Attachment_5_FRST_Abatement_Report.pdf

FINALT ASBESTOS ABATEMENT REPORT

First State National Historical Park

New Castle, Delaware Order Number: GS00F314CA/140P2020F0225

Submitted to:

National Park Service

Prepared for:

U.S. Department of the Interior

U.S. National Park Service, Denver Service Center Denver, CO

Prepared by:

Wood Environment & Infrastructure Solutions, Inc.

751 Arbor Way

Hillcrest I, Suite 180 Blue Bell, PA 19422

March 2021

Wood Project No. GSA3140024

03/05/2021 03/05/2021 Prepared by: Date Reviewed by: Date W. Scott McCartney, P.E.

Associate Engineer

Kevin J. McKeever P.E., P.G.

Branch Manager – Principal Engineer

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TABLE OF CONTENTS

Section Page

1.0 Introduction 1

2.0 Scope of Work 2

3.0 Deviations from Scope of Work 6

4.0 Asbestos Abatement and Air Monitoring Activities 8

4.1 Asbestos Abatement Procedures 8

4.2 Air Monitoring and Project Inspection Activities 9

4.3 Waste Disposal 9

FIGURES

Figure 1: Site Location Map

Figure 2: Basement and First Floor Areas

APPENDICES

Appendix A: Alliance Environmental Services Asbestos Abatement Work Plan

Appendix B: Asbestos Abatement and Renovation Notification

Appendix C: Alliance Environmental Services Abatement Personnel License Information

Appendix D: Non-Hazardous Asbestos Waste Shipment Records

Appendix E: Photographic Log

Appendix F: Project Air Sample Analysis Results

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NPS Sheriff’s House Asbestos Abatement Report 1

New Castle, Delaware

1.0 Introduction

Wood Environment and Infrastructure Solutions, Inc. (Wood) is pleased to submit this Asbestos Abatement Report to the National Park Service (NPS) in association with the asbestos abatement performed in the basement and in the mechanical room of the historic Sheriff’s House at First State National Historical Park located in New Castle, Delaware (Site) (Figure 1). The abatement project area was specifically for removal of soil in Rooms 001, 002 and 006 in the Site’s basement and the ceiling panels of the Site’s mechanical room (Room 115) (Figure 2). The abatement activities were in support of planned renovations of the historic Sheriff’s House, which is to be used as offices for NPS staff and as a historic landmark for visitors.

Wood contracted Alliance Environmental Systems (AES) to provide asbestos abatement, periodic visual oversight by a Delaware licensed asbestos inspector to verify adherence to regulations and the work plan, to provide oversight services to NPS contracted archeologists and to document the activities for this project. Additionally, Wood contracted with Vertex to conduct air clearance sampling and limited visual inspections of the work areas. The work was performed in accordance with Contract GS-00F-314CA, Order # 140P2020F0225 and Wood’s Revised Proposal, dated May 6, 2020.

This report presents information in the following sections:

• Section 2 describes the Scope of Work (SOW) for the asbestos abatement for the historic Sheriff’s House.

• Section 3 describes the deviations from the SOW encountered during execution of the project.

• Section 4 describes the asbestos abatement and air sampling tasks.

NPS Sheriff’s House Asbestos Abatement Report 2

New Castle, Delaware

2.0 Scope of Work

Presented below is a summary of the work conducted by Wood and our subcontractors, AES and Vertex, for the SOW/Contract Line Item Number (CLIN) as per the Request for Qualifications (RFQ) from the NPS and Wood’s Proposal submitted on May 6, 2020, and as specified in the Contract documents (Contract No.: GS-00F-314CA, Order No.: 140P2020F0225).

CLIN 1 Containment – Construction/Teardown

Wood and our subconsultant Vertex provided oversight of the construction and removal of the containments for both the basement excavation and the exercised optional abatement of the mechanical room. AES performed containment construction and removal. Wood personnel provided general visual oversite from outside containment, while AES, a certified Delaware asbestos abatement contractor provided oversite inside the containment structure, providing Wood with pictures and progress updates. The containment construction for the basement consisted of the following activities:

• Install 0.006-inch thick (6-mil) polyethylene (poly) critical seals on all openings on the first-floor stair landing that leads to the work area;

• Install two layers 6-mil poly sheeting on the walls;

• Install one layer 6-mil poly sheeting on the ceiling;

• Install negative air machines (AFD’s);

• Install AFD’s flex duct to vent outside the containment;

• Install three-stage decontamination chamber attached to the containment;

• Distribute electric, lighting and water to the containment; and

• Protect floor & walls in first floor Room 104 & hallways (laydown area).

The containment construction for the mechanical room consisted of the following activities:

• Demarcate the work area with barrier tape and warning signs to prevent unauthorized personnel from entering the work areas;

• Install 6-mil poly critical seals on all openings to the work area;

• Install two layers 6-mil poly sheeting on walls;

• Install two layers 6-mil poly sheeting on floor;

• Install AFD’s;

• Install AFD’s flex duct to vent outside the containment;

• Install three-stage decontamination chamber attached to the containment;

• Distribute electric, lighting and water to the containment; and

NPS Sheriff’s House Asbestos Abatement Report 3

• Protect mechanical units and associated appurtenances.

CLIN 2 Air Monitoring - Baseline / Final

Wood provided oversight of the baseline air monitoring of the basement and mechanical room.

Wood provided visual oversite from outside of the containment area for final air clearance sampling of the mechanical room and basement. Wood’s subcontractor, Vertex, conducted the baseline air samples of the basement and mechanical room prior to containment construction. As part of the baseline air monitoring sample collection, Vertex also performed a thorough visual inspection of each containment area. Upon the completion and passing of the pre-abatement inspection, abatement commenced. Vertex collected air samples in the mechanical room and basement areas after abatement activities were completed, but prior to the removal of containment structures. Vertex visited the Site three times, once to conduct baseline air clearance sampling, once to conduct final air clearance sampling of the mechanical room and once to conduct air clearance sampling of the basement.

For baseline and final clearance air sampling, Vertex utilized high-volume intake air pumps calibrated to allow a sufficient volume of air to pass through a mixed cellulose ester filter for fiber collection. After the completion of abatement activities in each containment area, Vertex conducted a visual clearance inspection to verify that the SOW had been completed. When the final visual inspection was successfully completed, clearance air samples were collected then analyzed by Phase Contrast Microscopy (PCM) in accordance with applicable regulations.

CLIN 3 Excavation - Phase 1

Wood and their subcontractor, AES, provided oversight of the Phase 1 archaeological test excavations performed by Elizabeth Anderson Comer/Archaeology (EAC/A). Wood and AES worked with and supported EAC/A during the Phase 1 test excavations, as needed. An AES Asbestos Abatement Supervisor was available onsite during EAC/A’s Phase 1 excavation activities.

CLIN 4 Excavation - Phase 2

Wood and their subcontractor, AES, performed oversight of the Phase 2 excavation activities.

Wood personnel provided general visual oversite from outside containment, while AES, a certified Delaware asbestos abatement contractor provided oversite inside the containment structure, providing Wood with pictures and progress updates. One of the Wood employees (Jason Straut) providing supervision of the project onsite, is an asbestos trained employee qualified to wear a respirator and enter the containment areas. This Wood employee would periodically enter the

NPS Sheriff’s House Asbestos Abatement Report 4

New Castle, Delaware containment area in the basement to document progress of the excavation and to take pictures.

Wood and AES also worked with the NPS archeologist during the Phase 2 excavation activities to identify any artifacts that were discovered during abatement and excavation activities to keep the project on schedule. AES provided the excavation and removal of the asbestos containing material (ACM) as part of this CLIN. AES double bagged and secured all excavated ACM soil. Bags filled with excavated materials were manually removed from the basement project area and placed into the outside dumpsters for disposal.

CLIN 5 Removal / Transportation / Disposal / Fees

Wood personnel provided oversight of ACM removal and disposal activities at the site conducted by AES from outside of the containment structures (oversaw placement of ACM bagged material into ACM dumpsters staged on Market Street). Dumpsters to be filled with abated ACM were brought onsite as needed during the progression of the excavation and mechanical room abatement activities.

CLIN 6 Labor

Based on the April 27, 2020, conference call, the NPS requested that this CLIN not be utilized in the proposal.

CLIN 7 Equipment

This CLIN was only utilized to capture other direct costs (ODCs) for Wood equipment during all aspects of the SOW activities.

CLIN 8 Materials

This CLIN was only utilized to capture ODCs for Wood materials or personal protective equipment (PPE) during all aspects of the SOW activities.

CLIN 9 Submittals / Work Plans / Reports

Wood reviewed the AES prepared abatement work plan and site-specific health and safety plan (HASP). Wood also prepared a site-specific HASP for onsite Wood personnel and prepared the final asbestos abatement report for the project.

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CLIN 10 General Conditions

Effort in this CLIN included general activities associated with this project such as the project kick-off meeting, industry standard project coordination, subcontract management and oversight, and project reviews by senior level personnel.

CLIN 11 Permitting

AES prepared and obtained the necessary local permits [asbestos abatement notification to Delaware Department of Natural Resources and Environmental Control (DNREC) and the United States Environmental Protection Agency (USEAP) for the abatement activities.

CLIN 12 Contractor Overhead and Profit

Wood and our subcontractors (AES and Vertex) provided a combined breakout of overhead and profit which equated to approximately 22% of the project.

CLIN 13

This CLIN was not utilized in the SOW.

CLIN 14 Mechanical Room Number 115 (Optional)

Based on the April 27, 2020, conference call, the NPS requested that this CLIN be included in the SOW. This optional CLIN was exercised and AES abated the asbestos containing cementitious ceiling (transite) panels. The ceiling panels requiring abatement were previously nailed to the ceiling joists and then ceiling support beams were installed over the panels. AES removed the transite panels (pulled nails and scored edges along the beams to minimize panel breakage), wrapped and sealed the panels in 6 mil poly-sheeting for disposal, high efficiency particulate air (HEPA) vacuumed Room 115 (ceiling, walls, and floor), and painted the exposed transite panel edges at the beams with an encapsulant (asbestos bridging compound).

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3.0 Deviations from Scope of Work

The following section summarizes the deviations from the SOW as agreed to by Wood, AES and the NPS.

Project Coordination:

The initial RFQ included coordination with EAC/A, NPS’s archeologists, for Phase 1 test excavation and to provide two-week notification prior to starting abatement activities. However, after the project was awarded, Wood was notified that there were many stakeholders associated with the rehabilitation of the Sheriff’s House, and that several government agencies should be involved and coordinated as work was started and progressed. This coordination extended to EAC/A, the New Castle Public Works Department, the NPS local representatives in Philadelphia, Pennsylvania, the State of Delaware Historic and Cultural Affairs, and the government’s subcontractor GWWO Inc. Wood met onsite with all interested stakeholders on October 20, 2020, to review the SOW and discuss project coordination. Wood and AES were asked to wait until the City of New Castle was finished conducting utility work in the vicinity of the Site, and potentially until a paving project of Market Street, adjacent to the Site, was completed. The paving project for Market Street was then postponed until Spring 2021, allowing for the asbestos abatement project to start on November 16, 2020. Also, Wood and AES were notified that there would be an estimated two-week work stoppage between Phase 1 and Phase 2 test excavation tasks pending review and approval of EAC/A’s archaeological report by the tribal council. Due to the historic nature of the Site, the tribal council would need to review EAC/A’s archaeological report, prior to excavation activities proceeding in Room 006.

Phase 1 Excavation:

Per the RFQ, it was Wood and AES’s understanding that the Phase 1 test excavations would be conducted by AES under the supervision of EAC/A. However, Wood and AES were later advised that the Phase 1 test excavations were to be conducted by EAC/A under AES’s Asbestos Abatement Foreman per Delaware regulation for asbestos abatement. This work was conducted on November 19 and 20, 2020.

Mechanical Room Containment System:

The mechanical room (Room 115) containment structure was originally estimated to be completed during summer months when the boilers located in the room would not be operating. Due to project delays in contracting and coordination, the abatement activities actually took place in November when the boilers were in use. AES built a separate containment structure for the boilers to allow them to operate while the mechanical room was abated.

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Phase 2 Abatement Excavation and Apparent Sub-Floor:

During the archeological test excavation activities, it was noted that there may be a brick, cobble, and/or rubble sub-floor below the soil of the basement. This was discussed with NPS and NPS agreed that AES would proceed with soil removal in the basement to the proposed nine-inch depth or to the apparent sub-floor, if encountered. If the sub-floor was encountered, AES would stop work in that area and continue the excavation in the remaining abatement project areas. Any evidence of a sub-floor would be reviewed by the archaeologist and, if approved, removed under a Change Order. AES did not encounter a sub-floor while excavating to the nine-inch depth.

Some broken pieces of brick and cobbles were identified during the excavation, as well as, naturally occurring cobbles and stones, but no distinct sub-floor was encountered. Some metal spikes and hinges were discovered and set aside for later evaluation. A series of bricks placed in a semi-circle were discovered in Room 006 and were left in place (located below the nine-inch depth).

Phase 2 Pause in Abatement Excavation Delay During the final stages of excavation, removal of soil from the basement and cleaning, NPS expressed a concern that a rubble sub-floor may have been inadvertently removed during excavation. NPS project managers requested that Wood and AES pause work on December 31, 2020, so that NPS and the stakeholders could determine if an archeologist should come out to the Site to inspect the basement for the presence of flooring materials. At the time of the request all excavation had been completed and AES was completing soil removal from the basement and preparing for final cleaning. On January 4, 2021, NPS inquired when a non-trained or protected asbestos person could safely enter the basement area. Wood advised NPS that final cleaning and the collection of final air clearance samples was required prior to non-asbestos certified and protected personnel entering the area. AES returned to the Site on January 6, 2021, to conduct final cleaning. Vertex conducted final air clearance sampling and inspection on January 7, 2021.

NPS archeologist, David Gadsby visited the Site on January 7, 2021, after clearance was given by Vertex to inspect the basement and mechanical room.

NPS Sheriff’s House Asbestos Abatement Report 8

4.0 Asbestos Abatement and Air Monitoring Activities

4.1 Asbestos Abatement Procedures

Wood retained AES to conduct the abatement activities at the Site. The abatement work was conducted over 26 days from November 16, 2020 to November 24, 2020 and from December 9, 2020 to January 8, 2021 (no abatement activities were conducted on weekends, holidays or on January 4 or 5, 2021) in the basement and mechanical room at the Site. Table 1 presents a chronology of the abatement activities. The asbestos containing transite ceiling panels located in the mechanical room were easily accessible and removed without difficulty. The soil with potential ACM in the basement was excavated down to a depth of nine inches without encountering materials that could be identified as a distinct sub-floor. Soil, rock, stone, brick etc. located beneath support columns was left in place to prevent impacting the structural integrity of the basement ceiling/first floor of the Site.

AES prepared and submitted for approval an Abatement Workplan (Appendix A). Upon NPS approval of the workplan and agreement by all parties, the work was scheduled to begin on November 16, 2020. The required 10-day notification was submitted to the State of Delaware on October 30, 2020, and is included in Appendix B. AES conducted all work under the supervision of a State of Delaware certified Asbestos Abatement Supervisor. AES personnel certificates are included in Appendix C. In accordance with the approved workplan, AES installed containment structures in the mechanical room and basement between November 16, 2020 and November 20, 2020. The basement and mechanical room containment structures consisted the referenced material in the CLIN 1 description on page 2 above. of the following:

The asbestos waste dumpster was staged outside the Site on Market Street. Warning signs were placed at the entrance to the Site building and the mechanical room.

The asbestos containing transite panels in the mechanical room were removed by pulling the existing nails and scoring the edges along the beams to minimize panel breakage, wrapping and sealing the panels in 6-mil poly sheeting for disposal, HEPA vacuumed the room (ceiling, walls and flooring) and paint the exposed transite panel edges at the beams with encapsulant (asbestos bridging compound). The soil in the basement was misted and placed into 6 mil poly disposal bags and removed from the basement to an ACM Dumpster for transportation and disposal.

All waste bags and larger wrapped materials were appropriately labeled with generator information and Department of Transportation (DOT) signage. The abatement project generated waste was transported to the Western Berks Community Landfill located in Birdsboro, PA 19508.

A copy of the asbestos waste manifests are provided as Appendix D.

NPS Sheriff’s House Asbestos Abatement Report 9

New Castle, Delaware

Photographs documenting the asbestos abatement activities are provided in Appendix E.

4.2 Air Monitoring and Project Inspection Activities

Air monitoring and asbestos project inspector (API) services were conducted by Wood and Wood’s subcontractor, Vertex. API services consisted of the following:

• Monitoring of the abatement activities and procedures of the abatement contractor;

• Inspection of the regulated work area prior to abatement activity commencement;

• Collection of air samples for compliance with applicable regulations;

• Visual inspection and clearance testing of the regulated work area; and

• Collection and removal verification of all project designated ACM.

Project air samples were collected before and after the mechanical room asbestos abatement and the basement asbestos abatement on November 13, 2020, November 24, 2020, and January 7, 2021, respectively. Pre-abatement background air samples were collected on the morning of November 13, 2020. The pre-abatement air samples, collected on November 13, 2020 were collected from the mechanical room (2 samples) and the basement areas (3 samples). All samples analyzed by PCM were below the analytical detection limit of 0.002 fibers per cubic centimeter (F/cc). Three mechanical room final air clearance samples were collected on November 24, 2020 and were analyzed by PCM to report non-detect for asbestos fibers. Five final air clearance samples were collected from the basement on January 7, 2021 and analyzed by PCM and found to be non-detect for asbestos fibers. The air sample analytical results are included as Appendix F.

Air samples collected were analyzed by PCM in accordance with the National Institute for Occupational Safety and Health (NIOSH) Method 7400. The analyses were performed by a microscopist who has completed a NIOSH 582 equivalent course for microscopic evaluation of airborne fibers. The analytical results of the air samples collected from the work area perimeter were below the OSHA regulated reoccupation clearance level of 0.01f/cc.

4.3 Waste Disposal

Project related ACM (transite panels and soil) generated during the abatement project, was placed in appropriately labeled plastic waste disposal bags, and wrapped in transparent 6-mil poly-sheeting. Labels with the asbestos waste generator information were affixed to the duct tape at the “neck” of each waste bag. Generated wastes were placed in a 6-mil poly-sheeting lined, four

(4) sided, waste dumpster before being transported by Advanced Disposal to the Western Berks Community Landfill. Per the waste manifests approximately 100 cubic yards (3,901 bags) of material was removed from the Sheriff’s House mechanical room and basement.

NPS Sheriff’s House Asbestos Abatement Report 10

New Castle, Delaware

A copy of the Advanced Disposal waste manifests is provided as Appendix D. Project photographs, including the bagged asbestos waste, the lined dumpster, and the generator information tags on the bags, are provided in Appendix E.

Table 1: Chronology of Abatement Activities:

Date: Description:

10/20/2020 On-Site Project Kick-Off Meeting 10/30/2020 Notification made to DNREC/EPA of Asbestos Abatement Activities (10-day notification).

11/12/2020 AES visits the Site to pre-plan abatement activities and location of decontamination shower.

11/13/2020 Vertex conducts baseline air sampling in basement and mechanical room.

11/16/2020 AES begins construction of containment system in basement and mechanical room.

11/18/2020 AES completes containment structure in basement.

11/19/2020 EAC/A conducts test pits in basement, AES completes containment in mechanical room.

11/20/2020 EAC/A completes test pits in basement, AES begins abatement of ceiling panels in mechanical room.

11/23/2020 AES completed removal of asbestos panels in mechanical room.

11/24/2020 Vertex conducts air clearance samples of mechanical room; AES completes removal of the containment system in mechanical room.

Project put on hold until approval to begin basement excavation given by

NPS.

12/9/2020 AES begins soil removal in the basement.

12/24-12/25 No work due to Christmas Holiday.

12/28/2020 Work resumes. All soil excavated in basement. AES works on removing soil bags from Basement to dumpster.

12/31/2020 Work halted based on concern about brick, cobble, and/or rubble apparent sub-floor being removed by Wood and /AES. AES did not encounter any defined floor during excavation.

1/6/2021 AES completes removal of soil bags and prepares basement for final air clearance sampling.

1/7/2021 Vertex conducts final air final air clearance sampling of basement.

Basement is cleared for non-abatement entry. NPS’s David Gadsby onsite to review work in basement, investigate brick structure found in Room 006.

1/8/2021 AES removes containment system from the basement and demobilizes from the Site.

NPS Sheriff’s House Asbestos Abatement Report

FIGURES

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751 Arbor Way, Suite 180 Tel. 610-828-8100

Blue Bell, PA 19422 www.woodplc.com

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ASBESTOS ABATEMENT

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10 MARKET STREET

NEW CASTLE, DE 19720

NATIONAL PARK SERVICE

12795 W ALAMEDA PARKWAY, P.O. BOX 25287

DENVER, CO 80225

GSA3140024

751 Arbor Way, Suite 180 Tel. 610-828-8100

Blue Bell, PA 19422 www.woodplc.com

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BASEMENT AND FIRST FLOOR AREAS

SOURCE

PDFs RECEIVED FROM NPS ENTITLED "BASEMENT FLOOR PLAN"

AND "FIRST FLOOR PLAN", DATED 10-14-2019.

ASBESTOS ABATEMENT

REPORT

10 MARKET STREET

NEW CASTLE, DE 19720

NATIONAL PARK SERVICE

12795 W ALAMEDA PARKWAY, P.O. BOX 25287

DENVER, CO 80225

SCALE: 1" = 16'

8' 16'

AREA TO BE

EXCAVATED

(9" IN DEPTH)

CEILING

PANELS

REMOVED

First State National Historical Park Appendix A

APPENDIX A

Alliance Environmental Services Asbestos Abatement Work Plan

First State National Historical Park Appendix A

Historic Sheriff’s House – First State National Historic Park – New Castle, DE Alliance Environmental Systems, Inc.

ASBESTOS HAZARD ABATEMENT PLAN

10/29/20

INTRODUCTION

This asbestos work plan has been developed for the Asbestos Contaminated Soil Removal from the Historic Sheriff’s House Basement; and the removal of Asbestos Cement Board from the outside Mechanical Room, located in the First State National Historic Park – New Castle, DE. Alliance Environmental Systems, Inc. (AES) under a subcontract with Wood Environmental & Infrastructures Solutions, Inc. (Wood). This asbestos hazard abatement work plan was prepared based on the scope of work provided by the National Park Service (NPS) dated March 25, 2020, and a subsequent coordination conference call on August 25, 2020, with the NPS and their archeological subcontractor (EAC). The provisions of this plan have been developed in strict accordance with all applicable Safety and Health requirements, and all applicable local, State of Delaware and federal regulations including but not limited to Occupational Safety and Health Administration (OSHA) 29 CFR Part 1926.1101 including Appendices B, and F and 40 CFR Part 61, Subpart M (EPA – NESHAPS).

A. LOCATION

The general location of the work contemplated by these specifications is in the basement and in the outside mechanical room of the Historic Sheriff’s House in the First State National Historic Park – New Castle, DE

B. WORK DESCRIPTION

The work to be performed during this phase of the project will include the removal and disposal of asbestos containing materials: Phase 1A - 22 SF and Phase 1B - 1,200 SF (respectively) of soil from the basement; and Phase 2 - approximately 300 SF of asbestos cement board from within the outside mechanical room (Room 115) of the building.

C. COMPETENT PERSONNEL

The following personnel have received EPA/State of Delaware-accredited Asbestos Abatement Contractor supervisor training, and meet the “Competent Person” criterion within 29 CFR 1926.1101

A. Project Executive (AES) – Mark Griffin B. Project Superintendent (AES) –Joseph DiFeterici & Kington Insixiengmay

D. PRODUCTS

Materials

1. Use only surfactant or wetting agents (Super Water Wetter, Non-ionic Surfactant, AS205) sold for the purpose of asbestos wetting. Materials intended for other uses, such as household detergents, are not permitted.

2. Disposal bags shall be 6-mil polyethylene and pre-printed with labels in accordance with Standards 29 CFR 1926.1101 and 49 CFR 172.

3. HEPA filters shall provide an efficiency of not less than 99.97% when challenged with 0.3-micrometer particle-size.

4. Disposable Coverall/Suits (with head and foot covering).

5. Six (6)-mil polyethylene plastic sheeting.

6. Duct tape.

7. Respirators NIOSH/MSHA approved equipped with HEPA cartridges.

8. Penetrating Lockdown encapsulant (Chemsafe 500 and/or Powerlock by

American Coatings).

9. Spray Adhesive (Lynx-Tack and/or BullTac).

10. Towels and Cleaning Rags

11. Gloves (Rubber, Leather and Cut Resistant).

12. Assortment of Hand Tools (shovels, spades, digging bars, crowbars, etc.).

13. Warning Signs and Barrier Tape.

14. SDS will be provided for all chemicals & materials brought on site.

Equipment

1. All vacuums cleaners shall be equipped with a HEPA filter.

2. Airless sprayers

3. Hand tools.

4. Wheel Barros

5. Dump Carts

6. Air Filtration Devices equipped with HEPA filters.

7. 3-Stage Decontamination Chamber equipped with shower and hot & cold running water.

8. Manometer.

E. ASBESTOS WORK METHODS

All asbestos removal work shall be performed in accordance with OSHA 29 CFR

1926.1101 and EPA 40 CFR 61 Standards, State of Delaware Regulations, and additional project specific requirement ATTACHMENT A. The non-mandatory Appendices B and F in standard 29 CFR 1926.1101 are mandatory for this work. The most recent asbestos removal and disposal requirements established by applicable federal, state, and local government regulations shall be strictly adhered to.

1. Phase 1A&B - Asbestos Contaminated Soil

Work Area Preparation:

- Demarcate work area with barrier tape and warning signs to prevent unauthorized personnel from entering the work areas.

- Install 6-Mil polyethylene (poly) critical seals on all openings to the work areas.

- Install (2) layers 6-Mil poly sheeting on walls.

- Install (1) layer 6-Mil poly to underside of 1st floor (work area ceiling).

- Distribute electric & water

- Install negative air machines (AFDs) and vent to outside via flex duct.

- Install 3-Stage decontamination chamber at entrance to work area.

- Set up Manometer to measure negative pressure (.02 inches)

2. Phase 2 - Mechanical Room Asbestos Cement Board

Work Area Preparation:

- Demarcate work area with barrier tape and warning signs to prevent unauthorized personnel from entering the work areas.

- Install 6-Mil polyethylene (poly) critical seals on all openings to the work areas.

- Install (1) layer 6-Mil poly sheeting on walls.

- Install (2) layers 6-Mil poly sheeting on floor.

- Erect framing/box around furnace & flue and seal from work area. Install small micro-trap to at allow venting of furnace to outside.

- Distribute electric & water

- Install negative air machines (AFDs) and vent to outside via flex duct.

- Install 3-Stage decontamination chamber at entrance to work area.

F. ACM ABATEMENT METHODS

1. NESHAPS Asbestos Categories

a. Friable Asbestos-Containing Material (ACM) - Friable asbestos-containing material (ACM) is defined by NESHAPS as any material containing more than 1 percent asbestos as determined using the Polarized Light Microscopy (PLM) method, that, when dry, can be crumbled, pulverized or reduced to powder by hand pressure.

b. Non-friable Asbestos-Containing Material – Non-friable ACM is any material containing more than 1 percent asbestos, as determined using the Polarized Light Microscopy (PLM) method, that, when dry, cannot be crumbled, pulverized or reduced to powder by hand pressure. EPA also defines two categories of nonfriable ACM.

c. Category I Nonfriable ACM - Category I nonfriable ACM is any asbestos-containing packing, gasket, resilient floor covering or asphalt roofing product which contains more than 1 percent asbestos as determined using the Polarized Light Microscopy (PLM) method, and which is in good condition and not considered to be friable.

d. Category II Nonfriable ACM - Category II non-friable ACM is any material, excluding Category I non-friable ACM, containing more than one percent (1%) asbestos as determined using polarized light microscopy according to the methods specified in Appendix A, Subpart F, 40 CFR Part 763 that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure. Category II ACM (cement siding, transite board shingles, etc.) subjected to intense weather conditions such as thunderstorms, high winds or prolonged exposure to high heat and humidity may become "weathered" to a point where they become friable.

e. Regulated Asbestos-Containing Material - Regulated Asbestos- Containing Material (RACM) is (a) friable asbestos material, (b) Category I non-friable ACM that has become friable, (c) Category I non-friable ACM that will be or has been subjected to sanding, grinding, cutting or abrading, or (d) Category II non-friable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations.

2. Removal of Regulated Asbestos-Containing Materials (RACM)

a. Wet Removal Procedures - The asbestos-contaminated material must be sprayed repeatedly before, during, and after the removal process to maintain an adequately wet condition to minimize asbestos fiber release.

Appropriately bagged and adequately wet waste material will be held in the staging area until such time as it is moved to the dumpster for transportation to the disposal site. Care must be taken to ensure that this material has been adequately wet.

3, Methods Of Compliance AES will use the following engineering controls and work practices in all operations covered by this section, regardless of the levels of exposure:

a. Wet Methods Wet methods to adequately wet the ACM, controlling employee exposures during asbestos handling, removal and cleanup, including the use of a misting unit to create a high level of humidity. Some exemptions to wetting include those times when it can be demonstrated that the use of wet methods are not feasible, such as in freezing temperature, when water would create an electrical hazard or equipment malfunction, or when it would create a slipping hazard, such as on roof surfaces.

b. HEPA Equipped Vacuums HEPA filter equipped vacuum cleaners will be utilized to collect

ACM dust and small particles of material.

c. Prompt Clean up Prompt clean up (not allowing accumulation) and disposal of wastes and debris contaminated with asbestos in to leak-tight containers.

d. Additional Control Methods

In addition to the above, AES will use the following control methods to achieve compliance with the TWA permissible exposure limit and excursion limit prescribed by Paragraph (c) of this section:

1. Local exhaust ventilation equipped with HEPA filter dust collection systems.

2. Enclosure or isolation of processes producing asbestos dust.

3. Ventilation of the regulated area to move contaminated air away from the breathing zone of employees and toward a filtration or collection device equipped with a HEPA filter.

4. Use of other work practices and engineering controls that the Supervisor can show to be feasible.

5. Wherever the feasible engineering and work practice controls described above are not sufficient to reduce employee exposure to or below the permissible exposure limit and/or excursion limit AES will use them to reduce employee exposure to the lowest levels attainable by these controls and will supplement them by the use of respiratory protection that complies with the requirements of the Asbestos Standard.

4. Prohibitions

The following work practices and engineering controls will not be used for work related to asbestos or for work, which disturbs ACM or PACM, regardless of measured levels of asbestos exposure or the results of initial exposure assessments:

a. High-speed abrasive disc saws that are not equipped with point of cut ventilator or enclosures with HEPA filtered exhaust air.

b. Compressed air used to remove asbestos, or materials containing asbestos, unless the compressed air is used in conjunction with an enclosed ventilation system designed to capture the dust cloud created by the compressed air.

c. Dry sweeping, shoveling or other dry clean-up of dust and debris containing

ACM.

d. Employee rotation as a means of reducing employee exposure to asbestos.

5.Personal Protective Equipment

Based on the coordination call referenced above, AES will supply full body/head coveralls for the NPS archeologist subcontractor, EAC.

EAC will provide their personnel with all other required PPE for the abatement activities. Wood personnel will have their own company supplied

PPE.

AES requires the following protective equipment for the safety of its workers:

a. Respiratory Protection: Except to the extent that more stringent requirements are written directly into the contract, or required by local ordinance, Respiratory Protection will be strictly addressed. Where there is a conflict in the requirements set forth in this Program and the standards promulgated in the Applicable Codes listed in Paragraph 4.0 of these Guidelines, the more stringent requirements will be enforced.

b. In general, pursuant to a negative exposure assessment, AES shall utilize Powered Air Purifying Respirators for all Class I work and ½ Face Negative Air Purifying Respirators for Class II Work (i.e. floor tile and mastic).

c. Coveralls: AES will provide disposable full body coveralls and head covers and require that all persons entering the work area wear them. AES will provide enough protective clothing for the required number of changes for all working / non-working personnel and EAC employees entering the work area. Disposable coveralls, once contaminated, will be disposed of daily as ACM waste.

d. Foot Covers: AES will provide either disposable or washable foot covers, which must be used over, or in some cases in lieu of, the employee’s personal footwear. If unable to adequately decontaminate personal footwear, it must be properly disposed of as asbestos-containing material (ACM) waste at the end of the project. AES will provide steel toe rubber boots to be utilized within various work areas.

e. Rubber Boots: When rubber boots are used in the work area, they will be required to remain in the work area until the completion of the project, at which time they must be thoroughly cleaned and decontaminated, both inside and out, and put into a plastic bag before removal from the area.

When working in areas requiring the use of safety shoes or boots, the rubber boots must be an approved type having a hard toe safety shield inside the boot. If unable to properly decontaminate these items, they must be disposed of as ACM waste at the end of the project or properly transported on-site to the next containment.

f. Hard Hats: AES will always provide hard hats and require that they be worn when working on an asbestos abatement project when feasible.

Contaminated hard hats must remain in the work area until they can be thoroughly cleaned and decontaminated and placed into a plastic bag before removal from the work area at the end of the project.

g. Safety Glasses and/or Goggles: Where required, AES will provide eye protection in the form of either approved safety glasses or goggles for all employees on the jobsite. If taken into containment, the safety glasses and/or goggles must remain in the work area where they will be appropriately cleaned or disposed of as ACM waste at the completion of the project. In those cases where additional eye protection is deemed necessary, this will be provided by AES in the form of goggles. The same requirements for contaminated safety glasses also apply to goggles.

h. Work Gloves: AES will provide appropriate work gloves to all personnel in the work area. The gloves must remain in the work area until the completion of the project, at which time they will be appropriately cleaned or properly disposed of as ACM waste.

i. Hearing Protection: AES will administer an effective Hearing Conservation Program, as prescribed by OSHA in 29 CFR 1910.95, Occupational Noise Exposure, whenever employee noise exposures equal or exceed an 8 hour time weighted average (TWA) sound level of 85 decibels (dB) measured on an appropriate noise dosimeter. When worn in a contaminated area, this equipment will be disposed of as ACM waste at the end of the project.

6. Medical Surveillance Before the start of work, all AES personnel shall receive a physical examination in accordance with Standard 29 CFR 1926.1101(m). In addition to Standard 29 CFR 1926.1101(m), the following will apply:

1. The medical examination is to be conducted regardless of the number of days of anticipated or actual airborne exposure levels or the type of respiratory protection.

2. Proof of a current medical examination and respiratory fit test is mandatory before allowing access to the Work Area. Copies will be submitted prior to work start.

7. Training Programs In addition to the training requirements of Standard 29 CFR 1926.1101(k)(3)(ii & iii), the following shall be provided:

1. All personnel, except the competent person, entering the regulated area shall be trained in accordance with Standard 40 CFR 763.

Access will not be permitted until training is complete. Copies will be provided prior to work start.

2. The competent person shall have received the EPA-approved asbestos supervision certification, or the annual asbestos supervision re-certification (1-day training course) within the past year. (State of Delaware). Copies will be provided prior to work start.

3. If a worker’s anniversary date for training lapses, the worker is not allowed to continue with work until the required training has been performed and documentation submitted.

4. Copies of certification cards/papers (including dates) of the personnel taking and conducting training will be available at the job site.

5. Persons performing air monitoring shall have attended and passed the NIOSH course, Sampling and Evaluating Airborne Dust (NIOSH 582), or shall be a certified Health and Safety Technologist, Asbestos Project Inspector-In-Training, or Certified Asbestos Project Inspector.

6. Personnel performing analysis of airborne asbestos samples shall be included in the American Industrial Hygiene Association Analyst Registry (AIHA) or the NIOSH/AIHA Proficiency Analytical Testing Program.

8. Packaging Waste for Disposal

a. PACKAGING ASBESTOS WASTE FOR DISPOSAL AES will place the asbestos waste into appropriately labeled 6-mil thick impermeable polyethylene plastic disposal bags. The ACM waste must be wetted with sufficient water to ensure that it is adequately wet. Prior to gooseneck sealing, the bag should be collapsed to remove any trapped air that may later contribute to bursting. After the exterior of the sealed bag is wet cleaned to remove any gross material, it is then double bagged and sealed by goose necking and taping. The bagged and labeled ACM waste will then be stored in a secured area to await transport to the disposal site.

Asbestos waste cannot be mixed with any other type of construction waste from the site.

b. OSHA Warning Labels

In compliance with the OSHA Asbestos Standard, 29 CFR 1926.1101, the OSHA Hazard Communication Standard, 29 CFR 1926.59, and the EPA NESHAP Standard, all of which require each employer to ensure that all containers of hazardous chemicals in the workplace are labeled, tagged, or marked with the identity of the hazardous chemical contained therein, and an appropriate warning of the hazards of the chemical, all asbestos-containing waste disposal bags utilized by AES will be appropriately marked as follows:

DANGER

DANGER

CONTAINS ASBESTOS FIBERS

AVOID CREATING DUST

CANCER AND LUNG DISEASE HAZARD

WARNING

DO NOT BREATH ASBESTOS FIBERS

These labels must be three (3) inches high by five (5) inches wide and conform to the requirements specified in 29 CFR 1910.145 for danger labels or signs.

c. Generator Labels

NESHAPS requires that each bag of asbestos-containing material that is to be transported off the facility site, contain a visible label identifying the name of the waste generator (owner) and the location at which the waste was generated. This generator label must either be printed on the outside of the bag or it must be a separate label attached to the bag, or it can be a separate label that is inserted between the two poly bags if the outside bag is a clear bag that would allow the label to be read without opening the bag.

d. DOT Transportation Labels

In addition to the warning labels required by both OSHA and the EPA, the United States Department of Transportation (DOT) requires a “CLASS 9” warning label on each bag of asbestos-containing materials that is transported away from the removal site. The label should be as follows:

The “CLASS 9” (Miscellaneous Hazardous Materials) label should be approximately 100 m/m by 100 m/m in size and in addition to complying with Section 172.407; the background on the CLASS 9 label must be white with seven black vertical stripes on the top half. The black vertical stripes must be spaced, so that, visually, they appear equal in width to the six white spaces between them. The lower half of the label must be white with the class number ``9'' underlined and centered at the bottom.

e. Adequately Wet

NESHAPS describes the wording adequately wet as meaning to sufficiently mix or penetrate the ACM with a liquid to prevent the release of particulates.

An adequate amount of the liquid control device (amended water) must be mixed with the ACM to form a slurry. AES will make certain that enough water is in each bag of ACM to readily enable an observer to view the water without having to open the bag.

f. Leak-Tight Seal

NESHAPS states that each bag containing asbestos materials must have a "leak-tight" seal. This means that solids or liquids cannot escape or spill out.

It also means dust tight. Since NESHAPS also requires that the bagged ACM be sufficiently wet, a proper seal must also ensure that the water in the bag does not have sufficient air to evaporate thereby allowing the fibers to dry out and become airborne. In order to accomplish this "leak-tight" seal, the two bags must be individually "gooseneck" sealed. This is done by twisting the top of the bag to form a long twist and then bending over the top of the twisted portion and taping it to the bottom of the twisted portion, thereby forming the "gooseneck." In doing this, a small amount of air is trapped in the gooseneck which provides a leak-tight seal. Each of the two bags must be separately sealed in this manner.

G. PROJECT SPECIFIC ABATEMENT PLAN

1. Pre-Abatement Activities

• AES will notify the EPA and the State of Delaware of the asbestos abatement project.

• A pre-abatement kick-off meeting will be held onsite with all necessary stakeholders in order to coordinate specific aspects of the abatement work.

• AES will have a waste dumpster delivered to the site and be placed in the street (attached drawing).

• AES will isolate and contain the work areas (basement excavations and mechanical room) as described in Sections E.1 and E.2 above.

• An Independent Third Party (Wood subcontractor Vertex) will perform a pre-abatement inspection for the basement and mechanical room prior to

2. Phase 1A Excavation In accordance with the coordination call held on August 25, 2020, EAC will perform excavation activities of impacted soils within two (2) one-meter square locations, approximately 22 SF to a depth of approximately nine inches. See ATTACHMENT A (provided at the end of the work plan) for specific requirements to be followed for EAC during the Phase 1 excavation. Wood and AES will provide oversight (a Delaware licensed Asbestos Abatement Supervisor) and support for EAC during the Phase 1 excavation activities. EAC will systematically remove impacted soil and set it outside of the excavation areas. Although, daily air monitoring is not required in Delaware on non-state projects; the Wood team has included 1 day per week of daily air monitoring for Phase 1 activities performed by Vertex. For the daily air monitoring, Vertex will utilize high-volume intake air pumps calibrated to allow a sufficient volume of air to pass through a mixed cellulose ester filter for fiber collection.

Once all EAC’s activities are completed, EAC will then inform Wood and AES that the excavated soil can be placed in 6-mil disposal bags and removed from the basement to an ACM waste holding area for transportation and disposal. There is an expected delay of approximately two weeks in the project schedule between EACs activities and Wood and AES receiving approval from EAC to remove the soil from the basement.

3. Phase 1B Excavation AES will perform excavation activities of impacted soils within the basement (approximately 1,200 SF area) to a depth of approximately nine inches. Phase 1B excavation activities will include the removal of Phase 1A stock-piled soil. Phase 1B does not require the archaeological procedures that were used in Phase 1A.

Wood and AES will work with EAC to assist them with general archaeological monitoring during the Phase 1B excavation activities. This will include Wood/AES contacting EAC when a potential artifact is uncovered. The artifact will be set aside in a demarcated safe area until AEC arrives and determines the validity of the artifact (save or discard). AES will continue excavation activities in a separate area of the basement. During Phase 1B, impacted soil will be misted, placed in 6-mil disposal bags, and removed from the basement to an ACM waste holding area for transportation and disposal. (attached plan). The Wood team has included 1 day per week of daily air monitoring by Vertex for Phase 2 activities.

4. Phase 2 - Mechanical Room Activities AES will remove the asbestos cementitious ceiling (transite) panels by pulling the existing…