Project-Specific Regulated Asbestos Contaminated Soil Management Plan

Transcription

1 March 27, 2018 Prject-Specific Regulated Asbests Cntaminated Sil Management Plan 39th Avenue Greenway Denver, Clrad Prepared Fr: City and Cunty f Denver 200 West 14th Avenue, Department 310 Denver, Clrad Pinyn Prject N.: 1/

2 March 27, 2018 Prject-Specific Regulated Asbests Cntaminated Sil Management Plan 39th Avenue Greenway Denver, Clrad City and Cunty f Denver 200 West 14th Avenue, Department 310 Denver, Clrad Pinyn Prject N.: 1/ Prepared by: Kristen Hill Clrad Asbests Building Inspectr #21592 Timthy Grenier, PE Clrad Asbests Building Inspectr #18029 Brian Partingtn Principal Prject Delivery

3 Table f Cntents Acrnyms... iv Definitins... v 1. Intrductin General Site Backgrund Purpse Key Parties and Respnsibilities Applicable Regulatins Prpsed Sil-Disturbing Activities Site Characterizatin... 5 Suspect Materials... 5 Suspect Asbests Bulk Sampling Required Training Site-Specific Training fr Site Persnnel Training fr Asbests Building Inspectrs & Air Mnitring Specialists Training fr Asbests Wrkers Training fr Cntractrs that are NOT Asbests Certified Health and Safety CABI & AMS Requirements General Cntractr Requirements General Cntractr and/r General Abatement Cntractr Requirements Ntificatins General Asbests-Cntaminated Sil Management Requirements Immediate and Interim Actins upn Discvery f Suspected RACS Site Access Cntrl Emissin Cntrl Plan Sil Wetting r Stabilizing Management f RACS t be Left in Place Stabilizing Suspected ACM Prcess Flw Nn-Asbests Cntaining Material Handling Prcedures Hand Remval f Minimal Suspected ACM upn Discvery Bulk Remval f RACS Establishing a RWA after Cnfirmed Discvery f RACS Engineering Cntrls Initial Minimum Cntrls Wind Break Barriers i

4 12.3 RACS Dispsal Prcedures Mechanical Remval/Disturbance f RACS frm a Regulated Wrk Area RACS Remval Quantities Off-Site Dispsal f RACS Wind Speed Mnitring Air Mnitring Air Mnitring Matrix Tables Persnnel Air Mnitring Required Preliminary and Area Air Sampling Prtcl Area Air Sampling Sampling Media Sample Analysis Respnse t Labratry Results RACS Stckpiling Stckpiling f RACS Transprting RACS t Stckpile Decntaminatin Prcedures Heavy Equipment r Machinery Decntaminatin Asbests Wrker Decntaminatin During RACS Disturbance in a RWA Decntaminatin and Persnnel Prtectin During Remval f ACM Wrk Area Clearance Clse-Out Reprt References Tables Table 1 Primary Cntacts and Rles... 3 Table 2 Respnsibilities... 4 Table - 3 Nn-Sil Debris Materials Encuntered at the Site... 6 Table - 4 Remval/Disturbance by Hand r Hand-Held Tls f Nn-Friable RACS that has nt been Rendered Friable Table - 5 Remval/Disturbance (by hand r hand-held tls) f Friable RACS Table - 6 Remval/Disturbance by Mechanical Means (Heavy Equipment) f Nn-Friable RACS Table - 7 Remval/Disturbance by Mechanical Means (Heavy Equipment) f Friable RACS ii

5 Attachments Attachment A Ntificatin f Planned Sil Disturbing Activity iii

6 Acrnyms AHERA Asbests Hazard Emergency Respnse Act ACM Asbests Cntaining Material AMS Air Mnitring Specialist AQCD Air Quality Cntrl Divisin BMP Best Management Practice CABI Certified Asbests Building Inspectr CDPHE Clrad Department f Public Health and Envirnment CSWR 5.5 Clrad Slid Waste Regulatins Sectin 5.5 Divisin CDPHE Hazardus Materials and Waste Management Divisin GAC General Abatement Cntractr GC General Cntractr GPS Glbal Psitining System HASP Health and Safety Plan HEPA High Efficiency Particulate Air mph Miles Per Hur NIOSH Natinal Institute fr Occupatinal Safety and Health NIST Natinal Institute f Standards and Technlgy NVLAP Natinal Vluntary Labratry Accreditatin Prgram OSHA Occupatinal Safety and Health Administratin PCM Phase Cntrast Micrscpy PLM Plarized Light Micrscpy Ply Plyethylene PPE Persnnel Prtectin Equipment PSRMP Prject Specific RACS Management Plan RACS Regulated Asbests Cntaminated Sil Reg. 8 Air Regulatin N. 8, Part B RWA Regulated Wrk Area TEM Transmissin Electrn Micrscpy iv

7 Definitins Adequately wet means sufficiently wet t minimize r eliminate visible emissins f dust and/r debris within the regulated wrk area and prevent the release f visible emissins frm leaving the regulated wrk area (RWA). The bservance f visible emissins, utside f the regulated wrk area, f dust and/r debris may be an indicatin that sils are nt adequately wet. Adjacent Receptr Zne means an area f uncntrlled access at a distance f 150 feet r less frm the nearest RWA bundary during active Regulated Asbests Cntaminated Sil (RACS) disturbance. Fr the purpse f this definitin, radways withut sidewalks, where nly vehicles are permitted, are cnsidered t be areas f cntrlled access and therefre nt adjacent receptr znes. Fr the purpse f this definitin, an area fr which access is nt rdinarily cntrlled that is clsed t the public during sil disturbing activities in the adjacent RWA is cnsidered t be an area f cntrlled access and therefre nt an adjacent receptr zne. Amended water means water t which a surfactant has been added. Air Mnitring Specialist (AMS) means a persn trained and certified, in accrdance with the requirements f Air Quality Cntrl Cmmissin Regulatin N. 8 (5 CCR , Part B) (CDPHE, 2008), fr the cllectin f air samples t determine airbrne particulate and/r asbests cncentratins. Asbests means the asbestifrm varieties f serpentine (chrystile), riebeckite (crcidlite), amsite (cummingtnite-grunerite), anthphyllite, actinlite, and tremlite. "Asbests-cntaining material (ACM) means any material that cntains mre than ne percent (1%) asbests by weight, area r vlume. Asbests-cntaminated sil means sil cntaining any amunt f asbests. Asbests Prject Designer r Prject Designer means a persn wh has been certified as an asbests Prject Designer in accrdance with Air Regulatin N. 8, Part B. Asbests Wrker means an individual certified under the Clrad State Regulatin N. 8, Part B t disturb, enclse, remve, and abate friable and nn-friable asbests cntaining material. Certified Asbests Building Inspectr (CABI) means a persn trained and certified in accrdance with Air Quality Cntrl Cmmissin Regulatin N. 8, (5 CCR , Part B), fr the identificatin f asbests cntaining materials and the cllectin f samples t determine asbests cntent inspectin and sampling, and wh has experience with a minimum f 40 hurs f experience n asbests cntaminated sil prjects n a minimum f three asbests-cntaminated sil prjects. Cnsultant refers t the entity cntracted t perfrm training, inspectins and air mnitring related t sil disturbing activities in accrdance with the PSRMP. CSWR 5.5 refers t Sectin 5.5 f the Clrad Slid Waste Regulatins (6 CCR , Sectin 5.5) Friable ACM means any material that cntains mre than ne percent asbests by weight, area, r vlume, and when dry can be crumbled, pulverized, r reduced t pwder by hand pressure. The term includes nnfriable frms f asbests after such previusly nn-friable material becmes damaged t the extent that when dry it can be crumbled, pulverized, r reduced t pwder by hand pressure as determined in the field by a CABI. v

8 General Abatement Cntractr refers t entity cntracted t perfrm asbests cntaminated sil disturbing activities in accrdance with the PSRMP. Mechanical means perated r prduced by mechanism r machine. This may include but shall nt be limited t, an excavatr, backhe, grader, tiller, auger, r hand shvel. Nn-Regulated Asbests Cntaminated Sil (Nn-RACS) means sil r debris that cntains nly: Intact nn-damaged, nn-friable ACM(s). Damaged nn-friable ACM(s) that d nt have a high prbability t release fibers based n the frces expected t act upn the material during disturbance as determined in the field by a CABI(s) thrugh a RACS Determinatin. The fllwing ACM(s) are predetermined t be Nn-RACS: Resin-based materials including but nt limited t phenlic-plastic (Bakelite), used in electrical and mechanical parts Resilient flring (vinyl, asphalt, rubber) excluding nn-tar impregnated friable felt backing n sheet vinyl flring (linleum) Tar impregnated r asphaltic materials in gd cnditin that have nt becme brittle Elastic, pliable, r rubberized materials, including but nt limited t: Pliable duct sealant Pliable fiberglass insulatin sealant Pliable fire-stp caulking /sealants Pliable windw and dr caulking Extremely hard materials, catings and sealants including but nt limited t: Labratry cuntertps and sinks Epxy-type Cncrete Masnry Unit (CMU) catings Epxy-type panel adhesive Duct sealant Ceiling tile adhesive Other ACM(s) as apprved by the Department at the request f the wner r persn disturbing debris, t nt have a high prbability t release fibers. Prject Specific Regulated Asbests Cntaminated Sil Management Plan (PSRMP) means a RACS management plan fr a single prject submitted in accrdance with CSWR 5.5 vi

9 Regulated Asbests Cntaminated Sil (RACS) means sil, ash r debris (plus six inches in all directins f surrunding sil r ther matrix material) cntaining: Friable ACM as determined in the field by a CABI thrugh a RACS determinatin; Previusly nn-friable ACM(s) that have been rendered friable as determined in the field by a CABI(s) thrugh a RACS determinatin. Nn-friable ACM(s) that have a high prbability f releasing fibers based n the frces expected t act upn the material during sil disturbance as determined in the field by a CABI(s) thrugh a RACS determinatin; deterirated nn-friable ACM(s) that are in pr cnditin resulting in a high prbability t release fibers due t weathering, histrical mechanical impact, fire damage (by evidence f ACM within an ash layer) r ther factrs as determined in the field by a CABI(s) thrugh a RACS determinatin. The fllwing brken, resized, r damaged ACM(s) are predetermined t be RACS: Asbests cement materials Plaster Brittle caulking, glazing and sealants Pwdery CMU sealant Pwdery flr leveling cmpund Drywall/wallbard and assciated jint cmpund material Firebrick Other material as determined by the Department, at the request f the wner r persn disturbing debris, t have a high prbability t release fibers. Sil r ash knwn t cntain nn-visible asbests based n dcumented evidence. Regulated Wrk Area (RWA) means the prtin(s) f the prject at which sil-disturbing activities invlving RACS will ccur. Fr asbests-cntaminated sil disturbance, Wrk Area als means the regulated/cntrlled area bundary. "Receptr Zne means area(s) f public where access is nt restricted within 150 feet f the bundary f a RWA being actively disturbed. Surfactant is a cmpund that lwers the surface tensin between tw liquids r between a liquid and a slid. Surfactants may act as detergents, wetting agents, emulsifiers, faming agents, and dispersants. Essentially, surfactants make water, wetter. Visible Emissins means any emissins which are visually detectable, withut the aid f instruments, cming frm material cntaining asbests, asbests waste, asbests-cntaminated sil, r frm handling and dispsal f asbests waste, material cntaining asbests r asbests cntaminated-sil. vii

10 1. Intrductin Pinyn Envirnmental, Inc. (Pinyn), has been cntracted by the City and Cunty f Denver (CCD) via the Denver Department f Public Health and Envirnment (DDPHE) t prepare this Prject-Specific Regulated Asbests-Cntaminated Sil (RACS) Management Plan (PSRMP) fr the 39th Avenue Greenway (prject) in Denver, Clrad in accrdance with the Site-specific Materials Management Plan (MMP; Pinyn, 2018a). The CCD s purpse f the prject invlves the cnstructin f strmwater infrastructure including an pen channel that when cmpleted will cnvey fldwater t the utfall at Glbeville Landing Park. This prject is an integral part f the Platte t Park Hill: Strmwater Systems prgram (P2P Prject). The P2P prject was created by CCD with the intentin t increase neighbrhd cnnectivity, imprve water quality, add new park and recreatin spaces, and prvide fld prtectin. The pen channel will be present alng East 39th Avenue frm apprximately Franklin Street t Steele Street (Site; MMP Figure 1). Infrastructure in ther areas, including alng East 39th Avenue between Blake Street and Franklin Street; East 39th between Steele and Jacksn; East 40th Avenue between Yrk Street and Claytn; Claytn Street between East 40th Avenue and just suth f East 42nd Avenue; Madisn Street between East 39th Avenue and East 40th Avenue; East 40th Avenue between Madisn Street and Mnre Street; and finally Mnre Street between East 40th Avenue and East 42nd Avenue; will be cnstructed in existing r new right f way in and alng city streets as new buried strm sewer. Bridges will als be cnstructed as part f the P2P prject. Pinyn has assisted the CCD in identifying prject regulated material risks fr the identificatin and management f regulated materials, particularly thse related t impacted sil. Pinyn previusly cmpleted evaluatins f ptential Recgnized Envirnmental Cnditins (RECs) fr the Mntclair and Park Hill cnveyance system cmpnents f the P2P prject. The details can be fund in Pinyn s Evaluatin f Histrical Uses and Ptential Recgnized Envirnmental Cnditins Platte t Park Hill Drainage Prject Mntclair Outfall reprt (REC reprt; Pinyn, 2016). The REC reprt findings resulted in subsurface investigatins t evaluate ptential impacts frm the identified RECs. The subsurface investigatin activities included test trench excavatins and subsurface sil samples at the Site. A summary f the envirnmental findings, per parcel, is prvided in Appendix A f the Materials Management Plan (Pinyn, 2018a). The investigatin findings related t RACS is incrprated int this PSRMP. 1.1 General Site Backgrund Histrically, buildings at the Site were razed in an era where asbests assessment and abatement were nt required (Pinyn, 2018a). Areas f cnstructin debris, remnant fundatins, r ther undcumented r uncntrlled filling have the ptential t cntain RACS (Pinyn, 2018a). Due t the ptential fr the Site t cntain RACS, Pinyn utilized trenches, als knwn as test pits, t evaluate buried materials at several lcatins n Site. Trenches were placed at Parcels 7, 8, 9, 11, 15, 13, and 19 (MMP Figure 1, Figure 2a, Figure 2b) t evaluate fr the presence f buried fill material, including building debris which may be asbests cntaining (Pinyn, 2018b). Sil and excavated material was visually evaluated by a Certified Asbests Building Inspectr (CABI) during excavatin. If suspect asbests r RACS was encuntered, a sample was cllected and submitted fr labratry analysis (Pinyn, 2018b). Trenches were excavated t ttal depths f five t eight feet belw the grund surface (bgs) (Pinyn, 2018b). Each trench was advanced apprximately ne ft belw the first bservatin f native sils (Pinyn, 2018b). Suspect asbests-cntaining material (ACM) was encuntered at seven f the parcels tested via trenches (Pinyn, 2018b). The cmpsitin f the debris was primarily f sil, with nn-sil cmpnents including: nnasbests cntaining brick and assciated grut, nn-asbests cntaining green shingle, and nn-asbests cntaining white fibrus material (Pinyn, 2018b). In additin t the nn-asbests cntaining debris, there was an ACM fabric cnnected t metal in Trench-02 f Parcel 9 (Pinyn, 2018b). Based n the prevalence f debris Denver, Clrad Page 1

11 at the Site, there is reasn t believe that mre ACM may be present in ther areas f the Site sil. A Materials Management Plan (MMP) has been develped fr the prject that addresses nn-asbests cntaminants that may be encuntered during cnstructin f the prject (Pinyn, 2018a). It is the intent f the DDPHE that the MMP and this PSRMP will be implemented cncurrently during cnstructin f the Site. Further subsurface evaluatins are planned fr the Site, pending land wner access. Updates will be presented in Appendix A f the MMP. 1.2 Purpse This PSRMP has been prepared t ensure cmpliance with the Clrad Slid Waste Regulatins CCR Part 1, Sectin 5.5 (CSWR 5.5; CDPHE, 2014), and prvides the prcedures fr identificatin, safe handling, dispsal, and transprt f ACM, nn-racs r RACS that may be encuntered during sil-disturbing activities related t the Site. Prvisins f CSWR 5.5, nt specifically referenced within this PSRMP must be fllwed. In the event f any disparity between the tw, CSWR 5.5 will supersede prvisins included within this PSRMP. This PSRMP has been prepared t minimize ptential delays, and t develp apprved standard prcedures that the general cntractr (GC), r where applicable, the General Abatement Cntractr (GAC), will implement as needed fr future sil-disturbing where ACM may be encuntered. These standard prcedures, nce apprved by the Clrad Department f Public Health and Envirnment (CDPHE), Hazardus Materials and Waste Management Divisin (Divisin), will satisfy the PSRMP regulatry requirements. Denver, Clrad Page 2

12 1.3 Key Parties and Respnsibilities The key parties, their cntact infrmatin and prject respnsibilities, are utlined belw: Table 1 Primary Cntacts and Rles Party Cntact Respnsibility Custmer Technical Assistance Line CDPHE Phne: Fax: Regulatry Agency David Ericksn Phne: David.Ericksn@denvergv.rg City and Cunty f Denver (CCD) Department f Public Health and Envirnment (DDPHE) Denver Department f Public Wrks Nrth Denver Crnerstne Cllabrative (NDCC) General Cntractr (GC) General Abatement Cntractr (GAC) Envirnmental Cnsultant If n immediate respnse, call Steve Cggins Phne: steven.cggins@denvergv.rg Andrew Rss Phne: Andrew.Rss@denvergv.rg Larry Walsh SEMA Cnstructin lwalsh@semacnstructin.cm TBD Tim Grenier Phne: ; Grenier@pinyn-env.cm Envirnmental Quality Technical Oversight Public Wrks Prject Manager NDCC Prject Manager (in crdinatin with DDPHE) Cnstructin RACS Abatement/Management MMP Supervisr, CABI, and if necessary Air Mnitring Specialist (AMS); discvery ntificatin t DDPHE prject manager and t CDPHE if apprved by DDPHE Respnsibilities fr key persnnel are summarized in Table 2, and discussed in detail in the PSRMP sectins nted. Denver, Clrad Page 3

13 Table 2 Respnsibilities Duties per PSRMP General Cntractr Prject Persnnel Subcntractrs CABI Air Mnitring Specialist (AMS) Prvide Awareness Training Sectin: 2 Receive Site Awareness Training (All Site Persnnel) Sectin: 2 Receive Annual Asbests Awareness Training (t enter any Regulated Wrk Area [RWA] during RACS disturbance) Sectin: 2 CABI Respnsibilities Sectin: thrughut PSRMP Handling, Disturbing, Remving ACM/RACS Sectin: 12 Decntaminatin f Equipment, Persnal Prtective Equipment (PPE) and RWA Sectin 12.7 Wind Speed Mnitring Sectin: 12.4 Air Mnitring Sectin: 12.5 Dcumentatin GAC 1.4 Applicable Regulatins The requirements f CSWR 5.5 apply t the wner r peratr f any prperty with RACS at which sildisturbing activities are ccurring r planned. The wner/peratr may chse t fllw the prcedures set frth in CSWR 5.5.1(A) and (B) when debris is expsed r disturbed t determine if the debris is RACS. Sildisturbing activities invlving nn-racs, where n RACS is present r generated, are nt subject t the requirements f CSWR 5.5, but nn-racs must be dispsed as nn-friable asbests waste in accrdance with the dispsal requirements set frth in Sectin 5.2 f the CSWR. 1.5 Prpsed Sil-Disturbing Activities Cnstructin fr the prject will include surface grading and excavatin f sil in areas with knwn debris and fill material. The general requirements fr handling nn-asbests materials are prvided in the 39 th Avenue Greenway MMP (Pinyn, 2018a). Sils that are t be reused must meet the sil reuse requirements. Suspect ACM bserved by the CABI during cnstructin will be assumed t be ACM, and will be handled accrdingly, unless labratry analysis prves therwise. Nn-RACS debris and RACS-cntaining debris will Denver, Clrad Page 4

14 be dispsed f at the Denver-Arapahe Dispsal Site (DADS) under prper waste prfile and manifest prcedures. The GC will need t crdinate btaining the waste prfile and manifests with CCD. 1.6 Site Characterizatin Test trench excavatins were cmpleted t investigate ptential ACM at the Site. Debris was fund in 12 f 21 trenches, and a ttal f 19 suspect ACM samples were cllected and submitted fr labratry plarized light micrscpy (PLM) analysis. The sampled materials are listed in Table 3. One f the materials lcated in Trench 02 f Parcel 9 (MMP Figure 2a) was fund t be ACM; the material was fabric n metal and cntained 85% Chrystile apprximately five feet belw the subsurface. Detailed descriptins f the suspect materials, phtgraphic lg, lab analytical reprt, and a map shwing the trench lcatins f the suspect materials can be fund in Pinyn s Phase II Investigatin Reprt (Grups A and B) (Pinyn, 2018b). In additin t the test trench excavatins, Pinyn cmpleted sil brings at the Site (Pinyn, 2018b). Tw sil brings (19-1 and 19-2 in Parcel 19; MMP Figure 2b) indicated subsurface debris was present in the Sites sil frm 0-3 feet bgs and 5-10 feet bgs in Parcel 19. Further investigatin is planned, as prperty access becmes available. The results will ultimately be presented under separate cver, and a summary will be included within Appendix A f the MMP. This PSRMP has been prepared t minimize ptential delays, and t develp apprved standard prcedures that the CABI will implement in the event that additinal sampling is fund t be necessary. These standard prcedures, nce apprved by the Divisin, will satisfy the requirements fr a PSRMP. Suspect Materials The fllwing table (Table 3) presents infrmatin n the nn-sil debris materials that have been identified at the Site, and have been fund t be ACM, Suspect ACM, r nn-acm. The crrespnding phtlg f the materials and the asbests labratry results fr the suspect materials are lcated in Appendix C and Appendix D f the Phase II Envirnmental Investigatin Reprt (Pinyn, 2018b). Denver, Clrad Page 5

15 Table - 3 Nn-Sil Debris Materials Encuntered at the Site Material Type Fabric frm metal Red Brick 1 Red Brick 2 Red Brick 3 White Brick Red Brick with Mrtar Brick Mrtar Brick with White Plaster Off-white fibrus material Green Shingle Misc. Descriptin ACM Gray pink fabric frm metal was taken frm Parcel 9 apprximately five feet belw grund surface. The sample cntained 85% Chrystile. Suspect ACM Red brick was encuntered at the Site; this red brick is ubiquitus in the Denver area. Pinyn has sampled this material numerus times, and the material des nt cntain asbests. Due t the vlume f brick encuntered, samples were cllected, and the material was cnfirmed t be a nn-acm. White brick was encuntered in Parcel 13; a sample was cllected, and the material was cnfirmed t be nn-acm. Red brick and assciated mrtar was encuntered in Parcel 9 and Parcel 15; this material is ubiquitus in the Denver area. Pinyn has sampled this material numerus times, and the material des nt cntain asbests. Due t the vlume f brick with mrtar likely t be encuntered, a sample was cllected, and the material was cnfirmed t be nn-acm. Brick mrtar was encuntered in Parcel 9; a sample was cllected, and the material was cnfirmed t be nn-acm. Off-white brick material with plaster was encuntered in Parcel 19 and did nt cntain asbests. Off-white fibrus material was encuntered in Parcel 13; a sample was cllected, and the material was cnfirmed t be nn-acm. Black tar with green granular material was lcated in Parcel 19. Sample was submitted fr lab analysis and did nt cntain asbests. Nn-Suspect ACM 1 Cal fragments/fines, ceramics, metal, glass, plastic, cncrete, wd, asphalt, metal, cans, and gravel, were identified buried at the Site, and are assumed t be a nnsuspect ACM and a slid waste. Ntes: 1 Nn-suspect ACM are listed in Table 5-1f Phase II Reprt (Pinyn, 2018b) ACM Asbests Cntaining Material As these materials have been previusly evaluated by a CABI, it is assumed that these determinatins may be adpted by the CABI during implementatin f this PSRMP. If new materials are identified in the future nt nted in Table 3, additinal sampling may be necessary t evaluate if asbests is present in the material. Further, if new materials are identified during subsequent subsurface investigatins r during the curse f subsurface wrk, and are determined nn-acm by the CABI, the CABI may apply that institutinal knwledge f Site cnditins and presume thse materials are als nn-acm. Suspect Asbests Bulk Sampling The CABI will be n-site n a full-time basis t visually classify RACS/Nn-RACS fr ff-site dispsal, and will initially evaluate the ptential fr ACM based n a visual assessment. In the event that suspect ACM is visually identified by the CABI, steps utlined in Sectin 8.1 will be implemented. The fllwing steps will be applied t sample and analyze ptential ACM identified by the CABI: Samples f suspect asbests material will be placed in apprpriate sample cntainers such as sample bags r jars. Denver, Clrad Page 6

16 Care shuld be taken t ensure that suspect asbests material is adequately wetted t prevent visible emissins during the sampling prcess. A field sampling frm r lg bk entry will be maintained fr each sample btained. The frm r lg bk entry will include the lcatin using a hand-held glbal psitining system (GPS) instrument, date and time f each sample, depth belw the grund surface the sample was identified, descriptin f the type f material, assessment f friability f the material, and ther bservatins made. Prper chain-f-custdy prcedures will be fllwed fr all samples cllected. Samples f newly discvered suspect asbests materials will be analyzed by a Natinal Vluntary Labratry Accreditatin Prgram (NVLAP)-accredited labratry by PLM methdlgy t determine if any asbests fibers are present. Denver, Clrad Page 7

17 2. Required Training As described in CSWR 5.5, persnnel verseeing, directing, inspecting, and/r handling asbests and ACM (including suspect asbests) must have prper training as discussed in the fllwing sectins. In additin, all persnnel inside the regulated wrk area (RWA) during the disturbance f RACS shall have annual asbests awareness training. 2.1 Site-Specific Training fr Site Persnnel Persnnel expected t enter the RWA during disturbance f RACS will receive Site-specific training by a CABI familiar with this PSRMP and the Standard Requirements f CSWR 5.5. This includes drivers f trucks carrying cntaminated material fr ff-site dispsal. The training will cver the prvisins f this PSRMP, as well as the fllwing: Backgrund f asbests, including health effects Overview f the requirements f CSWR 5.5 and its implementatin Recgnitin f debris in sil that may cntain asbests and which requires further evaluatin by a CABI Overview f RACS and Nn-RACS Cntrls and ntificatins t be fllwed when debris that may cntain asbests is encuntered The nature f peratins that culd result in expsure t asbests fibers Spill preventin and cntaminatin reductin techniques Prper use, handling, and dispsal f PPE Respiratry prtectin levels required fr varius activities and cnditins Engineering cntrls and ther measures t prevent cntact with cntaminants Engineering cntrls t prevent visible emissins frm leaving the RWA Persnnel and equipment decntaminatin and the establishment f decntaminatin statins Emergency prcedures Prject chain-f cmmand and identificatin f authrized persnnel with stp wrk authrity Hands n training specific t the sil disturbing activities the individual will be perfrming subject t CSWR 5.5. Recrds f this training will be retained by the CABI and CCD, and will be available fr inspectin fr the duratin f the prject fr which the training is cnducted. Denver, Clrad Page 8

18 2.2 Training fr Asbests Building Inspectrs & Air Mnitring Specialists The fllwing training is required fr persnnel acting as CABIs and/r Air Mnitring Specialists (AMSs) fr this prject: Individuals perfrming inspectin and identificatin f ACM in sil must have a current CABI certificatin in accrdance with Regulatin N. 8 r CSWR 5.5, and have a minimum f 40 verifiable hurs f n-thejb asbests in sils experience n a minimum f three different asbests in sils prjects. Individuals perfrming air mnitring must have a current AMS certificatin in accrdance with Regulatin N. 8. In additin, individuals with the ptential fr expsure t asbests fibers shuld be trained in the prper usage f PPE and have a current annual physical with a medical release/respiratr usage frm. Other training requirements that may be detailed in the MMP, and if applicable, the prject Health and Safety Plan (HASP), prepared by a Health and Safety Officer (HSO). 2.3 Training fr Asbests Wrkers In additin t the abve training requirements, it is required that persnnel verseeing, directing, inspecting, and handling/remving asbests (including suspect asbests) have the fllwing: Current EPA Asbests Hazard Emergency Respnse Act (AHERA) 32-hur Wrker, 40-hur GAC/Supervisr, r 24-hur Building Inspectr accreditatin Current EPA AHERA 8-hur refresher curse certificatin Current Clrad asbests certificatins fr the apprpriate discipline in relatin t this PSRMP Current annual physical with medical release/respiratr usage frm and respiratr fit test All required certificates and licenses shuld be in accrdance with the prvisins set frth in Regulatin N Training fr Cntractrs that are NOT Asbests Certified In regard t persns directly invlved in sil-disturbing activities n sites where there is knwn RACS r a reasn t believe RACS may be encuntered (which is the case fr the site): The training will address such tpics as histry and backgrund f asbests, identifying types f asbests, health effects, engineering cntrls, and actins t take when suspect asbests materials are encuntered. Individuals perfrming sil-disturbing activities in an area with asbests waste r RACS are required t cmplete awareness training in accrdance with the 2005 Occupatinal Safety and Health Administratin (OSHA) standards set frth at 29 CFR (d)(9)(vii). In additin, the individual is required t cmplete ACM training that prvides infrmatin necessary t perfrm their duties in a way that ensures cmpliance with the requirements f CSWR 5.5. Infrmatin shall including an verview f suspect ACM that requires further evaluatin by a CABI, verview f RACS and Nn-RACS, decntaminatin requirements, engineering cntrls and verview f RACS handling. Denver, Clrad Page 9

19 The training must be cnducted by a CABI certified in accrdance with Regulatin N. 8, and wh has a minimum f 40 verifiable hurs f n the jb asbests in sils experience n a minimum f three different asbests in sils prjects. This training requirement applies t equipment peratrs, but is nt required fr drivers f trucks carrying impacted material if they remain in the cab f their truck, with the windws rlled up and their air and heating systems turned ff. Hwever, it is recmmended that drivers cmplete an n-the-jb ACM awareness training. Denver, Clrad Page 10

20 3. Health and Safety There is a ptential fr increased risk t the health f wrkers during disturbance/remval f RACS. Awareness by site persnnel f these hazards is f the highest pririty. Therefre, a site-specific HASP will be develped by the GC prir t initiating cnstructin activities at the Site, as described in the MMP. Site persnnel will be prvided with a cpy f the HASP fr review, and will be required t sign a frm stating that they are aware f, agree t, and understand the requirements f the HASP. The GC will be required t emply the prper persnnel, and PPE t prvide a safe wrking envirnment fr its emplyees, cnsultants and subcntractrs. Denver, Clrad Page 11

21 4. CABI & AMS Requirements The fremst requirement f this PSRMP is that a qualified CABI (and an AMS if a RWA is required) be nsite n a full-time basis during all sil-disturbing activities, t physically bserve and mnitr the air and site cnditins and prvide infrmatin t the GC and/r GAC t help limit and avid asbests fiber release. The CABI and AMS can be the same persn if she/he meets the CABI and AMS requirements listed belw. Ideally, the CABI and AMS will be the same persn. The CABI(s) will be respnsible fr the fllwing: Be nsite n a full-time basis during all sil disturbing, excavatin, and lading activities. Identify if suspect ACM and RACS is being disturbed. Cmplete necessary sampling f suspect asbests in accrdance with Sectin f this PSRMP. Cmplete daily lgs, thrughly detailing site activities. Maintain all pertinent dcumentatin related t adherence f the plan, including sampling results, air mnitring data, waste manifests, phtgraphs, etc. Verify implementatin and adherence f the plan during excavatin f fill material at the Site. Inspect RWA after remval f RACS t evaluate whether remaining ACM is present n the surface. The CABI will have Stp Wrk authrity if it is believed that wrk is being perfrmed utside the guidelines f this plan r f CSWR 5.5, r if actins harmful t life and health are bserved; the CABI will nt be respnsible fr cnsequential damages fr any wrk stppage, including real r perceived harm, including lst prductivity, that may result. If bulk remval f RACS frm a RWA is required, the AMS(s) will be respnsible fr the fllwing: Be n site n a full-time basis during disturbance, excavatin, and lading f RACS. Mnitr RWA during remval and dispsal f RACS fr cmpliance f this plan. Place and mnitr air samples n site and arund RWA during sil disturbing activities. Mnitr and lg wind speed and directin during sil disturbing activities. The AMS will have Stp Wrk authrity if it is believed that wrk is being perfrmed utside the guidelines f this plan r f CSWR 5.5, r if actins harmful t life and health are bserved; the AMS will nt be respnsible fr cnsequential damages fr any wrk stppage, including real r perceived harm, including lst prductivity, that may result. Denver, Clrad Page 12

22 5. General Cntractr Requirements The GC will be respnsible fr cmpleting site cnstructin activities in accrdance with the site-specific MMP (Pinyn, 2018a). If ACM is encuntered in quantities less than 10 separate pieces in a single lcatin, in an area less than 10 feet in diameter (with multiple pieces f material within a few inches f each ther t be treated as ne piece f asbests), the GC and/r CABI can hand remve the ACM in accrdance with Sectin 11 f this PSRMP. If quantities f ACM exceed this amunt, a GAC must cmplete the wrk. Denver, Clrad Page 13

23 6. General Cntractr and/r General Abatement Cntractr Requirements The fllwing cntains requirements fr the General Cntractr (GC) and/r General Abatement Cntractr (GAC) perfrming RACS disturbance/remval at the Site: The GC/GAC shall prvide dcumentatin t the CABI and CCD that all individuals perfrming RACSdisturbing activities have cmpleted a site-specific awareness training that prvides infrmatin necessary t perfrm their duties in a way that ensures cmpliance with the requirements f the CSWR 5.5. The GC/GAC shall ensure that individuals perfrming RACS disturbing activities have cmpleted asbests awareness training in accrdance with OSHA 29 CFR (d) (9) (vii). Recrds that dcument the training, experience, r certificatin requirements in CSWR 5.5. Dcuments shall be available fr review thrughut the duratin f sil-disturbing activities. The GC/GAC will be required t prepare and implement a HASP in accrdance with the applicable regulatins, including OSHA. The GAC will be respnsible fr the health and safety f its emplyees, subcntractrs, cnsultants, etc., as well as prvide all necessary training and PPE fr cmpletin f wrk at the Site. The GC/GAC will be respnsible fr maintaining all necessary site cntrls t prevent unauthrized entry int the RWA. The GC/GAC will be respnsible fr adherence t this plan at the directin f the CABI/AMS. Denver, Clrad Page 14

24 7. Ntificatins The PSRMP must be submitted t the Divisin fr review and apprval, alng with the Ntificatin f RACS Disturbance frm (Attachment A) at least 10 wrking days prir t cmmencing RACS-disturbing activities. RACS disturbance shall nt cmmence until apprval has been granted by CDPHE. Denver, Clrad Page 15

25 8. General Asbests-Cntaminated Sil Management Requirements 8.1 Immediate and Interim Actins upn Discvery f Suspected RACS This sectin describes the immediate and interim actins that will be implemented by the GC r GAC if suspected RACS is discvered. When suspected RACS is discvered during sil mving r earth-mving activities at the Site, the critical requirement is t avid generating dust r being in direct cntact with airbrne sil, thereby limiting ptential expsure t asbests fibers. If/when suspect RACS is encuntered, the fllwing prcesses must be fllwed: Stp all sil-disturbing activities in the area immediately upn encuntering the suspect RACS. Wet the area immediately surrunding the suspect RACS with water, prir t perfrming sampling activities that disturb the material (nte: visual inspectin des nt require wetting). Maintain wet cnditins thrughut sampling activities. A layer f 6-mil plyethylene (ply) sheeting may be used t prevent crss-cntaminatin nt clean sils during initial characterizatin activities by placing the ply n the grund and then placing the ptentially cntaminated sil, which has been thrughly wetted, directly n the ply. The CABI as described in Sectin 4 will cllect samples f the suspect RACS accrding t prcedures prvided in Sectin The samples will be analyzed by PLM t evaluate if asbests fibers are present. Generate n visible emissins (dust) during characterizatin activities. Disturb sil as little as pssible t perfrm sampling activities. If leaving the Site unattended, cver the disturbed sil with a layer f 6-mil ply sheeting, r spray with magnesium chlride slutin (r equivalent) in sufficient amunts t wet the sil t prevent drying and dust generatin. After cnfirmatin f RACS by the CABI, the CABI will direct the GC and/r GAC n prper implementatin f this PSRMP. Ntificatins will be cmpleted in accrdance with the Sectin 5.5 regulatin. Ideally, as RACS is expected n this prject, the 10-day ntificatin will be submitted prir t wrk activities at the prject. 8.2 Site Access Cntrl The GC and/r GAC will be respnsible fr maintaining effective prject access cntrl. A fence shuld be erected arund the perimeter f the prject area t limit access t the Site. Access will be limited t individuals that are apprved t be n Site. If RACS is encuntered, prper signage stating the area is a RWA will be installed by the GAC, as described in Sectin Persnnel wrking n the Site shall be advised and directed nt t disturb areas where suspected r knwn asbests is encuntered. Persnnel driving nt the Site shall be ntified f suspect r knwn asbests lcatins and directed t nt drive n r disturb thse areas. At n time will vehicle traffic be allwed n surfaces where samples have shwn psitive test results, r where visible asbests is present. This excludes equipment that is t remain ff the rad and n the prject area fr remval peratins. Prject equipment/vehicles mving acrss cntaminated sils must d s in a way as t nt generate visible emissins, Denver, Clrad Page 16

26 and the sil shall be wetted t cntrl visible emissins. The prject equipment/vehicles must be decntaminated per Sectin f this PSRMP. 8.3 Emissin Cntrl Plan Dust generated during RACS disturbance presents a ptential air quality issue. Dust suppressin and emissins cntrls are critical elements f this PSRMP. The fllwing are measures designed t minimize dust generated during RACS-disturbance peratins: Dust cntrl practices are t remain the highest cnsideratin and first pririty while handling RACS Water will be used t wet RACS and suspect RACS while handling, expsing, mving, dispsing f, and stabilizing A water truck will be used whenever necessary t prhibit the generatin f dust n Site If stckpiling f RACS is necessary, water will be peridically applied t limit the generatin f dust All equipment will arrive t and leave frm the Site clean 8.4 Sil Wetting r Stabilizing A cntinuus water supply (i.e., water truck, water tank, fire hydrant and hse, etc.) shall be available at all times at each wrk area during RACS disturbance. This supply will be available fr direct applicatin t the grund surface t suppress emissins. Prir t RACS disturbance (after the CABI has determined that suspect r cnfirmed RACS ccurs in a wrk area), the wrk area will be adequately wetted t prevent fugitive dust emissins. RACS that cntains friable ACM will be wetted using amended water cnsisting f a 50:50 mixture f plyxyethylene ester and plyxyethylene ether, r equivalent, in a slutin cnsistent with manufacturer specificatins, and applied at lw pressure t avid dust generatin and/r splattering. The wetting f the sil will be sufficient t reach the excavatin cut f the equipment being used. The CABI will evaluate the penetratin f the water/amended water and bserve fr evidence f visible emissins. If necessary, the applicatin f water/amended water using grund injectin techniques may be used at the directin f the CABI. Water will be sprayed directly at the excavatin cut, with care taken t avid generatin f dust r splattering. At least ne asbests wrker will be assigned t each wrk area fr the direct applicatin f water/amended water during RACS disturbance. Additinal water may be applied during remval/disturbance f RACS int dispsal trucks at the directin f the CABI; a CABI will mnitr each wrk area t verify that n visible emissins ccur. At the discretin f the CABI, additinal mitigatin measures may be emplyed, such as equipment r grund-munted misters. 8.5 Management f RACS t be Left in Place It is pssible that undisturbed RACS will remain in place in subsurface sils at the Site. The material that will be expsed frm the new surfaces created will need t be designed t prevent ptential expsure. Any cuts made t grade that expse RACS will need t be cvered r stabilized using ne f the fllwing methds: Denver, Clrad Page 17

27 Cver RACS with gefabric, fllwed by 18 inches f fill suitable fr unrestricted use, and vegetatin/landscaping per the prject plans Cver RACS with gefabric, fllwed by six inches f fill suitable fr unrestricted use, and cncrete r asphalt Cver RACS with gefabric, fllwed by fill suitable fr unrestricted use t grade r six inches, whichever is greater, fr vertical excavatin faces r trenches 8.6 Stabilizing Suspected ACM Debris, which will nt be kept wet with amended water, will be stabilized as fllws: Cver with ply sheeting r gefabric, cnduct daily inspectins, inspect within eight hurs after strm events, and repair/replace cver as necessary; r Cat with a chemical stabilizer demnstrated t be effective in the stabilizatin f asbests debris (e.g. magnesium chlride), cnduct daily inspectins and inspect within eight hurs after strm events, and reapplicatin f chemical stabilizer as necessary t maintain an effective cating; r Cver with a minimum f three inches f sil apprpriate fr unrestricted use. Denver, Clrad Page 18

28 9. Prcess Flw The fllwing prcess-flw chart presents the general prcess that will be fllwed during excavatin activities. Sectins 10, 11 and 12 f this PSRMP detail the specific actins required dependent n the type f ACM being managed (e.g., nn-friable and friable), and the quantity f material. Nn-ACM handling prcedures are presented in the prject MMP. Excavatin in sil with debris with CABI versight Suspect r cnfirmed ACM? N Cntinue excavatin per MMP Yes Nn-Friable ACM and <10 separate pieces in a 10-ft diameter area (Sectin 11) Hand remval ( pick and g ) f RACS. Excavatins may be cmpleted by General Cntractr with CABI versight. Cmplete wrk in accrdance with Sectin 11 f this PSRMP. CABI t evaluate if material is friable, and quantity f material at a discrete lcatin N Friable ACM r 10 separate pieces in a 10-ft diameter area (Sectin 11) Bulk remval f RACS. Excavatins cmpleted by General Abatement Cntractr with CABI and AMS versight. Regulated wrk area setup with persnal air and wrk area air sampling. Cmplete wrk in accrdance with Sectin 12 f this PSRMP. RACS Remved? Yes Denver, Clrad Page 19

29 10. Nn-Asbests Cntaining Material Handling Prcedures A subsurface investigatin was cmpleted at the Site t evaluate the presence f ACM (MMP Appendix A), and further investigatins are planned. Varius suspect ACMs were fund in the prject area (MMP Figure 1) and 19 samples f suspected ACM (e.g. brick, mrtar, shingles, fabric) were cllected fr labratry analysis frm the test trenches. Based n the labratry analysis, ne material was classified as ACM (Table - 3; Pinyn, 2018b). The remaining materials were nn-acm. If n additinal untested suspect materials, r cnfirmed ACM, are encuntered the material can be handled and dispsed f in accrdance with the Site-specific MMP (Pinyn, 2018). Additinal suspect and cnfirmed ACM will be handled in accrdance with this PSRMP. Denver, Clrad Page 20

30 11. Hand Remval f Minimal Suspected ACM upn Discvery If knwn r suspect nn-friable ACM is encuntered, and cntains less than 10 separate pieces f material in a single lcatin, in an area less than 10 feet in diameter (with multiple pieces f material within a few inches f each ther t be treated as ne piece f asbests), the CABI will direct (r perfrm themselves) the GC in the remval f these pieces f suspect r cnfirmed ACM using the prcedures listed (this is smetimes referred t as the pick and g methd): Adequately wet the suspect r cnfirmed ACM and surrunding sil (12-inches) with amended water cntaining a wetting agent, such as a 50:50 mixture f plyxyethylene ester and plyxyethylene ether. Gather and place the wet material and 12-inches f surrunding sil int duble-bagged, 6-mil ply bags. The CABI will then cmplete a secnd inspectin f the area and surrunding surface where minimal material was discvered t safeguard that n further ACM is in the area. If the CABI encunters further material after remval f riginal discvery that exceeds 1% (ne percent) by vlume f surrunding sil, mechanical remval methds inside a RWA shuld be implemented, as described in Sectin 12. Dispse f waste in marked, 6-mil ply bags with attached generatr labels in accrdance with the CSWR 5. Hand-remved, bagged ACM may be stred in a leak tight and secure cntainer labeled fr asbests, and dispsed f in accrdance with CSWR 5. Asbests wrker and equipment decntaminatin shall be perfrmed in accrdance with Sectin Where there are minimal amunts f nn-friable ACM discvered as described abve, the CABI may cnduct the remval actins, and the utilizatin f a GAC is nt required (althugh a GAC may prvide trained asbests wrkers t cmplete remval actins under the supervisin f the CABI). Therefre, this remval methd is apprpriate when the bulk-remval f sil frm the Site by the GC is being perfrmed, but nly when the sil is destined t be dispsed at DADS as a special slid waste, as described in the MMP. The abve cnditins must als be met. If friable ACM is encuntered, r if the amunt f material at a discrete lcatin is equal t r greater than 10 pieces as described abve, bulk remval actins as described in Sectin 12 will be required. During bulk remval actins f special slid waste, the CABI must carefully (and safely) bserve sil during the excavatin prcess, prir t the material being laded int trucks, t ensure that suspect ACM is nt verlked. In n event may excavated sil that cntains nn-sil cnstructin debris (e.g., nn-acm bricks, cncrete, ceramic) be reused ff-site. These sils must be dispsed at DADS as a special slid waste accrding with the MMP. Denver, Clrad Page 21

31 12. Bulk Remval f RACS Bulk remval f RACS will be required if friable ACM, r nn-friable ACM greater than r equal t 10 separate pieces f material in a single lcatin, in an area less than 10 feet in diameter (with multiple pieces f material within a few inches f each ther t be treated as ne piece f asbests) is encuntered Establishing a RWA after Cnfirmed Discvery f RACS The GC under the directin f the CABI will be respnsible fr establishing any RWAs fr discvered ACM that the CABI identifies, which will be remved by bulk-remval methds (nt hand-remval methdlgy as discussed in Sectin 11), and must take place n the day f discvery as fllws: Establish a visible perimeter arund the discvered material, which is identifiable t all persns n Site, t prevent crss cntaminatin. Demarcate area suspected f cntaining RACS with barrier tape, r ther means, and prvide access cntrl. Pst labeling and signage t demarcate RWA(s). The RWA shall be demarcated with a visual means that defines the full extent f the RWA. Labeling and signage shall indicate the ptential presence f asbests, and that the area is ff limits t unauthrized persnnel Engineering Cntrls Initial Minimum Cntrls Minimum engineering cntrls will be implemented when excavatins ccur within the ftprint f the RWA. The minimum engineering cntrl include, but are nt limited t the fllwing: A CABI must bserve each area where sil disturbing r lading activities are taking place; therefre, if multiple excavatins are ccurring simultaneusly, a CABI must be available t bserve each excavatin lcatin (i.e., utilize multiple CABIs). The CABI(s) will be n site at all times that RACS is being remved t ensure that n visible emissins are generated at any time during sil-disturbing activities. Additinally, the CABI will verify that the sil misture is sufficient during remval t suppress dust, and t ensure that the material is adequately wet. If visible emissins are bserved, then wrk practices will be mdified. Stckpiled sils will be stabilized using the applicatin f water r magnesium chlride, and/r by cvering with verlapped ply sheeting r apprpriate cver/stabilizatin. Wind Break Barriers Wind break barriers must be cnstructed prir t cmmencement f remval activities, and cnstructed f materials apprpriate t site cnditins. Ultimately, wind break barriers will be the respnsibility f the GAC. It is recmmended that the wind break barriers be relatively prtable and adequate t minimize sil dispersal frm the wrk area. The wind break barriers will be placed t cmpletely encmpass the wrk area and lading area, as this will assist t prevent uncntrlled access t the wrk area by unauthrized persnnel during and after wrk shifts. Denver, Clrad Page 22