2 (30-150) 72.6 (30-150) 71.2 (30-150) 70.8 (30-150) 74.0 (30-150) 71.8 (30-150) 78.5 (30-150) 95.2 (30-150) 86.8 (30-150) 86.1 (30-150) 85.6 (30-150) 89.5 (30-150) 86.8 (30-150) 94.9 (30-150) 101 (30-150) 95.5 (30-150) 83.5 (30-150) 94.0 (30-150) 94.5 (30-150) 90.4 (30-150) 90.1 (30-150) 98.3 (30-150) 91.1 (30-150) 79.9 (30-150) 90.0 (30-150) 90.6 (30-150) 87.0 (30-150) 86.6 (30-150) Notes: All solid/bulk sample concentrations in milligrams per kilogram (mg/kg)(ppm). Surface wipe sample concentrations are in micrograms per 100 cm2 (µg/100cm2) ND (1.0) = Not Detected above associated laboratory method detection limit Bold = Compound detected PCB Bulk Product = Sealants with PCB concentrations 50 ppm. Designation may be made based upon result from similar material(s) PCB Remediation Waste = Materials with PCB concentrations 1ppm which have been impacted by PCB Bulk Product Waste. Designation may be made based upon result from similar material(s) Excluded PCB Product = Sealants with PCB concentrations < 50 ppm and not impacted by a PCB Bulk Product Demo Debris = Manage as general demolition debris with < 1 ppm PCBs * = The surrogate recovery for this sample is not available due to sample dilution below the surrogate reporting limit required from high analyte concentration and/or matrix interferences ** = This surrogate recovery is outside the surrogate reporting limit ATC Associates Inc. 3/25/12 22 of 23 High School - Table 1 - PCB Analytical Data Summary_ Grouped by Series

51 Table 1 Building Material PCB Survey Brockton High School 470 Forest Avenue Brockton, Massachusetts draft Sample ID Material Location Characteristics Similar Samples Sample No. Date Collected Prep Method Analytical Method Compound Aroclor 1016 Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 Aroclor 1262 Aroclor 1268 Total PCBs Associated Source PCB Bulk Product Waste Determination (Management) A 202B 202C 203 Caulk (between metal/masonry) Glazing (between metal/glass) Concrete Masonry Unit (adjacent to window caulk) Concrete Masonry Unit (adjacent to window caulk) Concrete Masonry Unit (adjacent to window caulk) Textured Concrete (0" from Sample 10B) Exterior, Elev. 12, 2nd Floor, North, Gym Exterior, Elev. 12, 2nd Floor, North, Gym Interior, Elev. 3, 1st Floor, Academic Buildingmiddle/north Building-middle/south Building-north East Interior, Elev. 3, 1st Floor, Academic Interior, Elev. 3, 2nd Floor, Academic Exterior, 2nd Floor, Elevation 13, Gym, Side Black/Smooth/Soft/Sticky/Rubbery Black/Smooth/Soft/Sticky/Rubbery , , 95, 114, 202B, 202C 29, 95, 114, 202A, 202C 29, 95, 114, 202A, 202B 42, 42B, 47, 57, 65, 74, B B B B B B /24/2012 2/24/2012 2/24/2012 2/24/2012 2/24/2012 2/24/2012 EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 3540C EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 EPA 8082 Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) Concentration (mg/kg) ND(0.93) ND(9.2) ND(0.095) ND(0.10) ND(0.10) ND(0.095) ND(0.93) ND(9.2) ND(0.095) ND(0.10) ND(0.10) ND(0.095) ND(0.93) ND(9.2) ND(0.095) ND(0.10) ND(0.10) ND(0.095) ND(0.93) ND(9.2) ND(0.095) ND(0.10) ND(0.10) ND(0.095) ND(0.93) ND(9.2) ND(0.095) ND(0.10) ND(0.10) ND(0.095) ND(0.095) ND(0.93) ND(9.2) ND(0.095) ND(0.10) ND(0.10) ND(0.095) ND(0.93) ND(9.2) ND(0.095) ND(0.10) ND(0.10) ND(0.095) ND(0.93) ND(9.2) ND(0.095) ND(0.10) ND(0.10) ND(0.095) ND(0.095) B PCB Remediation Waste PCB Bulk Product Demo Debris Demo Debris Demo Debris PCB Remediation Waste Surrogates Compound DCBP (1) DCBP (2) TCMX (1) TCMX (2) % Recovery % Recovery % Recovery % Recovery % Recovery % Recovery 114 (30-150) * (30-150) 131 (30-150) 143 (30-150) 143 (30-150) 109 (30-150) 106 (30-150) * (30-150) 122 (30-150) 131 (30-150) 131 (30-150) 104 (30-150) 97.1 (30-150) * (30-150) 116 (30-150) 119 (30-150) 119 (30-150) 102 (30-150) 100 (30-150) * (30-150) 122 (30-150) 126 (30-150) 126 (30-150) 105 (30-150) Notes: All solid/bulk sample concentrations in milligrams per kilogram (mg/kg)(ppm). Surface wipe sample concentrations are in micrograms per 100 cm2 (µg/100cm2) ND (1.0) = Not Detected above associated laboratory method detection limit Bold = Compound detected PCB Bulk Product = Sealants with PCB concentrations 50 ppm. Designation may be made based upon result from similar material(s) PCB Remediation Waste = Materials with PCB concentrations 1ppm which have been impacted by PCB Bulk Product Waste. Designation may be made based upon result from similar material(s) Excluded PCB Product = Sealants with PCB concentrations < 50 ppm and not impacted by a PCB Bulk Product Demo Debris = Manage as general demolition debris with < 1 ppm PCBs * = The surrogate recovery for this sample is not available due to sample dilution below the surrogate reporting limit required from high analyte concentration and/or matrix interferences ** = This surrogate recovery is outside the surrogate reporting limit ATC Associates Inc. 3/25/12 23 of 23 High School - Table 1 - PCB Analytical Data Summary_ Grouped by Series

52 Request for Approval of TSCA Risk-Based Clean-up of PCBs Brockton High School Brockton, Massachusetts April 9, 2012 Appendix A Photographs ATC ASSOCIATES INC.

53 Request for Approval of TSCA Risk-Based Clean-up of PCBs Brockton High School 470 Forest Avenue Brockton, Massachusetts Sample ) PCBs = 0.89 ppm Sample 53 (Exterior Glazing) PCBs = 340 ppm Sample 59 6 ) PCBs = 0.21 ppm Sample 60 0 ) PCBs = 0.68 ppm Encapsulate wall (typical) Sample 57 (Textured 0 ) PCBs = 22 ppm Sample 56 (Textured 6 ) PCBs = 23 ppm Sample 54 (Exterior Caulking) PCBs = 14 ppm Sample 55 (Textured 12 ) PCBs = 14 ppm Photograph 1: View of Fine Arts Building entrance, Elevation 17, showing sample locations. Encapsulate wall (typical) Sampling area presented in Photo 1. Encapsulate textured concrete columns (typical) Photograph 2: Looking northwest at Fine Arts Building entrance, Elevation 17. Project No

54 Request for Approval of TSCA Risk-Based Clean-up of PCBs Brockton High School 470 Forest Avenue Brockton, Massachusetts Sample ) PCBs = ND (0.091) Sample 116 (Glazing) PCBs = 3,000 ppm Sample 117 (Caulking) PCBs = 6 ppm Sample ) PCBs = ND (0.095) Sample 126 (Wipe Metal Frame) PCBs = 2.5 µg/100 cm 2 Samples 124 & 125 (Wipe 0 & 12 ) PCBs = ND (0.20 µg/100 cm 2 ) Sample 123 (Concrete 0 ) PCBs = ND (0.10) Sample 122 (Concrete 6 ) PCBs = ND (0.091) Sample ) PCBs = ND (0.10) Sample 121 (Concrete 12 ) PCBs = ND (0.095) Photograph 3: View of Administration Office, Room C16, Elevation 1, showing sample locations. Sampling area presented in Photo 3. Photograph 4: Looking southwest at Administration Office, Room C16, Elevation 1. Project No

55 Request for Approval of TSCA Risk-Based Clean-up of PCBs Brockton High School 470 Forest Avenue Brockton, Massachusetts Sample 47 (Textured 0 ) PCBs = 32 ppm Sample 43 (Exterior Glazing) PCBs = 840 ppm Sample 45 (Textured 12 ) PCBs = 44 ppm Sample 46 (Textured 6 ) PCBs = 22 ppm Sample 44 (Exterior Caulking) PCBs = 13 ppm Sample ) PCBs = ND (0.091) ppm Sample 48 (Wipe Glazed 0 & 6 ) PCBs = ND (0.20 µg/100 cm 2 ) Sample ) PCBs = ND (0.095) ppm Sample 51 (Wipe Metal 0 ) PCBs = 0.44 µg/100 cm 2 ) Sample 50 (Wipe Glass 0 ) PCBs = ND (0.20 µg/100 cm 2 ) Photograph 5: View of Academic Building, Room R117, Elevation 1, showing sample locations. Encapsulate textured concrete column (typical) Sampling area presented in Photo 5. Encapsulate textured concrete sill (typical) Photograph 6: Looking west at Academic Building, Room R117, Elevation 1. Project No

56 Request for Approval of TSCA Risk-Based Clean-up of PCBs Brockton High School 470 Forest Avenue Brockton, Massachusetts Encapsulate interior textured concrete surround (typical) Encapsulate exterior textured concrete surround (typical) Photograph 7: View of typical textured concrete surround, view from interior. Encapsulate exterior CMU surround (typical) Encapsulate interior CMU surround (typical) Encapsulate exterior textured concrete surround (typical) Encapsulate interior textured concrete surround (typical) Photograph 8: View of typical textured concrete and CMU surround, view from interior. Project No

57 Request for Approval of TSCA Risk-Based Clean-up of PCBs Brockton High School Brockton, Massachusetts April 9, 2012 Appendix B Laboratory Analytical Reports (Included with electronic copy only) ATC ASSOCIATES INC.

58 Appendix C Technical Specification Section Selective Demolition Section Asbestos Abatement Section Lead-Containing Paint Considerations Section Removal and Disposal of PCBs Section Painting

59 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA SECTION SELECTIVE DEMOLITION PART 1-GENERAL 1.01 GENERAL REQUIREMENTS 1.02 SCOPE OF WORK 1.03 SUBMITTALS 1.04 PROJECT CONDITIONS

60 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA 1.05 PERMITS, TAXES AND LICENSES PART 2-MATERIALS 2.01 MATERIALS PART 3 EXECUTION END OF SELECTIVE DEMOLITION

61 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA SECTION ASBESTOS ABATEMENT PART 1 - GENERAL 1.01 GENERAL REQUIREMENTS A. The General Provisions of the contract, including General and Supplementary Conditions and applicable provisions of Division 1 - General Requirements, apply to the work specified within this Section. B. Examine all conditions as they exist at the project prior to submitting a bid for the work of this Section. C. All provisions of this Section relating to the health and safety of workers and the general public, as well as protection of the environment are minimum standards. The General Contractor and the Asbestos Abatement Subcontractor are responsible for determining whether any additional and/or more stringent protective measures are required by any legal requirements or prudent conservative work practices, and implementing such measures if deemed necessary. Nothing in this Section shall be deemed to relieve the General Contractor and the Asbestos Abatement Subcontractor from any liability with respect to any such legal requirements or requirement of prudent conservative practice. D. All work-site preparations and practices will be conducted in accordance with all Federal, Massachusetts and appropriate City and other local regulations, standards and codes pertaining to worker health protection, protection of the public health and the environment, including current US Environmental Protection Agency (EPA), Department of Labor Occupational Safety and Health Administration (OSHA), US Department of Transportation (DOT), Massachusetts Department of Labor Standards (DLS), Massachusetts Department of Environmental Protection (DEP), local and all other Federal, Commonwealth of Massachusetts and local regulations pertaining to asbestos removal, its transportation and disposal. E. The Consultant will render certain technical services during the Work, including without limitation, the services described at 453 CMR (5) and described within this Section. All services performed by such Representative shall be considered advisory to, and for the sole and exclusive benefit of the Owner. The Asbestos Abatement Subcontractor acknowledges that the Consultant is an independent contractor of the Owner and agrees that no act or omission by such Consultant, and no communication by said "Consultant", shall be deemed in any manner to alter or modify the terms of this Contract, or to waive any provision hereof, or to bind Owner, unless specifically agreed upon by Owner in a signed written instrument. ASBESTOS ABATEMENT

62 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA F. Prior to use of any design, device, material, method of operation, or process covered by letters patent or copyright, the right for such use shall be secured by suitable legal agreement with the patentee or owner of the letters patent or copyright. No arrangement involving letters patent or copyright is acceptable, if subsequent payment for permanent use following completion of the work is required or implied. The contractor shall be responsible for any liability on the part of the Consultant, which may result from violations by the contractor. G. The Owner has retained ATC Associates Inc. as the Environmental Consultant for the purpose of project management during asbestos abatement activities. H. For the purpose of this Section, "Consultant" shall refer to ATC Associates Inc., who will act as designated, authorized representatives of the Owner for the purpose of inspecting, monitoring, and testing SUMMARY OF WORK The following is the Scope of Work, at a minimum, required to be performed associated with the window replacement project at the City of Brockton High School and Downey Elementary School in Brockton, Massachusetts under the Base Bid and Alternate Bid. All Asbestos Abatement work under this Section shall be performed by a contractor holding a current Massachusetts Department of Labor Standards (DLS) Asbestos Abatement Contractor s license. Contractor shall furnish all labor, worker training, materials, equipment, and services for the complete and proper removal and disposal of asbestos-containing materials. 1. Removal and disposal of all specified asbestos-containing materials (ACM) and specified non-acm materials as identified herein. This shall include all asbestos-containing window caulking, window glazing and specified non-acm window components where necessary to access asbestos. All work performed shall be as required by Sections 3.03, 3.04, and Work area preparations, including pre-cleaning, installation of critical barriers and polyethylene sheeting, construction of remote decontamination facilities, work area preparation, sealing, isolation, and other activities as directed by the Owner or Consultant. 3. Protection on non-acm materials and stationary equipment inside of work areas with two layers of polyethylene sheeting. 4. Furnishing of all labor, materials, equipment, and services required for all work included under the provisions of this Section. 5. Compliance with all applicable federal, state, and local regulations, as well as all provisions set forth within this Section, and facility requirements. ASBESTOS ABATEMENT

63 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA 6. Clean up following removal activities in each designated work area. 7. Performance of any other work or activities required by this Section, applicable regulations, or as necessary to perform a complete job to the satisfaction of the Owner and Consultant. 8. Provide temporary electrical wiring and services as required for asbestos removal according to the Provisions as set forth in this Section. 9. Contractor is responsible for safely accessing and removing asbestos, and also providing any additional equipment necessary (fall protection equipment) to perform abatement from the buildings. General Contractor will provide scaffolding equipment necessary to access asbestos-containing materials included in the project scope of work. 10. Removal and disposal of asbestos-containing materials, and specified non- ACM materials, that may be uncovered during demolition/renovation and are not included in the base bid scope of work. This work will be performed as unit price work. 11. Coordination of all work with the General Contractor, including scheduling and sequencing/phasing of removal work, temporary protection at window and door openings, etc., to the Owner s satisfaction. A. The following is a summary of the work items to be performed under the Contract. Given quantities are estimates only and are not guaranteed. Bidders shall not use these estimates as the only basis for their Bid. Bidders shall confirm all quantities and items during the Pre-Bid walkthrough to the extent reasonably possible. The Bidders are responsible to review and confirm all quantities and field conditions (including structural integrity of walking/working surfaces), including locations of all ACM and debris, surface area, lengths, widths, cross-sections, thickness, composition of layers, substrate composition and any attachments thereto, including glue, mastic, compounds, prior to the submission of bids. Neither the Consultant nor the Owner will be responsible for errors or omissions and/or charges for extra work arising from any bidders failure to become familiar with the existing conditions of the site, requirements of the work and the results to be produced. By submitting a Bid, the Bidder further agrees that the descriptions contained herein and on the drawings (i.e., quantities, descriptions, locations, areas, thicknesses, etc.) are adequate and that the bidder will produce the required results. No claims for extra payment due to incorrect quantities will be considered. By submitting a Bid, a Bidder agrees and warrants that he is familiar with and will perform all the work required, including all items indicated herein and/or on the Drawings. The estimates of asbestos containing materials to be removed are in the following table. ASBESTOS ABATEMENT

64 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA Summary of Identified Asbestos-Containing Materials to be Removed City of Brockton High School Brockton, Massachusetts Material Location(s) Estimated Quantity Window Glazing Fine Arts, Main All Windows and Compound Building and Gym Doors 35,000 sf Condition Result Good <1-10% Chrysotile * See Project Drawings Including Alternate Drawings Summary of Identified Asbestos-Containing Materials to be Removed City of Brockton Downey School Brockton, Massachusetts Material Location(s) Estimated Quantity Window & Door All Windows and Glazing Entire Building Doors 13,117 sf Compound plus 24 Doors Window & Door Caulking Material Entire Building All Windows and Doors 13,117 sf plus 24 Doors * See Project Drawings Including Alternate Drawings Condition Good Good Result 2-15% Chrysotile <1-5% Chrysotile 1.03 SEQUENCE OF WORK The following is a typical sequence of work that Contractor shall adhere to during the asbestos abatement project. Consultant may authorize deviations from this typical sequence based upon the specific conditions encountered during the project. 1. Contractor shall post all required signage. 2. Contractor shall secure area from unauthorized access. 3. Owner/Contractor will remove all movable objects from the work area. 4. Contractor shall prepare the specified Work Area for glazing material and caulking material removal as described in this Specification. ASBESTOS ABATEMENT

65 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA 5. Contractor shall construct remote decontamination unit, and any other construction needed to complete the work area to the satisfaction of Consultant. 6. Consultant shall inspect and approve all work area preparations before permitting Contractor to begin removal work. 7. Contractor shall remove and dispose all asbestos-containing materials as required by this Section. 8. Consultant shall perform a final visual inspection to assure that no visible debris exists in the work area. Contractor shall re-clean the work areas as needed until they pass a visual inspection by Consultant. 9. Contractor shall remove all work area barriers, equipment, polyethylene sheeting, etc. and clean any areas to the satisfaction of Consultant and Owner COORDINATION AND PHASING OF WORK A. Contractor shall coordinate all work in this Section with all other work of this Project. Where additional regulatory requirements apply to the work in this Section, the Contractor shall ensure compliance with all requirements. B. Contractors work schedule must be coordinated with and acceptable to the General Contractor and approved by the Owner. Contractor shall work continuously and diligently in each work area on the days and during the hours indicated on their work schedule C. Contractor shall cooperate fully with other Contractors at the facility. D. Contractor shall subdivide work areas and/or otherwise provide additional containments and mobilization where and when necessary to accomplish asbestos abatement in accordance with the project phasing, as determined by the General Contractor, and as specified by the Owner SUBMITTALS A. Pre-Construction Meeting The Contractor shall meet with the Owner and the Consultant for a Pre-Construction meeting prior to commencing work on the project. The meeting shall be at the facility or at the offices of the Owner, at a mutually convenient time and date. At the meeting, the Contractor shall be represented by authorized representatives and the field supervisor who shall run the project on a daily basis, and who shall present ASBESTOS ABATEMENT

66 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA evidence that all requirements for initiation of the work have been met. minimum agenda for the meeting shall be: The 1. Review of "Pre-Job Submittals". 2. Channels of communication. 3. Construction schedule, including sequence of critical work. 4. Designation of responsible personnel. 5. Procedures for safety, security, quality control, housekeeping, and related matters. 6. Use of premises, facilities, and utilities. B. PRE-JOB SUBMITTALS The Contractor is required to provide one copy of the following Pre-Job Submittals at the Pre-construction Conference: 1. Copies of all notifications, permits, applications, abatement contractor license, personnel licenses and like documents required by Federal, State, or local regulations obtained or submitted in proper fashion, 2. List of employees to be used on this project. 2. Copies of medical records as required by OSHA or a notarized statement by examining medical doctor that such examinations took place and when for each employee to be used on project, 4. Record of successful respiratory fit test performed by a Competent person (as defined by OSHA) within the previous 6 months, as required elsewhere in the documents for each employee to be used on this project, 5. Certificate of Insurance, 6. Proposed respiratory program for employees throughout all phases of the job, including make, model and NIOSH approval numbers of respirators to be used, 7. Written description of all procedures, methods, or equipment to be utilized by the Contractor that differ from the Contract Sections, including manufacturers Sections on any equipment not specified for use by the Contract Sections, 8. Proposed electrical safeguards to be implemented, including but not limited to location of transformers, GFCI outlets, lighting, etc., necessary to safely perform the job, including a description of an electrical hazards safety plan for common practices in the work area, ASBESTOS ABATEMENT

67 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA 9. A list of all equipment to be used on site, by make and model, including negative pressure equipment, HEPA vacuums, Water Atomizing Devices, etc., 10. Chain of Command of responsibility at work site including supervisors, foreman, and competent person, their names, resumes and certificates of training, 11. Proposed Emergency plan and route of egress from work areas in case of fire or injury, including the name and phone number of nearest medical assistance center, 12. Contractor's testing lab, AIHA PAT proficiency, and Certification in the State where work site is located, 13. Schedule of values breaking down the work in sufficient detail so as to serve as the basis for payment, with disposal costs listed as a separate item. C. Post-Construction Submittals The Contractor is required to submit the following to the Consultant within thirty days after completion of the project: 1. Manifests and waste receipts acknowledging disposal of all waste material from the project showing delivery date, quantity, and appropriate signature of landfill's authorized representative, 2. A copy of the entry-exit logbook required elsewhere in these Sections, 3. All personnel monitoring results as required by OSHA and elsewhere in these Sections, 4. Copy of licenses, medical, and fit tests of all workers and supervisors who performed work on the project, 5. All notifications as required elsewhere in these Sections REFERENCE STANDARDS, REGULATIONS AND CODES A. All work shall be performed strictly according to the Sections contained herein and with the regulations cited in this Article. The Contractor undertaking asbestos abatement work and persons in their employ shall comply with and be bound to requirements of the following Federal, State, and Local standards, regulations and codes. These standards and codes shall be by reference made part of this Section and shall be complied with. Whenever regulations are conflicting, the more stringent regulation will prevail. ASBESTOS ABATEMENT

68 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA 1. US Department of Labor; Occupational Safety and Health Act of (Particular attention is drawn to the Asbestos Regulations: CFR Title 29, Part 1910, Sec and Part 1926, Sec , and the Respirator Regulations; CFR Title 29, Part 1910, Sec and the Hazard Communication Program, CFR Title 29, Part ). 2. US Environmental Protection Agency, CFR, Title 40, Part 61, Subparts A and M, National Emission Standards for Hazardous Air Pollutants; Asbestos NESHAP Revision; Final Rule, Dated Tuesday, November 20, US Environmental Protection Agency; TSCA Title II, Asbestos Hazard and Emergency Response Act (AHERA), 40 CFR Part 763 Subpart E - "Asbestos-Containing Materials in Schools" and also 40 CFR, Part 763, Subpart G - "Worker Protection Rule". 4. US Department of Transportation regulations, 49 CFR Parts 172 and All Commonwealth of Massachusetts laws, regulations and standards, including the regulations 453 CMR 6.00 "The Removal, Containment or Encapsulation of Asbestos" and 310 CMR 7.15 "Asbestos", and and MGL Chapter 21E. 6. Other Federal, State and local statutes, ordinances, regulations, or rules pertaining to this Section and the work described herein, including the storage, transportation and disposal of asbestos. B. All regulations by these and other governing agencies in their most recent version are applicable. These Sections refer to many requirements found in these references, but in no way intend to cite or reiterate all provisions therein or elsewhere. It is the contractor's responsibility to know, understand, and abide by all such regulations and common practices. Other provisions contained in these references may from time to time during the execution of this contract be enforced by the Owner at his own discretion REGULATORY SUBMITTALS A. The Contractor shall be responsible for securing all necessary permits for asbestos related work, including hauling, removal, and disposal, fire, and materials usage, or any other permits required to perform the specified work. B. The Contractor shall notify the following agencies in appropriate manner and place of impending work, and shall provide evidence of notifications at the preconstruction conference: 1. U.S. Environmental Protection Agency, J. F. Kennedy Federal Building ASBESTOS ABATEMENT

69 Boston, Massachusetts (10 working days in advance) Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA 2. Massachusetts Department of Environmental Protection Division of Air and Hazardous Materials (10 working days in advance) Send Notification to: Commonwealth of Massachusetts Asbestos Program P.O. Box Boston, Massachusetts Massachusetts Department of Labor Standards Asbestos Control Unit (10 working days in advance) 4. City of Brockton Fire and Health Department and other state or city agencies as required by law or ordinance PROJECT CONDITIONS A. Take all measures and provide all material necessary for protecting fixed machinery, controls, instrumentation, equipment, and furniture from asbestos fiber, dust and debris and from water damage. B. Working space and space available for storing materials is restricted within the confines of the project and/or at locations to be designated by the Owner. C. Provide access and personal protective equipment, including half face piece negative pressure respirators, to the Consultants, who are licensed and certified, to visit the Work Areas to maintain and adjust building services. D. Schedule the use of existing utilities with the Owner. No utility service, fire protection system, or communication system may be interrupted without prior approval of the Owner. E. Water, electric power, lighting and other utilities, toilets, and other facilities, shall be provided by the Owner from existing sources where Contractor's use is not excessive and does not interfere with buildings normal use. Where existing utilities of the facility are not adequate or cannot be used, the Contractor is responsible for providing alternative sources, the cost of which is to be included in bid price. The use of the Facility's utilities shall be coordinated through the Owner. F. Post and affix caution signs and labels as required by OSHA regulation, 29.CFR (k) (1). Post safety signs outside the work project as may be required by the Owner. Obtain two copies of 29.CFR , ASBESTOS ABATEMENT

70 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA 29.CFR , m 40.CFR.61, Subpart M, and Commonwealth of Massachusetts Regulations 453 CMR 6.00 and 310 CMR 7.00, and post one copy at the job site and retain one copy on file. G. Post at the job site, or at the entrance to each independent Work Area, one copy of all Material Safety Data Sheets (MSDS's) of all chemicals and other substances to be used on this contract. These sheets shall be made available to the Consultants for review. H. No storage of waste will be permitted onsite. All ACM shall be removed off-site at the end of each shift except that limited storage space may be provided by the Owner at the facility. Contractor will supply any additional temporary storage as needed. All materials and equipment are to be kept in orderly fashion in designated areas, free and clear of halls and doorways, and in conformance with all regulations, codes, and in consideration of building usage RESPIRATORS AND PROTECTIVE CLOTHING A. Personal protection, in the form of disposable Tyvek suits, and NIOSH approved respirators, are required for mechanics, contractor supervision, Consultant and visitors at the work site during the set-up, removal, and cleaning operations. Contractor shall provide all this protective equipment for workers, Consultant, and authorized personnel to access this work site. B. Each worker shall be supplied with a minimum of two complete disposable uniforms everyday. Removal workers shall not be limited to two uniforms, and the Contractor will be required to supply additional uniforms as is necessary. Under no circumstances will anyone entering the removal area be allowed to reuse a contaminated uniform. C. Work clothes shall consist of disposable full body suits, head covers, gloves, footwear, and eye protection. D. The Contractor shall supply workers and supervisory personnel with NIOSH approved protective respirators and HEPA/filters. Appropriate respirator selection shall be determined by the daily personnel samples being taken and strictly follow the guidelines set forth in the OSHA respiratory program 29 CFR and the Massachusetts DOS Regulations 453 CMR The respirators shall be sanitized and maintained according to the manufacturer's Sections. Appropriate respirators shall be selected using the information provided in OSHA Title 29 CFR Part Final Rules. This determination has been made for this project. PAPR s shall be supplied by the contractor for all personnel associated with this work. Disposable respirators shall not be considered acceptable in any circumstance. The Contractor will maintain on site a sufficient supply of disposable HEPA/filters to allow workers and supervisory personnel to change contaminated filters at least three (3) times daily. The Contractor is solely responsible for means and methods used and for compliance with applicable regulations. ASBESTOS ABATEMENT

71 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA E. Respirators shall be individually assigned to removal workers for their exclusive use. All respiratory protection shall be provided to workers in accordance with the written submitted respiratory protection program, which includes all items in OSHA 29 CFR (b) (1-11) A copy of this program shall be kept at the work-site, and shall be posted in the Clean Room of the Decontamination Unit. F. Workers must perform negative and positive pressure fit tests each time a respirator is put on, whenever the respirator design so permits. Powered air purifying respirators shall be tested for adequate flow as specified by the manufacturer. G. Workers shall be given a qualitative fit test in accordance with procedures detailed in the OSHA Lead Standard (29 CFR , Appendix D, Qualitative Fit Test Protocols) for all respirators to be used on this abatement project. An appropriately administered quantitative fit test may be substituted for the qualitative fit test. H. Upon leaving the active work area, pre-filters shall be discarded, cartridges removed, and respirators cleaned in disinfectant solution and clean water rinse. Clean respirators shall be stored in plastic bags when not in use. The contractor shall inspect respirators daily for broken, missing, or damaged parts. I. Contractor shall provide daily personal sampling to check personal exposure levels for the purpose of establishing respiratory protection needs. Samples shall be taken for the duration of the work shift or for eight hours, whichever is less. Personal samples need not be taken every day after the first day if working conditions remain invariant, but must be taken every time there is a change in the removal operation, either in terms of the location or the type of work. Sampling will be to determine eight-hour Time-Weighted-Averages (TWA). The contractor is responsible for personal sampling as outlined in OSHA Standard J. Sampling personnel shall be proficient in the taking of air samples under NIOSH 7400, and must be supervised by an individual who has completed the training course NIOSH 572 or equivalent. K. Air sampling results shall be available at the job site in written form no more than twenty-four (24) hours after the completion of a sampling cycle. The document shall list each sample's result, sampling time and date, person monitored, flow rate, sample duration, microscope field area, number of fibers per fields counted, cassette size and analysts name and company. Air sample analysis results will be reported in fibers per cubic centimeter. ASBESTOS ABATEMENT

72 1.10 WATER AND ELECTRICAL SERVICE Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA A. The Contractor shall provide temporary connections to existing building utilities and provide temporary facilities as required and necessary to carry out the work. B. The Contractor shall provide temporary connections to building water service and provide all lines necessary for distribution of water. C. Comply with applicable NEMA, NECA and UL standards and governing regulations for materials and layout of temporary electrical service. All power connections and panel work is to be performed by a licensed electrician. D. The Contractor shall provide temporary service connections from power sources as required. All existing power service to the work area will be isolated and shut down for the duration of the project. Contractor shall provide service (sub-panel) with a minimum of 100 amp, two-pole circuit breaker or fused disconnect. Sub-panel and disconnect shall be sized and equipped to accommodate all electrical equipment required for completion. Contractor's electricians will make all necessary connections to main power system. E. Provide I.D. warning signs at power outlets that are other than volt power. Provide polarized outlets for plug-in type outlets, to prevent insertion of volt plugs into higher voltage outlets. F. Provide all receptacle outlets equipped with ground fault circuit interrupters (GFCI) and reset button for plug-in connection of equipment. G. The Contractor must supply temporary lighting for all lighting requirements within contained areas. All existing lighting shall be isolated and shut down. ASBESTOS ABATEMENT

73 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA PART 2 - PRODUCTS 2.01 ASBESTOS ABATEMENT SUPPLIES A. Respirators: Respirators will be selected from those jointly approved by the National Institute for Occupational Safety and Health (NIOSH), US Department of Health and Human Services and the Mine Safety and Health Administration (MSHA), US Department of Labor. B. Surfactant (Amended Water): All water to be used for removal and wet wiping of asbestos-contaminated materials during clean-up operations shall be amended through the addition of a surfactant (a 50/50 mixture of polyoxyethylene ether and polyoxyethylene ester, or equivalent) mixed and supplied in accordance with manufacturer's instructions. C. Polyethylene Sheeting: All polyethylene sheeting used on the Project shall be fire resistant, and shall meet and be approved as called for in local, Fire Prevention Codes PART 3 - EXECUTION 3.01 GENERAL A. Approvals and Inspection 1. All temporary facilities, work procedures, equipment, materials, services, and agreements must strictly adhere to and meet these contract Sections along with EPA, OSHA, NIOSH, regulations and recommendations as well as any other federal, state, and local regulations. Where there exists overlap of these regulations, the most stringent one applies. All work performed by the Asbestos Abatement Subcontractor is further subject to approval of the Owner. 2. Modifications to these isolation and sealing methods, procedures, and design may be considered if all elements of proper and safe procedures to prevent contamination and exposure can be demonstrated. Written modifications to these Sections must be made to the Owner and Consultant for review before they can be used for work on this project. B. Damage and Repairs to the Work Site 1. Asbestos removal and disposal shall be performed without damage to the building, including, but not limited to, structural members, ceilings and walls. The Asbestos Abatement Subcontractor shall provide protection of these items and materials as part of the work area ASBESTOS ABATEMENT

74 C. HVAC Systems Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA preparation. Where asbestos abatement activity causes damage, the Asbestos Abatement Subcontractor shall patch, repair, replace or otherwise restore it to its original condition at no additional cost to the Owner. 1. All duct work, heating units and HVAC equipment shall be wrapped in two layers of six-mil polyethylene prior to any other work taking place, or excluded from work area boundaries by airtight polyethylene sheeting. D. Barriers and Isolation Areas 1. The Asbestos Abatement Subcontractor shall construct and maintain suitable critical barriers to separate asbestos abatement window/door work areas from interior spaces occupied by the Owner. Critical barriers shall be of sufficient size and strength to prevent staff, residents, the public and others from entering the work areas. Critical barriers shall be constructed at all window access locations or other open entrances to the window work areas. Any seams in the critical barriers shall be sealed airtight with caulking or an approved equal method. These barriers shall be removed by the Asbestos Abatement Subcontractor at the completion of construction work. 2. Warning signs shall be posted on all critical barriers at the commencement of the work area preparation, as required in of the Occupational Safety and Health Standards Federal Register, Volume 51, Number 119, June 20, The signs shall display the proper legend in the lower panel, with letter sizes and styles of a visibility at least equal to that specified in OSHA Standard (k)(1)(ii). The signs will read as follows: DANGER ASBESTOS CANCER AND LUNG DISEASE HAZARD AUTHORIZED PERSONNEL ONLY RESPIRATOR AND PROTECTIVE CLOTHING REQUIRED IN THIS AREA 3. The signs shall be posted at the perimeters of asbestos removal, demolition or construction areas where the asbestos-containing material to be removed exists. 4. The Asbestos Abatement Subcontractor shall maintain all temporary and critical barriers, facilities and controls as long as needed for the safe and proper completion of the work. Any breaches in the containment will be corrected at the beginning of each shift and as ASBESTOS ABATEMENT

75 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA necessary during the workday. Work will not be allowed to commence until all control systems are in place and operable. 5. No barriers shall be removed until the work areas are thoroughly cleaned and all debris has been properly bagged and removed from work areas, and the air has passed final clearance tests, in accordance with provisions detailed herein PREPARATION AND DECONTAMINATION UNIT A. Preparation 1. The Asbestos Abatement Subcontractor shall prepare the window/door work area by installing critical barriers and sealing any openings near window abatement areas. Critical barriers consist of the boundaries of the work area including roof hatches, roof level windows and any constructed barrier to restrict public access to the work area. HVAC systems shall be shutdown and sealed, where applicable, as described previously with two layers of 6 mil polyethylene sheeting. B. Decontamination Unit and Procedures 1. It is the Asbestos Abatement Subcontractor's responsibility to provide a remote decontamination unit consisting of an Equipment Room, Shower, and Clean Room for personnel involved in asbestos removal. Each of the three rooms shall be of sufficient size to accommodate authorized personnel and related equipment. Each room shall be separate of other rooms by a double flap of six (6) mil. polyethylene sheeting acting as an airlock. This shall be designed to minimize fiber migration and airflow between the decontamination unit rooms. The rooms shall be framed with 2"x 4" lumber, masked, sealed and attached to the entry/exit ways of asbestos work areas. The three rooms together shall be referred to as the Decontamination Unit. 2. The Equipment Room shall serve as a transfer room and an intermediate area between the work area and any decontamination procedures to occur in the shower room. This room shall be vacuumed and washed whenever necessary in order to prevent asbestos dust and debris accumulations or when required by Consultant. The Equipment Room will also serve as an access area to the shower for personnel leaving the work area. Workers leaving the containment shall remove and dispose of disposable protective suits and wear only respirators into the Shower. At the end of each day, bags of asbestos waste and contaminated materials shall be removed after a thorough decontamination procedure as described in the contract Sections. Workers performing this operation will wear respirators and disposable full-body protective suits. ASBESTOS ABATEMENT

76 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA 3. The Shower Room shall have a continuous supply of cold and hot water, and be suitably arranged for complete showering during decontamination. The Shower Room with curtained doorways will comprise an airlock between contaminated and clean areas. All materials being passed from the equipment room to the clean room must pass through the shower and be thoroughly decontaminated. The shower floor will not be allowed to sit at ground level, but must be elevated a minimum of six inches off of the floor with a suitable catch basin for drainage into a filtration system. The shower will be equipped with a sump pump and an in-line two stage filter. The first stage will efficiently filter fibers greater than twenty (20) microns in length and the second stage will filter bulk material and fibers greater than five (5) microns in length. Alternatively, shower water may be rerouted back into the work area to be bagged and disposed of as asbestos contaminated waste. The Asbestos Abatement Subcontractor shall provide disposable towels and soap in the shower area. 4. The Clean Room shall store asbestos worker's clean protective clothing and clean respirator equipment. Contaminated clothing, respirators, tools, equipment, or other materials shall not be allowed into the Clean Room or beyond. The Clean Room will serve as an access for personnel entering the work area, and for the donning of respiratory protection and protective clothing. The Asbestos Abatement Subcontractor shall provide space in the clean room for the worker's personal clothing. This may be in the form of hangers or lockers ASBESTOS CONTAINING WINDOW/DOOR CAULKING AND GLAZING COMPOUND REMOVAL A. Removal of asbestos-containing window/door frame caulking and glazing compound shall be in accordance with all applicable regulations. At a minimum, the following work practices shall apply: 1. Grinding, sanding, cutting or abrading the ACM shall not be permitted unless performed using wet methods with in a work area established in accordance with Section Workers shall wear protective clothing and half-mask, dual-cartridge, HEPA-filtered respirator, at a minimum. 3. A regulated work area shall be established as required by regulations and to the satisfaction of the Consultant. 4. Place polyethylene sheeting below area where window/door caulking and glazing compound will be removed ASBESTOS ABATEMENT

77 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA 5. Using wet methods, remove the window caulking and glazing compound in a manner which precludes the material from becoming friable. 6. Properly decontaminate all non-acm materials in contact with the asbestos-containing material. All non-acm materials in contact with the asbestos-containing, not properly decontaminated, shall be wrapped in two layers of six-mil polyethylene sheeting and disposed of as asbestos contaminated waste. 7. Properly wet and double bag all ACM, and all non-acm materials contaminated with asbestos for disposal as ACM debris. 6. Using a HEPA vacuum clean all residual asbestos-containing material remaining in the work area. 9. Where the specified window/door component can be removed and disposed of whole, the entire window component (e.g., window sash, window frame, door frame) may be removed and wrapped in two layers of six-mil polyethylene and disposed of as ACM. As an alternative to disposal of the entire component, the ACM contaminated portion of the components may be removed and disposed of, provided that cutting or abrading or other process that will render the ACM friable, does not occur. Upon completion of the whole window/door unit and removal of window/door frames, caulking between window/door frame and building masonry shall be assumed present at all window and door locations and removal of this material as ACM is included in the Asbestos Abatement scope of work for both the Downey Elementary School and the Brockton High School. 10. Dispose all asbestos-containing waste in an EPA and DEP approved land DECONTAMINATION/WORK PROCEDURES A. In order to avoid possible exposure to dangerous levels of asbestos, and to prevent possible contamination of areas outside the demarcated work zone, work shall follow the guidelines listed below. 1. At no time shall a worker entering the containment area go further than the Clean Room of the Decontamination Unit without a respirator and protective clothing. 2. Before leaving the work area, the worker shall remove all gross contamination and debris from the coveralls. In practice this is carried out by one worker assisting another. ASBESTOS ABATEMENT

78 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA 3. All equipment used by the workers inside the demarcated work area shall be either left in the Dirty Room of the Decontamination Unit or thoroughly decontaminated before being removed from the area. Extra work clothing (that in addition to the disposable garments supplied by the Asbestos Abatement Subcontractor) shall be left in the Dirty Room of the Decontamination Unit until the completion of work in that area. 4. All persons leaving the work area must shower before leaving the regulated area. 5. Under no circumstance shall workers or supervisory personnel be allowed to eat, drink, smoke, chew gum, or chew tobacco in the work area; to do so shall be grounds for the Consultant to stop all removal operations. Only in the case of life threatening emergency shall workers or supervisory personnel be allowed to remove their protective respirators while in the work area. In this situation, respirators are to be removed for as short a duration as possible. 6. As with additional clothing, all footwear shall be left inside the work area until the completion of the job, then cleaned or discarded DISPOSAL OF ASBESTOS WASTE A. Waste removal procedure shall be done in accordance with all regulations as set forth by the agencies having authority to regulate. B. The Asbestos Abatement Subcontractor shall provide proof that disposal sites for the waste materials have current and valid permits in order to dispose of asbestos waste at the time of the pre-construction meeting. C. Receipts shall be obtained by the Asbestos Abatement Subcontractor from the dumping site(s), and submitted to the Owner upon request for final payment. D. Warning labels having permanent, waterproof print and adhesive shall be affixed to all bags, trucks, drums (lids and sides), and other containers used to store and/or transport asbestos-containing material. Labels must be conspicuous and legible and contain the following: CONTAINS ASBESTOS FIBERS AVOID CREATING DUST CANCER AND LUNG DISEASE HAZARD E. The Asbestos Abatement Subcontractor shall be responsible for all necessary precautions to prevent pollution by spilling during the performance of services and shall assume full responsibility for all Asbestos Abatement Subcontractor caused spills, which shall be cleaned up at the Asbestos ASBESTOS ABATEMENT

79 Abatement Subcontractor's expense. Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA F. Temporary storage of asbestos waste on-site must be approved by the Owner HOUSEKEEPING A. Throughout the work period, the Asbestos Abatement Subcontractor shall maintain the building and site in a standard of cleanliness as specified throughout these Sections AIR MONITORING 1. Contaminated disposable clothing, respirator filters, and other debris shall be bagged and sealed at the end of each work day. 2. All asbestos generated by either removal or repair, shall be bagged immediately and not allowed to be left exposed at the end of each work day. 3. Respirators shall be thoroughly cleaned at the end of each work day and stored for the next days use. 4. The Asbestos Abatement Subcontractor shall retain all stored items in an orderly arrangement allowing maximum access, not impeding traffic, and providing the required protection materials. 5. The Asbestos Abatement Subcontractor shall not allow the accumulation of scrap, debris, waste material, and other items not required for completion of the work. 6. The Asbestos Abatement Subcontractor shall provide adequate storage for all items awaiting removal from the job site, observing all requirements for fire protection and protection of the ecology. 7. Daily, and more often if necessary, the Asbestos Abatement Subcontractor shall inspect the work areas and adjoining spaces, and pick up all scrap, debris, and waste material. Remove all such items to the place designated for their storage. 8. The Asbestos Abatement Subcontractor shall maintain the site in a neat and orderly condition at all times. A. During removal of window materials, area samples may be collected by the Consultant outside the window work area, just outside the clean room, and inside the regulated area. During removal of window caulking materials, area samples may be collected by the Consultant outside major openings in the work area. The Asbestos Abatement Subcontractor shall be responsible for all OSHA personal sampling. ASBESTOS ABATEMENT

80 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA 3.08 WORK REVIEW A. Consultant will review the Asbestos Abatement Subcontractor's work practices prior to the start of and at periodic times during asbestos related work and will report any Section violations to the Asbestos Abatement Subcontractor. If the Asbestos Abatement Subcontractor fails to correct deficiencies in a timely manner, the Owner will be notified in writing, and work may be stopped. The Consultant will review the work area and conditions before work begins and after the Asbestos Abatement Subcontractor Site Supervisor has given approval. Outside airborne fiber concentrations must not exceed fibers/cc or pre-abatement levels, whichever is greater. If concentrations exceed this level, then work must be stopped, conditions reviewed as to the probable cause, and then corrected. B. Consultant will keep a daily log of the Asbestos Abatement Subcontractor's work practices and will make these daily logs a part of the final project documents. C. In addition to various daily inspections of engineering controls and work practices, Consultant will make three (3) mandatory inspections throughout the removal work. These inspections include: a pre-abatement visual inspection, a post-abatement visual inspection, and a post-teardown visual inspection. D. Each inspection must be requested by the Asbestos Abatement Subcontractor and performed by Consultant, to the satisfaction of the Consultant, and be signed off by the Consultant, before work is to continue on next task in the phase. Failure on the part of the Asbestos Abatement Subcontractor to obtain sign-off before proceeding is regarded as a serious violation of the contract and unacceptable. END OF SECTION ASBESTOS ABATEMENT

81 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA SECTION LEAD-CONTAINING PAINT CONSIDERATIONS PART 1 GENERAL 1.01 GENERAL PROVISIONS A. Attention is directed to the Contract including General Conditions, Modifications to the General Conditions, and all Sections within Division 1-General Requirements that are hereby made a part of this Section. B. In addition to the requirements specified herein, refer to all Contract Documents for complete description of work required to be performed under this Section. C. Examine all Drawings and all other Sections of the Specifications for requirements of related sections affecting the work of this Section. A lead determination at the site indicates that various window and door components are considered to be coated with lead containing paint. General Contractor shall assume that all windows, doors, window grates, exterior grills, and interior metal surrounds included in the project scope of work are coated with lead containing paint. D. The work of this Section shall be performed as stated herein. In performing the work of this section, the General Contractor shall refer to other Sections for additional procedures. The General Contractor is responsible for the coordination of the work of this Section with related work. No delays in completion of the work shall be claimed for lack of coordination. E. It is the intent of the Specifications and the Drawings to require that the equipment to be furnished complete in every respect, and that this Contractor shall provide all equipment needed and usually furnished in connection with such systems to provide a complete installation. Equipment, materials, and articles incorporated in the work shall be new and of the best grade of their respective kinds F. The General Contractor shall comply with all applicable federal, state, and local guidelines and regulations regarding all work involving the presence of lead-containing paint. G. The work of this Section references work of the Demolition Section. Additionally, requirements of the General Contractor regarding coordination and related work are identified in this Section and shall be considered the responsibility of the General Contractor. H. Use of roads at the site and all access to the site shall be as required by the Owner, and where described else ware in the Specification. I. For the purpose of this Section, the following definitions apply: "Site" shall refer to the Downey Elementary and Brockton High Schools- located in Brockton, Massachusetts. LEAD-CONTAINING PAINT CONSIDERATIONS Section of 16

82 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA "Architect" shall refer to CSS Architects, Inc. "Consultant" shall refer to ATC Associates Inc., who will act as designated authorized representatives of the Owner for the purpose of inspecting, monitoring, and testing DESCRIPTION OF WORK A. The work of this Section specifies minimum requirements for the disturbance, removal, containment, and disposal of lead-containing paint and associated waste generated as a result of window and door renovation activities as outlined in the Specifications. B. The procedures described herein apply to all renovation/construction work where a worker may be occupationally exposed to lead as well as to the disposal of the demolition debris. The General Contractor shall assume that any painted surface not tested, as included in this Section, shall be assumed to contain lead paint and it shall be the General Contractor s responsibility to protect workers performing under this Contract. This may require additional testing by the General Contractor to verify lead content. C. The General Contractor shall assume full responsibility and liability for the compliance with all applicable federal, state and local regulations pertaining to work practices, hauling and disposal of hazardous waste, hauling and recycling of all metal components coated with lead-containing paint, protection of workers and visitors to the site, and persons occupying areas adjacent to the site. The General Contractor shall hold the Owner, Architect, and Architect harmless for failure to comply with any applicable work, hauling, disposal, safety, health or regulation on the part of himself, his workers or his sub contractors. D. The General Contractor is required to ensure the protection of workers performing any related renovation/demolition work that will affect surfaces coated with lead-containing paint as well as protecting the public and the environment from exposure to lead dust. E. Codes and Standards 1. All work shall conform to the standards set by applicable federal, state and local laws, regulations, ordinances, and guidelines in such form in which they exist at the time of the work on the contract and as may be required by subsequent regulations. 2. In addition to any detailed requirements of the Specification, the General Contractor shall at his own cost and expense comply with all laws, ordinances, rules and regulations of federal, state, regional and local authorities regarding handling and storing of lead waste material. 3. The following r eferences ar e c ited as appl icable s tandard and r egulations as amended: a. Code of Federal Regulations (CFR) Publications: LEAD-CONTAINING PAINT CONSIDERATIONS Section of 16

83 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA 29 CFR 1910 General Industry 29 CFR Gases, Vapors, Fumes, Dusts and Mists 29 CFR Ventilation 29 CFR Lead in Construction 29 CFR Signs, Signals and Barricades 29 CFR Welding, Cutting and Heating in Way of Preservative Coatings 29 CFR Subpart T Demolition 40 CFR 50 National Primary and Secondary Ambient Air Quality Standards for Lead 40 CFR 61 Subpart A General Provisions 40 CFR Standard for Waste Manufacturing, Demolition, Renovation, Spraying, and Fabricating Operations. 40 CFR 241 Guidelines for the Land Disposal of Solid Wastes 40 CFR 257 Criteria for Classification of Solid Waste 40 CFR 261 and 262 Waste Disposal Facilities and Practices b. Massachusetts Regulations: 454 CMR Safety Procedures for renovation 454 CMR Occupational Lead Exposure 4. All regulations by the above and other governing agencies in their most current version are applicable throughout this project. Where there is a conflict between this Specification and the cited federal, state, or local regulations, the more restrictive or stringent requirements shall prevail. 5. THIS SECTION REFERS TO MANY REQUIREMENTS FOUND IN THESE REFERENCES, BUT IN NO WAY IS IT INTENDED TO CITE OR REITERATE ALL PROVISIONS THEREIN OR ELSEWHERE. IT IS THE GENERAL ONTRACTOR'S RESPONSIBILITY TO KNOW, UNDERSTAND, AND ABIDE BY ALL SUCH REGULATIONS AND COMMON PRACTICES. LEAD-CONTAINING PAINT CONSIDERATIONS Section of 16

84 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA 1.03 RELATED WORK SPECIFIED ELSEWHERE A. The work of this Section shall be performed as stated herein. In performing the work of this Section, the General Contractor shall refer to other Divisions for additional procedures. The General Contractor is responsible for the coordination of the work of this Section with other related work. B. Portions of the work herein require direct coordination with the work of the above noted Related Sections DEFINITIONS A. The following definitions apply to the performance of the work of this project. 1. Action Level: An airborne concentration of lead above 30-micrograms/cubic meter (µ/m 3 ) as a time-weighted average (TWA) for more than 30 days per year. 2. Area Monitoring: Sampling of lead concentrations within the work area and outside the work area, which is representative of the airborne concentrations of lead. 3. Clean Room: An uncontaminated change room directly adjacent to the work area having facilities for storage of employees' personal clothing and uncontaminated work clothes, materials and equipment provided when the airborne exposure to lead is above the PEL. 4. Architect: Authorized representatives who are under contract with the Owner to perform Engineering or Consulting services. 5. General Contractor: The term General Contractor refers to the General Contractor and its Sub General Contractors. 6. Decontamination Area: A contained area adjacent to or connected to the work area and consisting of an equipment room, shower area, and clean room which is used for decontamination of workers, materials and equipment. 7. HEPA Filter Equipment: High efficiency particulate air (HEPA) filtered vacuuming or exhaust ventilation equipment with a UL 586 filter system. Filters shall be of percent efficiency for retaining 0.3-micrometer diameter particles. 8. Lead Containing Paint: Paint, varnish, or stain that contains lead in excess of 0.0 mg/cm 2 or 0.0% lead by weight. 9. Lead Permissible Exposure Limit (PEL): 50 micrograms per cubic meter (µg/m 3 ) of air, based upon an 8-hour time weighted average. 10. Sample Location: Area or place where an air sample is collected. 11. Time Weighted Average (TWA): The TWA is an 8-hour time weighted average for the test of the concentration of lead for worker exposure. LEAD-CONTAINING PAINT CONSIDERATIONS Section of 16

85 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA 12. Wet Cleaning: The process of removing lead contamination from building surfaces, equipment and other objects by using cloths, mops, or other cleaning tools which have been dampened with water, and by afterwards disposing of these cleaning tools as lead contaminated wastes. 13. Work Area: A controlled-access work area which has plastic sheeting or other containment barriers erected to separate the trades SUBMITTALS A. Notifications 1. Provide in proper and timely fashion, all necessary notifications to relevant Federal, State, and local authorities and obtain and comply with provisions of all permits or applications required by the work specified, as well as make all required submittals required under those auspices. General Contractor shall indemnify Owner, Architect and Consultant from, and pay for all claims resulting from failure to adhere to these provisions. Costs for all permits, applications, and the like are to be assumed by General Contractor. B. Prior t o c ommencing a ny work unde r this S ection, the C ontractor s hall s ubmit the following items to the Architect for review in accordance with Section Submittals. No Work under this Section may commence until the Architect has accepted all required submittals. 1. Copies of al l not ifications, per mits, appl ications, l icenses and l ike doc uments required by f ederal, s tate, or l ocal r egulations a nd t his s pecification obt ained or submitted in proper fashion, 2. Copies of written medical opinions for each employee who may be occupationally exposed to lead as required by 29 CFR (j)(3)(v), 3. Employer s Lead Compliance Program as required by 29 CFR , including proposed worker training, respiratory protection program and medical monitoring for all employees throughout all phases of the job, including make, model and NIOSH approval numbers of respirators to be used; worker orientation plan; written description of all proposed procedures, methods, or equipment to be utilized, including those that may differ from the Contract Specifications. In all instances, the General Contractor must comply with all applicable federal, state and local regulations. 4. Proposed number and type (i.e., hazardous waste or non-hazardous waste, open top, front loading, etc.) of dumpsters for waste, proposed location(s), 5. A list of all equipment to be used on site, by make and model, 6. Chain of Command of responsibility at work site including supervisors and competent person, their names, resumes and phone numbers, LEAD-CONTAINING PAINT CONSIDERATIONS Section of 16

86 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA 7. List of total number of supervisors and workers intended to be assigned to the project, including name and lead awareness qualifications, 8. Material Safety Data Sheets on potentially hazardous materials to be used on the project, 9. Waste Disposal Plan which describes the waste stream and the disposal means (i.e. landfill, recycle, etc.) and includes the name, address, and ID number of the proposed hazardous waste hauler, waste transfer route, and proposed disposal reclamation or treatment facility, 10. Name and address of the proposed construction debris site, 11. Name and address of the proposed metal component construction debris recycling site, including letter stating such site accepts such waste, 12. Construction schedule including sequence of critical work. C. Submit the following to the Owner/Architect as a Post-Construction submittal package: 1. Copies of waste manifests and receipts acknowledging disposal and recycling of all lead waste material from the project, showing delivery date, quantity, and appropriate signature of landfill's authorized representative. 2. A notarized copy of the daily list of workers and site entry-exit logbook, 3. All personnel monitoring results, 4. All TCLP testing results GENERAL WORK PROCEDURES A. Work shall be carried out in sequential phases. Inspection and approval of each phase by the Architect shall be sought and gained before proceeding to the next phase and in accordance with the schedule agreed upon by Owner and General Contractor at the Pre- Construction meeting as amended. This shall include demolition requirements for work area clearance and work area release prior to general construction work. As a Contract requirement, any reasonable delay caused by this requirement will not constitute a basis for claim against the Owner/Architect. General Contractor must coordinate the work of this section with the work of the General Contractor and all other trades. B. At no time will Owner permit storage of debris generated from renovation/demolition activities to be stored inside buildings at the site, and any storage of materials shall be subject to Owner's approval. Assure security of debris at all times. C. The working hours for this project will be determined in the Pre-Construction meeting. LEAD-CONTAINING PAINT CONSIDERATIONS Section of 16

87 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA 1.07 SPECIAL CONSIDERATIONS A. Testing References 1. Limited testing for lead paint has been performed on a representative number of painted window and door components in the areas scheduled for renovation/demolition work using the paint chip digestion method (7420, SW-846). 2. General Contractor is to assume that all painted window and door components, including exterior grills and interior metal window surrounds are lead-containing. 3. The Occupational Safety and Health Administration (OSHA) requires employers to determine the airborne concentration of lead in dust in order to determine the employee s exposure hazard while impacting these coated surfaces and requires that the General Contractors and their employees adhere to the OSHA Lead-in- Construction standard found at 29 CFR B. The General Contractor shall follow the requirements of this Section regarding component removal, demolition, worker exposure and protection, work area cleaning, and waste disposal. C. Work Affected: In general, the following activities are minimum requirements of this Section and affect the demolition performed on the painted components: 1. No torch cutting, mechanical sanding or stripping or abrasive methods of paint removal shall occur. 2. No demolition or renovation activities shall occur which increase the workers exposure above the Action Level of 30 µg/m 3. General Contractor shall fully complete with the OSHA lead standard at 29 CFR Workers shall be informed of the components to be impacted during renovation or demolition that have been identified as containing lead. 4. Worker protection, at a minimum, shall comply with the OSHA Lead Standard 29 CFR Worker Right to Know and Health and Safety Standards of shall also apply to the work of this section. 5. Separation of Trades: Unprotected, untrained workers or trades shall not perform any related work within the same vicinity as work involving components identified with lead. 6. Clean-up Activities: The General Contractor shall maintain work zones free of accumulated debris and paint chips of demolition involving lead. LEAD-CONTAINING PAINT CONSIDERATIONS Section of 16

88 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA 1.08 REPORT OF FINDINGS A. The tables below identifies various components identified as containing lead in excess of 0.0 % by weight at the Downey Elementary and Brockton High Schools- located in Brockton, Massachusetts. The table was derived from a lead paint determination at the Subject Site. This inspection included the testing of representative painted window surfaces and is not intended to be a comprehensive identification of all painted surfaces. B. The Occupational Safety and Health Administration (OSHA) requires employers to determine the airborne concentration of lead in dust in order to determine the employee s exposure hazard while impacting these coated surfaces and requires that the General Contractors and their employees adhere to the OSHA Lead-in-Construction standard found at 29 CFR Summary of Paint Chip Samples Downey Elementary School Brockton, Massachusetts Sample No. Location % by weight of lead content 01 Red Paint on Metal Door: Northwest Corner Brown Paint on Window: Northwest Corner BDL 03 Brown Paint on Window: Southeast Corner BDL 04 Black Paint on Window: Northeast Hallway BDL BDL = Below Detection Limit Summary of Paint Chip Samples Brockton High School Brockton, Massachusetts Sample No. Location % by weight of lead content 01 Ground E l 3 North E nd E xterior: Black BDL Window Paint 02 Ground El 2 North: Yellow Door Paint Ground El 6 Administrative Offices Exterior: BDL Black Window/Door Paint 04 Ground El 2 Library Exterior: Black Window BDL Paint 05 Ground E l 2 Library Exterior: G reen D oor Paint 0.11 LEAD-CONTAINING PAINT CONSIDERATIONS Section of 16

89 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA 1.09 FEES, PERMITS & LICENSES A. The General Contractor shall pay all licensing fees, royalties, and other costs necessary for the use of any copyrighted or patented product, design, invention, or process in the performance of the work specified in this section. The General Contractor shall be solely responsible for costs, damages, or losses resulting from any infringement of these patent rights or copyrights. The General Contractor shall hold the Owner/Architect from any costs, damages, and losses resulting from any infringement of these patent rights or copyrights. If the Specification requests the use of any product, design, invention, or process that requires a licensing, patent or royalty fee for use in the performance of the job, the General Contractor shall be responsible for the fee or royalty fee and shall disclose the existence of such rights. B. The General Contractor shall be responsible for costs for all licensing requirements, where applicable and notification requirements, and all other fees related to the General Contractor s ability to perform the work in this Section. C. Secure all necessary permits for work under this Section, including hauling, removal, and disposal, fire, and materials usage, or any other permits required to perform the specified work CLEAN-UP A. Maintain the work site in a neat and orderly manner at all times, so as not to interrupt or infringe upon the work of other trades. B. Comply with all requirements for release of work areas as described in the project specification. C. It is the prerogative of the Owner/Architect to inspect whenever deemed necessary and the General Contractor is responsible for meeting and correcting any deficiencies discovered which do not meet the current applicable regulations and requirements of these specifications COORDINATION A. Extend full cooperation to Owner in all matters involving the use of Owner's facilities. At no time shall General Contractor cause or allow to be caused conditions which may cause risk or hazard to the general public or conditions that might impair safe use of the facility. The use of the facility's electricity, water or like utilities by the General Contractor shall be as specified in Division 1. B. Coordinate the work of this section with that of all other trades. Phasing and scheduling of this project shall be subject to the approval of the Owner/Architect. The work of this Section shall be scheduled and performed so as not to impede the progress of the project as a whole. Work shall not proceed in any area without the express consent of the Architect. LEAD-CONTAINING PAINT CONSIDERATIONS Section of 16

90 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA C. Unless specifically authorized by the Owner/Architect, the work of this project shall be conducted in accordance with the working hours agreed upon in the Pre-Construction Meeting. D. Inspections: The Architect may perform visual inspections during the work of this section, as described below. General Contractor shall not proceed with work until General Contractor has received the Owners/Architect s approval at the stages identified below: 1. Post Inspection: At the completion of work and final clean up, prior to clearance or removal of any critical barriers and decontamination unit from the work area. 2. Waste Removal Inspection: Prior to removal of hazardous waste from the site, Owner and Architect will inspect the quantity and type EMERGENCY PRECAUTIONS A. The General Contractor shall establish emergency and fire exits from the work area. B. When an injury occurs, the General Contractor shall stop work until the injured person has been removed from the work area DISPOSAL OF WASTE MATERIAL A. General 1. The General Contractor shall comply with the Resource Conservation and Recovery ACT (RCRA) and with all applicable state and local regulations. 2. The General Contractor shall be responsible for disposing of all metallic waste and components determined to be coated with Lead-Containing Paint (LCP) by separating and recycling. 3. The General Contractor shall be responsible for disposing of all non-metallic waste determined by Toxicity Characteristic Leachate Procedure (TCLP) to be hazardous. The General Contractor shall be responsible for testing representative building components prior to demolition of building structures and selective waste streams post demolition work. 4. The General Contractor shall comply with all EPA regulations. PART 2 PRODUCTS 2.01 GENERAL REQUIREMENTS A. The General Contractor shall deliver all materials and equipment to the site in the original containers bearing the name of the manufacturer, and details for proper storage and use. LEAD-CONTAINING PAINT CONSIDERATIONS Section of 16

91 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA B. All materials or equipment delivered to the site shall be unloaded, temporarily stored, and transferred to the work area in a manner that shall not interfere with other trades working in the area. C. Unloading and temporary storage sites, and transfer routes, must be approved in advance by the owner. D. Damaged or deteriorated materials may not be used and must be promptly removed from the premises. Material that becomes contaminated shall be packaged and legally disposed in an approved, secure landfill MATERIALS All materials and equipment proposed to be used on this project shall be subject to the acceptance of the Owner/Architect. The required materials shall include, but not necessarily limited to the following: A. Fire retardant polyethylene sheeting, minimum thickness of six (6)-mil. B. Plastic bags, minimum thickness of six (6)-mil. C. Duct Tape, up to 3 inch width D. Lead Warning Signs, as required by Section 3.02, the MA DOS Regulations, and OSHA Hazard Communication requirements. E. Flexible duct for ventilation units (if required) F. Spray adhesive, fire retardant G. Personal Protective Equipment, NIOSH approved respirators H. Ventilation units with HEPA filtration and exhaust fans. I. HEPA vacuums J. Tri-sodium Phosphate (TSP) and product data K. Cloth tarpaulin 2.03 TOOLS AND EQUIPMENT A. Transportation Equipment: Transportation equipment, as required, shall be suitable for loading, temporary storage, transporting, and unloading waste without exposure to persons or property. All over-the-road transportation equipment must carry the appropriate hazardous waste transport licenses and insurance. LEAD-CONTAINING PAINT CONSIDERATIONS Section of 16

92 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA B. Vacuum Equipment: All vacuum equipment utilized in the work area shall utilize HEPA filtration systems. C. Water Sprayer: The water sprayer shall be an airless or other low-pressure sprayer for water application. D. Other Tools and Equipment: The General Contractor shall provide other suitable tools including but not limited to: rounded edge shovels, rakes, brooms, and carts. E. The General Contractor shall provide ground fault circuit interrupters (GFCI) to protect all electrical cord and connections. F. Approved lighting equipment for use in the work area. G. Scaffolding: Scaffolding, as required to accomplish specified work, shall meet all applicable federal, state and local safety regulations and used in accordance with manufacturer s specifications. PART 3 EXECUTION 3.01 SCHEDULING A. The General Contractor shall coordinate all scheduling with the Owner/Architect. A schedule of work shall be submitted to the Owner/Architect, prior to contract performance UTILITIES A. Provide all necessary connections for temporary utilities in the workplace during work. Shut down and disconnect all electrical power to the work area so that there is no possibility of reactivation and electrical shock during the work. The temporary electrical power shall be in accordance with all OSHA requirements IDENTIFICATION OF HAZARDS A. Prior to any work involving lead-containing items, the General Contractor shall identify all work activities in which a worker may be occupationally exposed to lead. B. The General Contractor shall initially determine if any worker may be exposed to lead above the action level BARRIERS AND ISOLATION AREAS A. Containment controls (including critical barriers, protective coverings, HEPA-filtered ventilation and decontamination facilities) may be required for renovation/demolition work. The degree of containment shall be appropriate for the anticipated levels of airborne lead dust. The lower the level of airborne lead, the lesser the requirements necessary to control lead emissions at the job site. LEAD-CONTAINING PAINT CONSIDERATIONS Section of 16

93 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA B. Work Area Isolation (unless exempted according to Paragraph A) 1. The General Contractor shall isolate work areas for the duration of work by completely sealing off all openings in the work area. Isolation scaling shall be accomplished by constructing critical barriers where necessary around the work area perimeter. The work area shall be sealed airtight to the greatest extent possible. 3. Provide temporary power and lighting (with ground fault circuit interrupt protection) to the work areas, and ensure safe Installation of temporary power sources and equipment per applicable electrical code requirements, and OSHA requirements for temporary lighting in the environment normal to renovation/demolition areas. C. Equipment and Services: The General Contractor shall provide portable lighting, staging and scaffolding, utility hook-ups, portable fire extinguishers, first aid equipment, and all other equipment or items for the safe and efficient performance of Work. D. Decontamination Facility: 1. The General Contractor shall erect one or more Decontamination Facilities (if applicable) to serve each work area. The facility will consist of series of two or more connected chambers including, at a minimum, a clean room and a shower/wash room, separated by an air lock. Unless otherwise specified, the shower/wash room shall be contiguous to the work area. Non-contiguous, remote, three-chamber decontamination facilities may be substituted with the Architect s prior written approval. Three-chamber decontamination facilities shall include an equipment room to be used for removal and temporary storage of contaminated worker clothing, equipment, and other items leaving the work area, prior to decontamination in the shower/wash room of the decontamination facility. 2. In all cases, non-emergency access between contaminated and uncontaminated rooms or areas shall only be through the Decontamination Facility/Wash Room. 3. Ensure that barriers and linings are effectively sealed and taped at all times, and that the Shower/Wash Room floor is completely watertight. Repair damaged barriers, and remedy defects immediately upon discovery. Visually inspect enclosures at the beginning of each work period. E. All lead in renovation/demolition work areas shall remain isolated from all other trades on the project and remain inaccessible to the public. General Contractor shall monitor the access to the renovation/demolition work areas. The below listed items are required to control the generation of lead-containing dust during renovation/demolition activities if worker exposure is above the PEL. The General Contractor is ultimately responsible for cleaning all generated dust and paint debris from renovation/demolition operations and must maintain work areas free from lead dust generated from renovation/demolition activities. LEAD-CONTAINING PAINT CONSIDERATIONS Section of 16

94 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA 1. Signs shall be posted at all approaches to the work area warning that work involving lead is being conducted in the vicinity. Signs shall be in bold lettering not smaller than two inches tall. 2. Barriers shall not be removed until the work areas are thoroughly cleaned and approved by the Architect APPROVALS AND INSPECTIONS A. All temporary facilities, work procedures, equipment, materials, services, and agreements must strictly adhere to and meet this Section along with EPA, OSHA, regulations and recommendations as well as federal, state, and local regulations. Where there exists overlap of these regulations, the most stringent one applies. All work performed by the General Contractor is further subject to approval of the Owner/Architect PERSONNEL SAMPLING GENERAL CONTRACTOR A. Perform personnel air sampling during all renovation/demolition work to determine worker exposure limits. The results of such sampling shall be posted, provided to individual workers, and submitted to Owner/Architect as described herein. B. Provide sampling to check personal exposure levels. Representative sampling shall be taken for the duration of the work shift or for eight hours, whichever is less. Personal samples need not be taken for repeated working conditions if working conditions remain unchanged, but must be taken every time there is a change in the removal operation, either in terms of the location or the type of work. Sampling will be used to determine eight-hour Time-Weighted-Averages (TWA). Personal sampling shall be as outlined in OSHA Standard 29 CFR C. Air sampling results shall be transmitted to the Owner/Architect and individual workers available at the job site in written form no more than forty-eight (48) hours after the completion of a sampling cycle. The reporting document shall list each sample's result, sampling time and date, personnel monitored and their social security numbers, flow rate, sample duration, sample yield, cassette size, and analyst s name and company, and shall include an interpretation of the results. Air sample analysis results will be reported in micrograms/cubic meter (µg/m 3 ). D. The General Contractor s testing lab shall be AIHA accredited for analysis of metals. General Contractor shall submit for Owner s/architect s review and acceptance the name and address of the laboratory, certification(s) of AIHA accreditation for metal analysis, listing of relevant experience in air lead analysis, and presentation of a documented Quality Assurance and Quality Control program. E. Air monitoring frequency will be established in accordance with the requirements set forth in 29 CFR LEAD-CONTAINING PAINT CONSIDERATIONS Section of 16

95 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA 3.07 WORK PROCEDURES A. The General Contractor shall initiate, and continue, sufficient engineering and work practice controls, as described in the General Contractor s Lead Compliance Program, to reduce and maintain worker exposures to lead at or below the Action Level. B. The following work practices are specifically required by these specifications: 1. All persons except those directly involved in the work shall be excluded from the work area. Physical barriers shall be used, where necessary, to limit access to the work area for the duration of the window renovation activities. (Warning signs may need to be posted in accordance with applicable regulations.) 2. Provide hand washing facilities and assure that all workers thoroughly wash their hands and face upon exiting the work area. Workers shall pay careful attention to cleanse the hands and face when decontaminating (Provide hygiene facilities, including shower, as required based on initial assessment and continued monitoring.) 3. Thoroughly wet the areas to be demolished and mist the air to reduce the potential for creating airborne lead and dust. 4. All equipment used by the workers inside the work area shall be either left in the work area or thoroughly decontaminated before being removed from the area. Extra work clothing (in addition to the disposable suits supplied by the General Contractor) shall be left in the clean area until the completion of work in that area. The clean area shall be cleaned of all visible debris and disposable materials daily. 5. Under no circumstances shall workers or supervisory personnel eat, drink, smoke, chew gum, or chew tobacco in the work area; to do so shall be grounds for the Architect to stop all demolition operations. Only in the case of life threatening emergency shall workers or supervisory personnel be allowed to remove their protective respirators, if applicable, while in the work area RENOVATION/DEMOLITION PROCEDURES A. Feasible engineering controls shall be implemented by the General Contractor as described in the Lead Compliance Program to minimize the possibility of contamination of areas adjacent to the work area. The following activities are the minimum requirements of this section and affect the renovation/demolition performed on the painted components: 1. No torch cutting, mechanical sanding or stripping or abrasive methods of paint removal shall occur. 2. No renovation/demolition activities may occur which increase the workers exposure above the Action Level of 30 µg/m 3. General Contractor shall fully complete with the OSHA lead standard 29 CFR LEAD-CONTAINING PAINT CONSIDERATIONS Section of 16

96 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA B. Workers shall be informed of the components to be impacted during renovation/demolition that are identified as containing lead. C. Separation of Trades: Unprotected, untrained workers or trades shall not perform any related work within the same areas as demolition involving components identified as containing lead. Other trades may not enter these areas until clean-up procedures are completed STORAGE OF WASTE A. Use of waste and recycling containers on site shall be controlled under the following requirements: 1. Location of waste and recycling containers on site shall be coordinated with the General Contractor, subject to Owner s/architect s approval. 2. Waste containers shall be lined with two layers of six-mil polyethylene sheeting, be solid, enclosed containers, locked and sealed at all times. This requirement applies to waste classified as hazardous based on TCLP testing. 3. General Contractor shall comply with all federal, state, and local regulations and ordinances regarding lead waste and recyclable storage. END OF SECTION LEAD-CONTAINING PAINT CONSIDERATIONS Section of 16

97 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA SECTION REMOVAL AND DISPOSAL OF POLYCHLORINATED BIPHENYLS PART 1 - GENERAL 1.01 GENERAL REQUIREMENTS A. Part A and DIVISION 1 of PART B are hereby made a part of this SECTION. B. Examine all conditions as they exist at the project prior to submitting a bid for the work of this SECTION. C. Refer to SECTION Alternate for work affecting this SECTION SCOPE OF WORK A. Sampling has determined that polychlorinated biphenyls (PCB) are present in select building materials, including at levels greater than 50 ppm (parts per million). B. The removal and disposal of building materials with PCBs is regulated by the Toxic Substance Control Act (TSCA) pursuant to Code of Federal Regulations 40 CFR 761. Building materials with PCB concentrations equal to or greater than 50 ppm are regulated as PCB Bulk Product Waste and building materials impacted by the PCB Bulk Product Waste with PCB concentration equal to or greater than 1 ppm are regulated as PCB Remediation Waste as defined by 40 CFR C. This SECTION establishes requirements for the removal, segregation, management, and disposal of: (1) PCB Bulk Product Waste in the form of select sealants (window surround caulk and window glazing compound), (2) PCB Remediation Waste in the form of select sealants, masonry and other wall surfaces impacted by PCB Bulk Product Waste and associated debris and Personal Protection equipment (PPE); and (3) Excluded PCB Product Waste in the form of sealants, paint and masonry. The Contractor shall furnish all labor, materials, services, training, insurance, and equipment as needed to complete removal of PCB containing materials and debris as indicated herein. The Contractor shall follow all Federal, State and local ordinances, regulations and rules pertaining to removal, storage, transportation and disposal of PCBs. D. The Brockton High School and Downey Elementary School contain PCB Bulk Product Waste that will be removed and disposed of in accordance with 40 CFR (a). E. The Brockton High School contains PCB Remediation Waste that will be managed under a Risk-Based Disposal Plan in accordance with 40 CFR (c). REMOVAL AND DISPOSAL OF POLYCHLORINATED BIPHENYLS SECTION of 15

98 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA F. The Downey School contains PCB Remediation Waste that will be remediated to PCB concentrations of 1 ppm or less under a Self Implementing Cleanup and Disposal Plan in accordance with 40 CFR (a). G. The tables below summarize where PCB Bulk Product Waste and associated PCB Remediation Waste has been identified to be managed under this SECTION based upon sampling performed through November Location All windows and storefronts within limits of work as shown on Drawings. Brockton High School PCB Bulk Product Waste / PCB Remediation Waste Material PCB Bulk Product Waste Interior and Exterior Window Glazing PCB Remediation Waste- Window and storefront units in direct contact with PCB Bulk Product Waste Window Glazing PCB Remediation Waste- Interior and Exterior Window Surround Caulk PCB Remediation Waste Interior and Exterior Textured concrete columns and precast concrete adjacent to PCB Remediation Waste Location All windows and storefronts within limits of work as shown on Drawings. Downey Elementary School PCB Bulk Product Waste / PCB Remediation Waste Material PCB Bulk Product Waste Exterior Window Glazing PCB Remediation Waste- Window and storefront units in direct contact with PCB Bulk Product Window Waste Glazing PCB Remediation Waste- Interior and Exterior Window Surround Caulk PCB Remediation Waste Exterior concrete slab on grade foundation and ground floor brick mortar H. The tables below summarize where Excluded PCB Product Waste has been identified based upon sampling performed through November These materials will only be handled if required by the work of other SECTIONS. Their management is not covered by TSCA. This information is provided to support proper waste management and Contractor s OSHA worker right-toknow obligations. REMOVAL AND DISPOSAL OF POLYCHLORINATED BIPHENYLS SECTION of 15

99 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA Brockton High School Excluded PCB Product Location Material Maximum Reported PCB Concentration (ppm) None None Downey Elementary School Excluded PCB Product Location Material Maximum Reported PCB Concentration (ppm) None None I. The Contractor shall be responsible for verifying all quantity estimates in preparation of their bids, including the location and conditions of all PCBcontaining materials to be abated and disposed of under this contract. No additional compensation and/or contract time shall be granted to the Contractor for failure to perform this requirement RELATED WORK A. SECTION Selective Demolition B. SECTION Asbestos Abatement C. SECTION Painting 1.04 DEFINITIONS A. United States Environmental Protection Agency (EPA): Agency responsible for implementing PCBs Manufacturing, Processing, Distribution in Commerce, and Use Prohibition, 40 CFR 761 ( TSCA ) Code of Federal Regulations (CFR). B. PCB Bulk Product Waste: Building materials (e.g. caulking and glazing) originally containing total PCBs at concentrations equal to or greater than 50 parts per million (ppm). C. PCB Cleanup Waste: Solid and liquid wastes generated during the cleanup of PCB Bulk Product Waste and PCB Remediation Waste. D. PCB Remediation Waste: Building materials with total PCB concentrations equal to or greater than 1 ppm or 1 ug/100 cm 2 that have become contaminated due to nearby PCB Bulk Product Waste. REMOVAL AND DISPOSAL OF POLYCHLORINATED BIPHENYLS SECTION of 15

100 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA E. Excluded PCB Product. Building materials found to contain < 50 ppm total PCBs and not impacted by a PCB Bulk Product Waste put in service prior to 1984 and as defined in 40 CFR F. Isolation Barriers: The construction of partitions, the placement of solid materials, and the plasticizing of apertures to seal off occupied workplace from surrounding areas and to contain PCB-containing dusts, liquids, materials, or debris in the work area. G. Uniform Hazardous Waste Manifest: The shipping document, required to be originated and signed by the waste generator, used to track and substantiate the disposition of PCB-containing waste material GENERAL REQUIREMENTS A. All PCB abatement work referenced herein shall be performed in accordance with a Health and Safety Plan (HASP) developed by the Contractor in accordance with OSHA regulations, including Hazardous Waste Operations and Emergency Response (HAZWOPER) or other approved equal standard, and any other applicable federal, state, or local regulations. All workers handling PCB-containing materials on-site will be 40-hour HAZWOPER trained or other approved training. B. Materials to be managed in accordance with this specification may also contain asbestos. The requirements for managing these contaminants is specified in SECTION in addition to those presented here. 1. This specifically applies to health and safety, work zone containment, work zone posting and waste storage, shipping papers, transportation and disposal. 2. When there is a conflict, the most stringent requirements shall apply. 3. When there is a conflict between the above SECTIONS and this SECTION regarding surface preparation (e.g. etching, drilling, cutting, sanding, washing or other activities that will generate dust or building debris) and waste management, the requirements of this SECTION shall prevail. This specifically pertains to any activity related to the demolition, cleaning and/or disturbance of PCB Bulk Product Waste and PCB Remediation Waste. C. The Contractor shall provide all personnel with PPE, protective clothing, and monitoring equipment consistent with the levels of protection required for each type of work. Workers shall wear, at a minimum, ½-face respirators with P100 filters, water resistant Tyvek-type suits with boot covers, rubber gloves and eye protection when removing PCB Bulk Product Waste and PCB Remediation Waste unless a job specific exposure assessment is performed to demonstrate that a reduction in PPE is appropriate. D. No chipping hammers, grinding or wire wheels will be used to remove PCB Bulk Product Waste or PCB Remediation Waste materials unless performed inside containment with HEPA attachments. E. All equipment and tools shall be provided to the Site free of contamination. The Owner prohibits from the Site any equipment that in his/her opinion has not been thoroughly decontaminated prior to arriving at the Site. Any decontamination of the Contractor's REMOVAL AND DISPOSAL OF POLYCHLORINATED BIPHENYLS SECTION of 15

101 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA equipment prior to arrival at the Site shall be at the expense of the Contractor. The Contractor is prohibited from decontaminating equipment on Site which is not thoroughly decontaminated upon arrival. F. The work area will be demarcated with caution tape and signage at a distance to keep unauthorized workers and visitors out of the work area. A tool drop zone and personal decontamination facility will be established contiguous to the work zone. A clean zone will be established along with waste stream pathways. G. When working on the interior or exterior of the Site buildings, containments and/or regulated areas will be required to be established for removal and cleanup of the sealants and associated materials. H. The Contractor shall provide all drums, overpack drums, storage containers and related products and materials required for collecting, storing, and transporting the PCBcontaining waste in compliance with MassDEP, EPA, and U.S. Department of Transportation (DOT) requirements. All drums shall meet the requirements of DOT 49 CFR 173. I. Do not proceed with exterior PCB-containing material removal if contaminants are capable of being airborne due to high winds or mobilized by precipitation REGULATORY REQUIREMENTS A. The work of this SECTION shall meet the applicable waste removal and disposal requirements under 40 CFR 761, and in accordance with other applicable federal, state, and local regulations, laws, codes, and ordinances governing the removal, handling, transportation, and disposal of materials managed under this SECTION, including EPA requirements. B. The Contractor shall obtain all federal, state and local permits required for the removal, handling, transport and disposal of materials managed under this SECTION. The Contractor shall adhere to all permit requirements. C. The Contractor shall document that the disposal facility(ies) proposed have all certifications and permits as required by federal, state and local regulatory agencies to receive and dispose of the materials managed under this SECTION. D. The following regulations are cited for the information and guidance of the Contractor. The list below is not all-inclusive; the Contractor shall be responsible for a thorough knowledge and full implementation of all requirements for removal, transportation, and disposal of the materials managed under this SECTION. 1. PCBs Manufacturing, Processing, Distribution in Commerce, And Use Prohibition, 40 CFR 761 (TSCA). 2. Hazardous Waste Operations and Emergency Response, Federal Occupational Safety and Health Act (OSHA), 29 CFR Safety and Health Regulations for Construction, OSHA 29 CFR Part General Regulations for Hazardous Waste Management, EPA, 40 CFR 260. REMOVAL AND DISPOSAL OF POLYCHLORINATED BIPHENYLS SECTION of 15

102 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA 5. Regulations for Identifying Hazardous Waste, Hazardous Waste Generators and Hazardous Waste Transporters, EPA, 40 CFR 261, 262 and Regulations for Owners and Operators of Permitted Hazardous Waste Facilities, EPA, 40 CFR Interim Status Standards for Owners and Operators of Permitted Hazardous Waste Facilities, EPA. 40 CFR Standards for Management of Specific Hazardous Wastes and Facilities, EPA, 40 CFR Interim Standards for Owners and Operators of New Hazardous Waste Land Disposal Facilities, EPA, 40 CFR Hazardous Materials Regulations Relating to Transportation, 49 CFR U.S. Department of Transportation (DOT). 11. Other Regulations Relating to Transportation, 49 CFR Subtitle B Parts U.S. Department of Transportation (DOT). 12. Publications, Practices for Respiratory Protection, z American National Standards Institute (ANSI). 13. Hazardous Waste Management, 310 CMR 30, Massachusetts Department of Environmental Protection. E. The following guidance documents are cited for the information and guidance. The list below is not all-inclusive. The Contractor shall be responsible for a thorough knowledge and full implementation of all requirements for removal, transportation, and disposal of the materials managed under this SECTION. 1. Contractors Handling PCBs in Caulk During Renovation; EPA, EPA-747-F Preventing Exposures to PCBs in Caulking Material; EPA, EPA, 747-F (September 2009) SUBMITTALS A. The following submittals are required for review and approval by the Engineer on/or before the Pre-Construction Meeting: 1. Signed certification stating they have read and understand and will agree and abide by these Technical Specifications, and if available, the conditions specified in the EPA Work Plan for this project; 2. Laboratory Certification: All laboratories that will be performing PCB analysis for the Contractor must supply signed certification that their analytical procedures comply with the requirements of PCB analysis by EPA Method 8082 with soxhlet extraction by EPA Method 3540C; 3. HASP: Developed in accordance with OSHA regulations, including HAZWOPER or equivalent standard, and any other applicable federal, state, or local regulations; 4. Licenses and Permits: Licenses and permits required for complying with any applicable federal, state and local laws, codes, policies and regulations in connection with the work outlined in this SECTION; 5. Waste Profiles: All waste profiles, applications and questionnaires, prior to forwarding them to the party requiring these documents; REMOVAL AND DISPOSAL OF POLYCHLORINATED BIPHENYLS SECTION of 15

103 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA 6. Materials Product Data: Coatings and Paint Submit manufacturer's technical information including color, paint label analysis, and application instructions for each material proposed for use. Provide information demonstrating that the coating /paint is suitable for the substrate to be coated and meets performance requirements as indicated herein. Provide material safety data sheets. 7. Work Plan: Include all pertinent information relating to the work outlined in this SECTION. i. Name(s), address(es), and contact(s) of subcontractors retained for the work outlined in this SECTION. ii. Detailed description of work activities and progress schedule for each phase of the work outlined in this SECTION. iii. Description of engineering controls and procedures used to minimize exposure to PCBs, and to mitigate migration of dusts and contaminants generated by work outlined in this SECTION. iv. Description of means and methods for removal and disposal of the PCBcontaining materials. v. Proposed methods of waste storage, disposal, and transportation. vi. Name(s), address(es), and contact(s) of hazardous waste transporter(s) that transport hazardous waste from the Site to a TSCA-approved disposal facility, including EPA identification number and proof of permit, license, or authorization to transport hazardous waste in all affected states. vii. Name(s), address(es), and contact(s) of disposal facility(ies), which accept materials containing less than 50 ppm of PCBs, and greater than or equal to 50 ppm of PCBs, and a letter of acceptance indicating that the facility will accept removed materials associated with the work outlined in this SECTION. B. Work Method Changes: Owner and Engineer approval is required for all modifications to methods, procedures, and design, which may be proposed by the Contractor. Any such modifications or substitutions to methods, procedures, or design shall comply with applicable regulations. Contractor shall submit the proposed modification or substitution for review and approval. C. In addition to the items required by other sections of the Contract Documents, the following submittals are required for final payment: 1. Waste manifests or other documents required to transport and dispose of the items identified in this SECTION. 2. Completion Report: Report that summarizes and documents the removal and disposal of all materials associated with activities outlined in this SECTION. This includes Certificates of Disposal for materials managed as PCB Bulk Product Wastes QUALITY ASSURANCE A. Remove PCB-containing sealants to allow for optimal adhesion of new sealants as applicable. REMOVAL AND DISPOSAL OF POLYCHLORINATED BIPHENYLS SECTION of 15

104 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA B. Prepare surfaces for encapsulation for optimal adhesion of encapsulant. C. Engineer will visually inspect areas of remediation to confirm adequate removal and have the opportunity to collect air samples, wipe samples and/or building material samples prior to installation of new materials or encapsulation COORDINATION A. Extend full cooperation to the Owner in all matters involving the use of the Site and Owner s facilities. At no time shall the Contractor cause or allow to be caused conditions, which may cause risk or hazard to the general public, or conditions that might impair safe use of the Site. B. Provide Site access to the USEPA, MassDEP or Owner agent upon request. C. Provide access for inspection to all work areas by the Engineer through all phases of the work. The Contractor shall provide all ladders, lifts (with trained operator) or other equipment necessary in order for the Engineer to perform inspection, sampling and approval work as outlined by this SECTION. D. Owner will prepare work plans in accordance with 40 CFR 761 for EPA review and approval. This SECTION has been developed to reflect anticipated requirements of EPA approved work plans. PART 2 - PRODUCTS 2.01 MATERIALS A. All materials and equipment proposed to be used on this project shall be subject to the acceptance of the Owner and Engineer. The Contractor shall comply with local, state and federal regulations pertaining to the selection and use of materials and equipment on this project. B. Warning Signs and Labels Work areas shall be properly demarcated and posted utilizing signs and labels in accordance with OSHA, TSCA and USDOT requirements. C. Fire retardant polyethylene sheet shall be in roll size to minimize the frequency of joints, with factory label indicating four (4) or six (6) mil thickness. D. Tape (or equivalent) capable of sealing joints in adjacent polyethylene sheets and for the attachment of polyethylene sheets to finished or unfinished surfaces must be capable of adhering under both dry and wet conditions. E. Containers for storage, transportation and disposal of PCB-containing waste material shall be impermeable and watertight. F. Air filtration devices and vacuum units shall be equipped with HEPA filters. REMOVAL AND DISPOSAL OF POLYCHLORINATED BIPHENYLS SECTION of 15

105 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA G. Coating/encapsulant shall be oleophobic and designed to adhere to the surface and not require recoating for at least 10-years.Coatings for all surfaces masonry shall be an elastomeric, epoxy or similar coating applied in at least two layers of contrasting colors. Refer to SECTION Painting for additional requirements; PART 3 - EXECUTION 3.01 ABATEMENT OF PCB-CONTAINING MATERIALS A. The Contractor is informed that the renovation will involve the disturbance of building components that contain PCBs. The intent of this SECTION is to identify for the Contractor where PCBs have been confirmed to exist and the applicable regulatory responsibilities the Contractor shall comply with in order to perform the renovation/demolition work and remediation of contaminated building materials. B. All PCB Bulk Product Waste shall be removed and PCB Remediation Waste shown on the Drawings shall be managed in accordance with 40 CFR 761. C. The removal of PCB Bulk Product Waste and management of PCB Remediation Waste shall be performed in accordance with the following minimal requirements: 1. Temporary fences, barriers or other controls shall be installed around the active work areas to establish the Construction Zone and keep the public out; 2. A Regulated Area shall then be established within the Construction Zone that demarcates the work area utilizing caution tape and appropriate signage; 3. The Regulated Area shall be established at a sufficient distance to keep nonauthorized personnel out of the work area; 4. Polyethylene sheeting shall be placed on the ground and secured to the Site building; 5. A remote decontamination unit shall be established directly adjacent to the Regulated Area ; 6. When working on the building exteriors: i. All doors, windows and/or vents located on the same side of the Site building and within fifty feet of where active abatement is taking place shall be closed and sealed with two (2) layers of six (6) mil polyethylene sheeting and duct tape; ii. All air conditioners and/or HVAC intakes located on the same side of the Site building and within 50 feet of where active abatement is taking place shall be shut off and sealed with six (6) mil polyethylene sheeting and duct tape; iii. Monitor interiors as work progresses. If based upon observations made as work progresses that dust is migrating to the Site building interior, work will be immediately suspended until corrective actions are implemented to control dust migration; 7. Remove sealant containing PCBs with hand tools, or power tools if under containment. 8. If it is required to drill holes into masonry surfaces to support setting new anchors where PCB Bulk Product Waste has been removed or material to be drilled into REMOVAL AND DISPOSAL OF POLYCHLORINATED BIPHENYLS SECTION of 15

106 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA is identified as PCB Remediation Waste, drilling shall take place using tools equipped with shrouds and HEPA vacuum dust collection systems. 9. All ground surfaces within the Regulated Area shall be cleaned of all sealant and associated debris. This shall include all sealant debris located on the ground prior to the start of the work as well as any material that was generated during the abatement; 10. All surfaces where PCB Bulk Product Waste sealants are removed shall be cleaned using HEPA vacuums and then double wiped with hexane (or other acceptable solvent) moistened cloths. This shall include the surrounding masonry surfaces and other media; 11. All removed sealants and associated debris shall be placed in double six (6) mil disposal bags and transported to the Waste Storage area for disposal. All wastes shall be removed from the Construction Zone at the end of each work shift; 12. All disposable tools, PPE, polyethylene sheeting and other materials shall be placed in six (6) mil disposal bags and transported to the Waste Storage area. All wastes shall be removed from the Construction Zone at the end of each work shift; 13. Remove all foreign material from abated areas that could interfere with adhesion of new sealant, including dust, paints (except for permanent, protective coatings tested and approved for sealant adhesion and compatibility by sealant manufacturer), oil, grease, waterproofing, water repellents, water, surface dirt, and frost; 14. Upon completion of the abatement, a visual inspection shall be performed by the Engineer to ensure all PCB-containing sealant and associated debris has been properly removed and surfaces prepared for coating, as applicable. The Engineer shall have the opportunity to collect building material samples as required by the EPA; and 15. Proceed with work only after unsatisfactory conditions have been corrected. D. At Brockton High School PCB Bulk Product Waste has impacted adjacent interior and exterior concrete columns and precast concrete and are to be managed as PCB Remediation Waste. The areas requiring management are shown on the Drawings. The following additional minimal requirements apply: 1. If area identified as PCB Remediation Waste is to be removed, it shall be managed as containing > than 50 ppm PCBs. 2. If area identified as PCB Remediation Waste is to remain, apply a double coating ( encapsulation ) system to concrete in accordance with the following minimal requirements. The coating limits are shown on the Drawings: i. After removal of PCB Bulk Product prepare surface for coating by removing loose paint and debris. If power tools will be used to prepare surface or there is the potential to generate dust, work shall occur in a containment; ii. If washing is required: a) Wash with a vacuumed attached pressure washer with a minimum 800 PSI at 1.5 gallons per minute and maximum 4,000 PSI at 12 gallons per minute. The attachment to the washer shall use a shroud and vacuum to collect wash water and result in no visual emissions; REMOVAL AND DISPOSAL OF POLYCHLORINATED BIPHENYLS SECTION of 15

107 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA b) Washing shall only take place after the existing sealant has been removed and the authorization has been granted by the Owner. The purpose of the surface preparation is to remove dirt, oil, and other materials adhered to the masonry surfaces to properly prepare the surface for the coatings application; c) A water tight catch basin shall be placed directly below the wash area as a secondary means of containment to control run off and over spray. The nearest down-gradient storm drain(s) (if any) shall also be covered using a flexible polyurethane drain cover to prevent wash water from entering the catch basin(s); d) Water usage and pressure will be minimized to the extent practicable to eliminate mist/vapors/overspray. Washing will not be conducted in high winds or freezing temperatures. Furthermore, Site personnel will ensure that no residual wash water drains into the collection basin and that wash water does not puddle or accumulate outside the collection basin; and e) The wash water will be stored in closed tanks or other approved container labeled as containing PCB wash water until disposal is arranged. Waste storage areas will be secured so that they are not accessible to the general public. E. At the Downey Elementary School PCB Bulk Product Waste has impacted adjacent exposed exterior slab on grade concrete foundations and brick mortar. These areas require additional cleaning. The area to be cleaned shall extend to 6-inches of either side of the existing window and storefront frames. The areas shall be cleaned using HEPA vacuums and then triple wiped with hexane (or other acceptable solvent) moistened cloths. F. Managing all wastes generated in accordance with 40 CFR 761, as detailed in Article 3.03 herein COATING APPLICATION A. A coating/encapsulant will be applied to surrounding surfaces as shown on the Brockton High School Drawings after adjacent PCB Bulk Product Waste is removed and surface prepared. B. After surface preparation, the additional PPE and training for handling PCB containing wastes is not required. C. The coating shall be oleophobic and designed to adhere to the surface and not require recoating for at least 10-years. D. Coatings for all surfaces masonry shall be an elastomeric, epoxy or similar coating applied in at least two layers of contrasting colors; E. If a clear sealant is required, it shall be applied in multiple applications until the product is observed to bead. REMOVAL AND DISPOSAL OF POLYCHLORINATED BIPHENYLS SECTION of 15

108 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA F. Performance: Once coating/encapsulant has cured, the Owner will collect representative wipe samples for PCB laboratory analysis. If a result is greater than 1 ug/100cm2, the area represented by the sample will be washed and the top coat reapplied in accordance with SECTION Painting. G. Refer to SECTION Painting WASTE MANAGEMENT A. All waste management will be in accordance with applicable local, state and federal regulations. All costs associated with handling, transport and disposal of all waste material generated on this project shall be borne by the Contractor. B. The Contractor is responsible for ensuring that all wastes are reduced in size to meet final waste disposal facility requirements and obtaining additional data that the waste disposal facility may require to accept waste, except as noted in this SECTION. C. The wastes generated during the work shall be classified as follows: 1. PCB Bulk Product Waste: All wastes known or assumed to have PCB content equal to or greater than 50 ppm. Includes all materials identified as PCB Bulk Product Waste, all PPE, containment materials and tools used during the abatement that are not decontaminated, all debris generated during preparation of areas identified as PCB Remediation Waste for coating, and if removed, materials identified as PCB Remediation Waste. i. Some materials also contain asbestos, as detailed in SECTION Asbestos Abatement. Refer to SECTION Asbestos Abatement for associated work requirements. ii. A Uniform Hazardous Waste Manifest is required for the removal from the premises, and disposal. iii. Waste containers shall be placarded as containing PCB Waste with markings meeting the EPA requirements of 40 CFR and iv. These wastes shall be disposed of in accordance with 40 CFR at a licensed facility that will receive and retain PCB Bulk Product Waste. 2. PPE and Containment Material can be managed in accordance with 40 CFR (a)(5). i. Wastes shall be properly containerized. Containers for this waste shall be labeled per 40 CFR and as Non-DOT, Non-RCRA Regulated Material. ii. These wastes shall be disposed of in accordance with 40 CFR (g)(6) at a permitted facility meeting the requirements of 40 CFR (b). 3. Decontamination and Wash Water. Water shall be decontaminated by filtration and disposed of in accordance with 40 CFR (b)(1) or, if not filtered, at a TSCA approved facility. Care should be taken to prevent stored water from freezing and impacting the container s integrity. There is no separate pay item for water management. REMOVAL AND DISPOSAL OF POLYCHLORINATED BIPHENYLS SECTION of 15

109 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA 4. Excluded PCB Product. This material may be managed by any permitted waste management facility as long as they are made aware of PCB levels in the materials they are to receive and their permit allows them to accept these types of materials. Note that some materials also contain asbestos, as detailed in SECTION Asbestos Abatement. Refer to SECTION Asbestos Abatement for associated work requirements D. Non-PCB containing materials shall be kept separate from PCB containing materials. With the exception that Excluded PCB Product can be comingled with demolition debris if the above requirements are met. E. All tools and equipment that cannot be decontaminated with a double wipe with a solvent wetted rag in accordance with 40 CFR (c) shall be managed in accordance with the waste category they were used for WASTE STORAGE A. A secure fenced area with proper signage will be constructed around the Waste Storage Area to restrict public access. 1. Waste container(s) shall be stored in accordance with (c) and labeled in accordance with CFR Access to containers shall be controlled via a fixed tarp. 2. When not in use, containers shall be closed by means to prevent water infiltration when not being loaded. 3. All waste containers shall be within a secured locked fenced area. 4. All solid waste containers shall be placed on-site at a location approved by the Owner. This area shall be placarded as containing PCB Waste with markings meeting the EPA requirements of 40 CFR and SHIPPING PAPERS A. A Uniform Hazardous Waste Manifest is required for removal from the premises, and disposal of materials categorized as PCB Bulk Product Waste in SECTION 3.03, unless an exemption from this required is obtained from the Massachusetts Department of Environmental Protection. 1. Each manifest, bill of lading, or other applicable documentation, shall note the truck registration number, state of registration, name of driver, and date of removal of material from the site. 2. The Contractor shall comply with the RCRA Hazardous Waste Manifest policies and is responsible for obtaining a temporary EPA Identification Number for the site. This includes providing a landline telephone number in accordance with the RCRA REMOVAL AND DISPOSAL OF POLYCHLORINATED BIPHENYLS SECTION of 15

110 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA regulations. One EPA Identification Number shall be used for all hazardous waste management associated with this SECTION. 3. The Owner will be designated as Generator and will sign all manifests and waste profile applications or questionnaires. B. All other materials shall be shipped under a straight bill of lading. C. The presence of asbestos and/or lead based paint in a waste may lead to more stringent shipping paper requirements. Refer to appropriate SECTIONS for these materials shipping paper requirements. D. A copy of all shipping papers demonstrating waste s final disposition shall be provided to the Owner TRANSPORT OF CONTAMINATED MATERIAL A. No contaminated materials shall be transported off-site until all disposal facility documentation has been received, reviewed, and accepted by the Owner. B. All hauler(s) shall be licensed in all states affected by transport. C. The Contractor shall be responsible for inspecting the access routes for road conditions, overhead clearance, and weight restrictions, and shall provide traffic control when needed. D. The Contractor shall be responsible for any and all actions and costs necessary to remedy situations involving material spilled in transit or debris, mud and dust tracked offsite. This cleanup and other ancillary activities shall be accomplished at the Contractor s expense. E. Trucks and containers shall be covered during transport as required by applicable law SPILL RESPONSIBILITY A. The Contractor is solely responsible for any and all spills or leaks during the performance of work under this contract, which occur as a result of or are contributed to by the actions of its agents, employees or subcontractors. Such spills or leaks shall be cleaned to the satisfaction of the Owner or its representative, and in a manner that complies with applicable federal, state and local laws, codes, policies and regulations. The spill cleanup shall be at no cost to the Owner. B. The Contractor shall report all such spills or leaks, regardless of their quantity, to the Owner immediately upon discovery. A written follow-up report shall be submitted to the Owner as soon as possible, but not later than 24 hours after the initial telephone report. The written report shall be in narrative form and, at a minimum, include the following: 1. Description of item spilled (including identity, quantity, manifest number, etc.); REMOVAL AND DISPOSAL OF POLYCHLORINATED BIPHENYLS SECTION of 15

111 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA 2. Exact time and location of spill, including a description of the area involved; 3. Containment procedures initiated; and 4. Description of cleanup procedures employed or to be employed, including location of disposal of spill residues, and corrective measures to prevent recurrences. F. DECONTAMINATION PROCEDURES A. General: Furnish labor, materials, tools, and equipment for decontamination of all personnel, equipment and supplies that enter the contaminated work area or are exposed to contaminated material. Provide equipment and decontamination pads, etc. necessary for the decontamination of equipment and personnel. B. Materials that contain PCBs shall meet the decontamination requirements specified herein. C. Equipment and Tools Decontamination: The decontamination procedure shall follow the requirements of 40 CFR (c) (2), decontamination via a wiping or double wash/rinse with an approved solvent. Equipment and tools that cannot be decontaminated will be managed as: 1. Contaminated materials with PCBs < 50 ppm if all sludges within or adhered to equipment or tool, dusts and bulk sealant material is removed; and 2. Containing PCBs >/= 50 ppm if all sludges within or adhered to equipment or tool, dusts and bulk sealant material cannot be removed. D. Personnel Decontamination: Provide and maintain a decontamination area which is to be located in the contamination reduction zone. Coordinate the location of the decontamination area with the Engineer. Decontamination of personnel and equipment is required after performance of activities in the exclusion zone. The personnel decontamination area may be in the form of a mobile trailer or field station. Personnel decontamination shall, at a minimum, consist of: decontamination before breaks and each time workers exit the exclusion zone, and at the completion of each work day to prevent worker exposure and the spread of contaminants off site. E. Emergency Decontamination: Should a worker be splashed with contaminants, the worker shall be immediately escorted to the field decontamination station and decontaminated in accordance with the HASP. Site eye wash and shower stations shall be made available and operable. END OF SECTION REMOVAL AND DISPOSAL OF POLYCHLORINATED BIPHENYLS SECTION of 15

112 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA *SECTION PAINTING *(Files Sub-Bid Required) PART 1- GENERAL 1.01 GENERAL REQUIREMENTS 1.02 FILED SUB- BIDS T1.0, T1.1 for the Downey Elementary and Brockton High Schools, AD1.2, AD1.2, AD2.1, AD2.2, A1.1, A1.2, A2.1, A3.1 for Downey Elementary School and AD1.1, AD1.2, AD2.1, AD2.2, AD3.1, AD3.2, A1.1, A1.2, A2.1, A2.2, A2.3, A3.1 and A3.2 for Brockton High School SCOPE OF WORK

113 1.04 SUBMITTALS Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA

114 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA 1.05 PRODUCT DELIVERY, STORAGE AND HANDLING 1.06 ENVIRONMENTAL CONDITIONS 1.07 PROTECTION AND STORAGE PART 2-PRODUCTS 2.01 GENERAL

115 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA 2.02 MATERIALS PART 3 EXECUTION 3.01 ACCEPTANCE OF THE SURFACES

116 3.02 PREPARATION Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA 3.03 APPLICATION

117 Green Repair Program Window Replacement Downey Elementary and Brockton High Schools Brockton, MA G EXTERIOR PAINT SYSTEM SCHEDULE 3.05 INTERIOR COATING SCHEDULE END OF PAINTING

118 Request for Approval of TSCA Risk-Based Clean-up of PCBs Brockton High School Brockton, Massachusetts April 9, 2012 Appendix D Abatement Contractor Workplan ATC ASSOCIATES INC.

119 ASBESTOS / PCB PROJECT SUBMITTALS Brockton High School & Downey Elementary - Window Replacement Brockton, Massachusetts April 3, 2012 (Rev. 4/12/12) Safe Environment of America, Inc. 100 Moody Street, Suite 200 Ludlow, MA Tel. (413) seofa@aol.com

120 Brockton High School & Downey Elementary - Window Replacement Asbestos / PCB Submittals TABLE OF CONTENTS DISCLAIMER, RIGHTS & SIGNATURES ASBESTOS SUBMITTALS (SECTION ) 1.05 B. 1. Notifications, permits, worker/contractor licenses, etc B. 2. List of Employees 1.05 B. 3. Employee Medical Records (OSHA) 1.05 B. 4. Respirator Fit Tests 1.05 B. 5. Certificate of Insurance 1.05 B. 6. Written Respirator Program 1.05 B. 7. Proposed Alternative Methods 1.05 B. 8. Proposed Electrical Safeguards 1.05 B. 9. Equipment List 1.05 B. 10. Chain of Command 1.05 B. 11. Proposed Emergency Plan 1.05 B. 12. Employee Exposure Monitoring Lab 1.05 B. 13. Schedule of Values Appendices/Documentation PCB SUBMITTALS (SECTION ) 1. Certification 2. Laboratory Certification 3. HASP 4. Licenses and Permits 5. Waste Profiles 6. Materials Product Data 7. Work Plan & Waste Disposal Appendices/Documentation Safe Environment of America, Inc.

121 Brockton High School & Downey Elementary - Window Replacement Asbestos / PCB Submittals DISCLAIMER, RIGHTS & SIGNATURES This document and all its contents are considered proprietary information, developed under private expense, and has been prepared for the exclusive use of the project constituents in association with the Brockton High School & Downey Elementary School Window Replacement project for asbestos and PCB-containing caulk removal work by Safe Environment of America, Inc. Photocopying of this document, or any sections or parts contained therein, and the contents are not to be disclosed to third parties without prior written consent of Safe Environment of America, Inc. Use of this document for purposes other than it is intended, is prohibited. SUBMITTED BY: Safe Environment of America, Inc. Todd Scyocurka, President 4/12/12 Date Signed (Revised Submittal) Safe Environment of America, Inc. 1

122 Brockton High School & Downey Elementary - Window Replacement Asbestos / PCB Submittals 1.05 B. 1. Notifications, permits, worker/contractor licenses, etc. See documentation attached in the appendices. State agency Notification pending B. 2. List of Employees To be submitted at a later date B. 3. Employee Medical Records (OSHA) See documentation attached in the appendices B. 4. Respirator Fit Tests See documentation attached in the appendices B. 5. Certificate of Insurance See documentation attached in the appendices B. 6. Written Respirator Program Safe Environment has a current, up to date written respirator program and will be maintained on the job site at all times. This program is specific to Safe Environment for the health and safety of our employees and for compliance with applicable regulations, and therefore is not subject to any changes by any unauthorized individuals, and may only be amended by Safe Environment s Respirator Program Manager at his/her discretion. We have included a copy of the cover page and table of contents of this program for documentation and verification purposes. See documentation attached in the appendices B. 7. Proposed Alternative Methods To the best of our intentions, there are no alternate procedures, methods, or equipment proposed to be utilized that differ from the specifications or manufacturer s specifications B. 8. Proposed Electrical Safeguards Lock-out-Tag Out The scope of the electrical isolation and protection work includes isolation and protection of electrical equipment that is in the area from which asbestos must be removed, and could therefore possibly become a hazard through contact or water spray short-circuiting. Shutdown of electrical circuits shall be performed by the owner and/or the general contractor per the project specifications; the owner shall provide temporary power in accordance with applicable local codes and regulations. Contractor will provide a "Lock Out" system on all electrical panels or equipment that will be shutoff during the removal process, where applicable. The electrical isolation work also includes the shutdown of lighting and power circuits in the affected areas and installation of temporary lighting and power with ground fault protection circuitry in 1 Safe Environment of America, Inc.

123 Brockton High School & Downey Elementary - Window Replacement Asbestos / PCB Submittals accordance with applicable codes. Contractor will provide temporary lighting where necessary or applicable. Work from the exterior will be supported by Safe Environment using portable generators. Electrical Safety Program Safe Environment has a current, up to date written Electrical Safety Program. This program is specific to Safe Environment for the health and safety of our employees and for compliance with applicable regulations, and therefore is not subject to any changes by any unauthorized individuals, and may only be amended by Safe Environment s Electrical Safety Program Manager at his/her discretion. We have included a copy of the cover page and table of contents of this program for documentation and verification purposes. See documentation attached in the appendices B. 9. Equipment List Euroclean Gd 930hsp 4 Gallon Dry Hepa Vacuum Hepa-Aire Model H2000hpa Teleshower Model S5000et Telescoping Shower Euroclean Wet And Dry Hepa Vacuum, Hazardous Dust Cleanup, Wd260-H North 5500 Series Half Mask Air-Purifying Respirator, Niosh Certified North 76008a Full Face Respirator Omnigaurd Iii Differential Pressure Recorder Airless Power Sprayer-Electric-Lp400 Carry Frame Aerospace 2 Stage Shower Pump 9115 Water Filtration 5 Micron Pump Filter Flex Duct Wire 12"X25' Section C Watt Honda Generator Industrial First-Aid Kwik Kit Klein-Lite Fall-Arrest Harness Tyvek Coveralls, Dppty122swhxl00, Ty122swhxl00, White Size Xl Zip 16" Tall Steel Toe Rubber Work Boots Glove Cotton Canvas, Rad / Msa V-Gard Hardhats Mi-T-M Ca mhb - Ca Series 2700 Psi 6.5 Hp Honda Ohv Cold Water Gasoline Pressure Washer Model Panel Mount Gfci 120v/ 15a, 20a Solo 3-Gallon Sprayer On Wheels Chapin Poly Tank Sprayer (27092) 6 Mil 33"X50" Black Asbestos Disposal Bags With Printed Warning Label 30 Gallon Fiber Drum - Open Head, Locking Lid, Stock No: T9a Safe Environment of America, Inc. 2

124 Brockton High School & Downey Elementary - Window Replacement Asbestos / PCB Submittals 1.05 B. 10. Chain of Command PROJECT MANAGER/SUPERINTENDENT Todd Scyocurka On-Site Supervisor Todd Scyocurka Admin./Clerical Sarah Burek Subcontractors Transport/Landfill Worker Zac Nadaud Worker Ken Humiston Worker Albino Salvador 1.05 B. 11. Proposed Emergency Plan A. All safety precautions, procedures and locations of emergency access and exits will be coordinated by the Contractor and the Owner s duly authorized representative, before the beginning of any work, where applicable or required. B. The Contractor will establish emergency and fire exits from the work area for the workers. Any emergency exits which must pass through a work area will be equipped with two (2) full sets of protective clothing and respirators at all times. C. Seriously injured personnel will be treated immediately in the work area or evacuated without performing decontamination. When an injury occurs, the Contractor will stop work and implement fiber reduction techniques; (e.g., water spraying) until the injured person has been removed from the work area. The owner s duly authorized representative will be notified in the event of an injury. No specific or special arrangements have been made or expected to be made with local health, fire, ambulance, or hospital authorities. For emergencies, 911 will be used. The nearest local hospital is: Hospitals/medical centers near work area: Brockton Hospital 680 Centre Street Brockton, Massachusetts 3.1 mi NE (508) Safe Environment of America, Inc. 3

125 Brockton High School & Downey Elementary - Window Replacement Asbestos / PCB Submittals 1.05 B. 12. Employee Exposure Monitoring Lab EMSL Analytical 4 Fairfield Blvd, Wallingford, CT, Phone: (203) , Fax: (203) See documentation attached in the appendices B. 13. Schedule of Values To be submitted at a later date. Safe Environment of America, Inc. 4

126 Brockton High School & Downey Elementary - Window Replacement Asbestos / PCB Submittals PCB SUBMITTALS (SECTION ) 1. Certification Safe Environment of America, Inc. has read and understands and agrees and will abide by the Technical Specifications, and where applicable, the conditions specified in the EPA Work Plan for this project. 2. Laboratory Certification All laboratories that will be performing PCB analysis for Safe Environment will comply with the requirements of PCB analysis by EPA Method 8082 with soxhlet extraction by EPA Method 3540C. We intend to utilize Con-Test analytical, East Longmeadow, MA. 3. HASP See attached. 4. Licenses and Permits Not applicable. 5. Waste Profiles Safe Environment will provide all waste profiles, applications and questionnaires, prior to forwarding them to the transporter and disposal site 15 days prior to the first shipment that the waste may contain PCB s greater than 50 PPM in accordance with 40 CFR The letter will be acknowledged via a disposal facility s representative, including signature and printed name and title. A sample Waste Profile Sheet is included in the Appendices. 6. Materials Product Data For Coatings and Paint - this is the responsibility of the painting filed sub-bidder. 7. Work Plan A. Work Areas/Containments A means of providing containment areas will be established based on the planned project sequencing and access requirements for the work areas, and will generally follow the General Contractor s work schedule. We anticipate several individual work areas of manageable, sufficient size to accommodate the work schedule. B. Locations and Types of Containment/Decontamination facilities Containment will include polyethylene sheeting on the interior side of the window opening and poly sheeting extending out from the building as specified. Windows in most cases require disassembly in order to be removed from the window opening, and Safe Environment will 5 Safe Environment of America, Inc.

127 Brockton High School & Downey Elementary - Window Replacement Asbestos / PCB Submittals perform this from mini-containments and/or regulated areas on the exterior of the building. Any mechanical cutting or abrading will be performed within a negative pressure enclosure and/or local exhaust HEPA filtration. Containment areas will be located based on the planned project sequencing and access requirements for the work areas, and will generally follow the General Contractor s work schedule. A remote decontamination area for personnel and equipment will be erected within close proximity to each work area exit point. C. Work Area Entrances/Exits A single access point will be used for entrance and exit to the work areas. Locations of entrances/exits will be contiguous to each work area, and may consist of a single change room of sufficient size for workers to change clothing in preparation for entry into the remote decontamination facility. D. Remediation Activity/Technique Prior to initiating the removal of any of the caulking or materials, the following site controls will be implemented: A Health & Safety Plan will be developed specific to the work activities (attached). All workers will follow applicable Federal and State regulations regarding the work activities, including but not limited to OSHA regulations, fall protection standards, respiratory protection, ladder/scaffolding safety, personal protective equipment, etc. The use of local exhaust HEPA vacuum filtration will be incorporated to control dust and odors that are generated during the remediation activities. Within each work area, a second control area may be constructed surrounding each of the removal areas. The use of local exhaust HEPA vacuum filtration will be incorporated to control dust generated during the removal activities. Wet wiping and water misting will be used as a dust suppressant as appropriate. Access to the active work areas will be controlled in a manner determined by the onsite Supervisor to meet project requirements and access needs. All powered tools will be equipped with appropriate tool guards and dust/debris collection systems (i.e., HEPA filters), where required by applicable regulations. Wet wiping and vacuuming of all tools and equipment in each work area will be performed at the completion of the work activity. To reduce dust levels and exposures to dust, a combination of engineered controls (e.g., work zone areas), equipment equipped with HEPA filters and dust controls, and personal protective monitoring plan may be included. Additional notifications and plans required for the work activities may also be prepared and submitted for approval, as needed. Safe Environment of America, Inc. 6

128 Brockton High School & Downey Elementary - Window Replacement Asbestos / PCB Submittals Caulking Removal (> 50 PPM) The following summarizes the activities to be conducted as part of this removal task: All work surfaces will be wetted to minimize dust during caulking removal. Window/Door Unit and Sealant Removal The window and door units and associated surround caulk will be removed per Section 3.01 of the Technical Specifications Section After the surround caulk is removed, the work area will be HEPA vacuumed and surrounds within 6-inches of either side of the caulk joint will be double-wiped (Downey Elementary triple-wiped) down with a hexane, or other appropriate solvent, wetted rag. Safe Environment will have the option to manage the window/door units as a system and therefore as a PCB Bulk Product Waste, or to fully remove the glazing and caulking from the window and glass and the area where these sealants are present decontaminated. If the windows are dissembled, the glazing will be managed as PCB Bulk Product Waste and asbestos-containing material, the surround caulk as a PCB Remediation Waste with a PCB concentration >/= 50 ppm and the remaining material as demolition debris. Prior to disposal as demolition debris, the glass and metal frames will then be double-wiped with a hexane, or other suitable solvent, rag and visually inspected to confirm that all sealants are removed. If required by the U.S. EPA, representative confirmatory wipe sampling will be conducted by Safe Environment. Please be advised that these window systems are extremely large and will need to be disassembled in order to be removed from the window openings, and further reduced within a separate Conex box-style containment with negative air filtration and attached, contiguous decontamination unit (located within fenced in area adjacent to asbestos/pcb containers/trailers), so that the components fit into the required waste packaging in order to meet the requirements of the landfill. Upon the completion of the initial removal activities, the remaining substrates will be visually inspected for the presence of any residual caulking. Given that the caulking is visually apparent, this visual inspection will be the primary verification method for the caulking removal. If residual caulking is observed, then any residual caulking will be removed from the adjacent masonry substrates using a combination of mechanical and physical means until the residual caulking has been removed to the maximum extent practical. E. Sequence of Work The sequence of work will be based on the planned project sequencing and access requirements for the work areas, and will generally follow the General Contractor s work schedule. We anticipate several individual work areas of manageable, sufficient size to accommodate the work schedule. Safe Environment of America, Inc. 7

129 Brockton High School & Downey Elementary - Window Replacement Asbestos / PCB Submittals F. Products/Equipment/Materials Work clothes may consist of PPE as required by OSHA regulations, including, but not limited to the following: Disposable coveralls Gloves (Disposable rubber gloves may be worn under these) Disposable foot covers (polyethylene) Chemical safety goggles Half mask cartridge respirator Spill Kit 1. Disposable gloves (polyethylene) 6 prs 2. Gloves with a high degree of impermeability to PCB 6 prs 3. Disposable coveralls with permeation resistance to PCB 4 ea 4. Chemical safety goggles 2 ea 5. Disposable foot covers (polyethylene) 6 prs 6. PCB Caution Sign: "PCB Spill Authorized Personnel Only" 2 ea 7. Banner guard or equivalent banner material 100 feet 8. Absorbent material 9. Blue polyethylene waste bags 5 bags 10. Cloth backed tape 5 ea 11. Area access logs, blank 1 roll 12. Brattice cloth, 2 6 x 6 10 ea 13. Rags 1 piece 14. Ball point pens 20 ea 15. Herculite, 4 x4 2 ea and 8 x8 1 ea 16. Blank metal signs and grease pencils 17. Waste containers 55 g 2 ea drum, may be used as container for kit G. On-site Waste Storage Facilities Temporary on-site waste storage facilities will consist of a 100-yard lockable trailer. Reduced components will be placed in 3 x3 x3 Gaylord boxes, lined with 10-mil poly liners. Barrels, if used, will be metal 55-gallon drums. Frame components, if not cleaned, will be wrapped with two layers 6-mil polyethylene sheeting. The trailer will be located within the fenced-in construction area. Security for the trailer includes the lockable trailer (asbestos and PCB waste) with a padlock.. H. Utility Connections It is anticipated that the General Contractor will provide temporary utilities such as electrical power to the work areas and also to ensure continued services to the buildings. I. Waste Transport Routes Waste transport routes will be directly from the designated containment work areas to the asbestos/pcb remediation contractor s temporary waste transport vehicle or a designated rolloff waste receptacle, placed at locations within close proximity to the work areas and in such Safe Environment of America, Inc. 8

130 Brockton High School & Downey Elementary - Window Replacement Asbestos / PCB Submittals location as not to disrupt ongoing operations and services or other trades, and shall be located in locations to prevent potential exposure to the general public and other unauthorized tradesmen working at the site. Waste Transporter information is as follows: RED TECHNOLOGIES 10 NORTHWOOD RD BLOOMFIELD, CT J. Waste Disposal Facilities PCB waste will be disposed of at waste disposal facilities in accordance with 40 CFR Part 761 and/or 310 CMR The final waste disposal site will be the following: Minerva Enterprises Inc 9000 Minerva Road Waynesburg, OH (330) The 2 nd disposal facility for this project is Wayne Disposal, Inc. and any waste that cannot be accepted by Minerva (above) will be sent to Wayne Disposal, Inc. in Michigan: Wayne Disposal Inc. (WDI) Site # North I-94 Service Drive Belleville, MI T: (800) F: (800) fax EPAID# MID Permits and license information is provided in the appendices. Additionally, disposal of PCB-containing waste materials to be handled in accordance with the following: Request for Approval of TSCA Risk-Based Clean-up of PCBs under 40 CFR 761 Brockton Public Schools Green Repair Program Brockton High School 470 Forest Avenue Brockton, Massachusetts ATC Project No March 30, 2012 Safe Environment of America, Inc. 9

131 Brockton High School & Downey Elementary - Window Replacement Asbestos / PCB Submittals Safe Environment understands that such plan has not yet received EPA approval and will make a reasonable attempt to comply with its contents, as we have not seen the final approved plan as of the date this submittal is prepared. Safe Environment of America, Inc. has no control over the Health & Safety operations of the ultimate waste disposal site. See documentation attached in the appendices. Safe Environment of America, Inc. 10

132 Brockton High School & Downey Elementary - Window Replacement Asbestos / PCB Submittals Limited Site Health & Safety Plan Polychlorinated Biphenyls (PCB s) Brockton High School & Downey Elementary - Window Replacement INTRODUCTION Where applicable, Safe Environment of America, Inc. (SEA) workers will perform the following minimum tasks: All employees assigned to this project will have appropriate awareness and hazard communication training for PCB s. Use engineering controls including HEPA vacuums to aide in the cleanup of debris. Use work practices involving wet cleaning methods to aide in the cleanup of debris. Install HEPA-filtered negative air filtration machines and critical barriers in the work area. Install caution tape around the work area to restrict access. Install warning signs for PCB s. Use warning labels on the waste bag for PCB s. Wear half mask air-purifying respirators equipped with HEPA filters and organic vapor canisters. Wear full body disposable coveralls Perform initial employee exposure monitoring A. PCB S - 29 CFR (Gases, vapors, fumes, dusts, and mists) CHLORODIPHENYL (42% CHLORINE) CAS #: Synonyms: Aroclor 1242; PCB; Polychlorinated biphenyl CARCINOGEN (Ca); TWA applies to other PCBs Permissible Exposure Limit (PEL) TWA mg/m3: 1 Exposure Monitoring Prior to the performance of any construction work where employees may be potentially exposed to PCB s, SEA will establish the applicability of the OSHA standards by determining whether PCB s are present in the workplace and whether there is the possibility that employee exposures will be at or above the PEL. SEA has designated a competent person who shall make this determination. Competent Person: Todd Scyocurka PCB s have been determined to be present in the workplace, and it has been determined that it is unlikely the employee's exposure will be at or above the PEL, due to the small impact, nature, and shortterm duration of the planned work on this project, and therefore initial exposure monitoring is not required. SEA may, at our option, perform exposure monitoring for our own documentation and compliance purposes at our discretion, and if opted to perform such monitoring, determinations of employee exposure will be made from breathing-zone air samples that reflect the monitored employee's regular, daily 8-hour TWA exposure to PCB s; and eight-hour TWA exposures may then be determined for each employee on the basis of one or more personal breathing-zone air samples reflecting full shift exposure on each shift, for each job classification, in each work area. Safe Environment of America, Inc. 11

133 Brockton High School & Downey Elementary - Window Replacement Asbestos / PCB Submittals Exposure of SEA employees to inhalation, ingestion, skin absorption, or contact with PCB s at a concentration above those specified in the "Threshold Limit Values of Airborne Contaminants for 1970" of the American Conference of Governmental Industrial Hygienists, will be avoided. To achieve compliance with the TLV, administrative or engineering controls will first be implemented whenever feasible. When such controls are not feasible to achieve full compliance, protective equipment or other protective measures will be used to keep the exposure of employees to airborne PCB s within the limits. Any equipment and technical measures used for this purpose will be approved for each particular use by an industrial hygienist or other technically qualified person. Whenever respirators are used, their use will comply with 29 CFR Respiratory Protection Each person entering a regulated area will be supplied with and required to use a respirator. SEA will select, and provide to employees, the appropriate respirators specified in paragraph (d)(3)(i)(a) of 29 CFR SEA will provide HEPA filters for powered and non-powered air-purifying respirators. SEA will use the assigned protection factors listed in Table 1 of 29 CFR to select a respirator that meets or exceeds the required level of employee protection. Type of respirator 1, 2 Table Assigned Protection Factors Quarter Half mask Full mask facepiece Helmet/ hood Loosefitting facepiece 1. Air-Purifying Respirator Powered Air-Purifying Respirator , /1, (PAPR) 3. Supplied-Air Respirator (SAR) or Airline Respirator Demand mode Continuous flow mode ,000 25/1, Pressure-demand or other positivepressure mode , Self-Contained Breathing Apparatus (SCBA) Demand mode Pressure-demand or other positivepressure mode (e.g., open/closed circuit) Employee Information and Training , , SEA will train each employee who is potentially exposed to PCB s. SEA will institute a training program, ensure employee participation in the program, and maintain a record of the contents of the training program. Training will be provided prior to or at the time of initial assignment to a job involving potential exposure to PCB s and at least annually thereafter. SEA will provide instruction to all employees assigned to this project as to the hazards of mercury in conjunction with the Hazard Communication Standard, 29 CFR , including a review of a material safety data sheets or substance data sheet for barium. Safe Environment of America, Inc. 12

134 Brockton High School & Downey Elementary - Window Replacement Asbestos / PCB Submittals First Aid Eye: Irrigate immediately If this chemical contacts the eyes, immediately wash the eyes with large amounts of water, occasionally lifting the lower and upper lids. Get medical attention immediately. Contact lenses should not be worn when working with this chemical. Skin: Soap wash immediately If this chemical contacts the skin, immediately wash the contaminated skin with soap and water. If this chemical penetrates the clothing, immediately remove the clothing, wash the skin with soap and water, and get medical attention promptly. Breath: Respiratory support If a person breathes large amounts of this chemical, move the exposed person to fresh air at once. If breathing has stopped, perform mouth-to-mouth resuscitation. Keep the affected person warm and at rest. Get medical attention as soon as possible. Swallow: Medical attention immediately If this chemical has been swallowed, get medical attention immediately. Non-fire Spill Response: Keep material out of water sources and sewers. Build dikes to contain flow as necessary. Firefighting: Use foam, dry chemical, or carbon dioxide. Keep run-off water out of sewers and water sources. Reactivity: This compound is incompatible with the following: Strong oxidizers (NIOSH, 1997). Safe Environment of America, Inc. 13

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