Attachment 5 - SOW - FrogSwitch Hazmat Survey Rev1.pdf

U.S. Department of Transportation Volpe National Transportation Systems Center Hazardous Building Materials Sampling Survey

Frog, Switch & Manufacturing Company, Carlisle, PA

STATEMENT OF WORK

1.0 INTRODUCTION

Under an Interagency Agreement, the U.S. Department of Transportation John A. Volpe National Transportation Systems Center (Volpe Center) is providing support to the U.S. Environmental Protection Agency (EPA) Targeted Brownfields Assessments (TBA) program. As part of this effort, a sampling survey of hazardous building materials, including but not limited to asbestos-containing materials (ACM), lead-based paint (LBP), and polychlorinated biphenyls (PCBs), will be conducted at the former Frog, Switch & Manufacturing Company (the Site) located at 600 East High Street, Carlisle, PA.

2.0 BACKGROUND

The purpose of this survey is to identify and document the presence, locations, and quantities of hazardous building materials, primarily ACM, LBP, and PCBs to support planning for potential renovation, demolition, or redevelopment activities in compliance with local, state, and federal regulations.

Site location layout maps are included as Attachments 1 and 2 respectively.

3.0 TASKS TO BE PERFORMED

The investigation includes the Contractor tasks listed below. The contractor must be a Pennsylvania certified asbestos inspector. The Contractor shall conduct all work in accordance with Federal, State and local requirements. Where inconsistencies exist, the Contractor shall follow the most stringent requirement.

3.1 Work Plan

The Contractor shall submit a simplified draft Work Plan within 5 business days after attending a kickoff meeting with Volpe Center representatives that addresses the project requirements below.

The Work Plan shall detail the technical approach and schedule for conducting all activities as required and described below. To assist with the preparation of the Work Plan, the contractor shall thoroughly review any Government-furnished information (GFI).

In addition, the Work Plan shall also identify any required permits needed to perform the work and the contractor shall be responsible for obtaining those permits as required. Copies of the permits shall be attached to the work plan as an appendix. If no permits are required, the Work Plan shall cite the justification for this.

The contractor shall include insurance and credentials information in their work plan. The contractor shall provide proof of:

• PA asbestos and lead inspector certifications

• Laboratory accreditations

• OSHA HAZWOPER Training compliance

An additional component of the Work Plan is the Site Safety and Health Plan (SSHP), which shall include personnel health and safety precautions to be followed to ensure the health and safety of onsite personnel while completing the effort. The SSHP shall include:

• Appropriate PPE per OSHA requirements for all onsite field staff.

• Confined space entry protocols, if needed.

• Methods for ensuring site is safe and accessible for all sampling activities.

The work plan shall also include a Risk Management Plan that identifies major risks and hazards on each site and discusses ways to minimize these risks.

An outline summarizing the required content of the work plan is shown below:

1.) Technical Approach

a. Methods and procedures, including equipment, methods, and materials to be used, for activities described below 2.) Site Safety Health Plan 3.) Risk Management Plan

a. Identification of major risks

b. Risk mitigation plan

4.) Appendix

a. Copies of any state or local permits, certifications, accreditations, trainings, or other supplemental information The Contractor should expect a 5-business day Volpe Center review period between submission of the Draft Work Plan and receipt of Volpe Center comments. The Volpe Center and the Contractor shall meet to discuss any comments and changes, if necessary. The Contractor shall make the changes and submit a Final Work Plan within 5 business days of the receipt of comments.

3.2 Site Reconnaissance

Prior to the inspections the contractor will:

• Conduct a site walk with Volpe staff and/or owner’s representative.

• Review historical data, building drawings (if available), and prior environmental reports.

3.3 Asbestos Surveys

A Pennsylvania certified asbestos inspector will perform comprehensive, AHERA-compliant sampling of asbestos-containing materials of all accessible areas at the 14 Site structures. Building inspections will be performed in accordance with Volpe SOP-024 Hazardous Building Materials Survey. The contractor will:

• Identify suspect ACM containing materials such as but not limited to:

o Pipe insulation o Floor tiles and mastic o Roofing materials o Wall and ceiling plaster or joint compound o Thermal insulation

• Collect a representative number of bulk samples (~200-400 estimated)

• Submit samples to a NVLAP-accredited laboratory using Polarized Light Microscopy

(PLM)

• Document quantities and locations on site maps or drawings.

3.4 Lead-Based Paint Survey

The contractor will perform lead-based paint inspections of all accessible areas at the 14 Site structures. Building inspections will be performed in accordance with Volpe SOP-024 Hazardous Building Materials Survey. The contractor will:

• Screen painted surfaces throughout the building using XRF (X-ray fluorescence).

• Collect additional paint chip samples, as needed, for laboratory analysis (TCLP or total lead).

• Evaluate painted surfaces including walls, doors, windows, piping, and equipment.

3.5 Other Hazardous Materials Survey

The contractor will also perform an inspection of other hazardous materials associated with building materials at all accessible areas for the 14 Site structures, including but not limited to:

PCBs, refrigerants, mercury lamps, etc. Building inspections will be performed in accordance with Volpe SOP-024 Hazardous Building Materials Survey. The contractor will:

• Identify and document other potentially hazardous building components such as:

o Fluorescent light ballasts (PCBs) o Mercury-containing devices (thermostats, switches) o Universal waste (batteries, exit signs)

• Note any areas of suspect chemical staining or storage residues.

3.6 Site Close-out

The Contractor shall provide a brief closeout email, detailing the work completed.

3.7 Reporting

The contractor shall prepare a report including:

• Executive summary

• Methodology

• A summary table of sample locations and results

• Material quantities and condition assessments

• Annotated site plan(s)

• Photographs of materials confirmed as hazardous

• Regulatory compliance summary

• Recommendations and estimated costs for abatement and/or further evaluation

• Copy of laboratory analytical reports

• Chain of custody forms and lab certificates of analysis

4.0 DELIVERABLES

The Contractor shall prepare the following required deliverables in the quantities described in Table 1 below:

Table 1 - Deliverable Schedule and Details Deliverable Name Format # Copies Date Due/ Recipient

Draft Work Plans Electronic; MSWord* 1 10 business days after kickoff meeting with Volpe; send to technical point of contact (TPOC) and altPOC

Final Work Plans Electronic MSWord*;

Electronic .pdf

5 business days after receipt of govt comments; send electronic copies to TPOC and altPOC

Report Electronic 1

15 business days after site demobilization

5.0 SCHEDULE

The Contractor shall work with the Volpe Center to prepare a schedule for completing the above-described tasks in this SOW and shall include it with their technical proposal. The Government would like this work completed as soon as possible. The period of performance for this effort shall be from date of award to September 1, 2025 with the field work being completed as soon as possible after contract award. Approximate work hours are from 8:00 a.m. to 4:30 p.m. Monday through Friday. There is to be no work on the weekends, Government holidays, or outside of set work hours unless approved and coordinated with the Volpe Center TPOC. In consideration of the EPA TBA project locations and contract period of performance, schedule delays or impacts stemming from inclement or extreme weather will be evaluated as needed.

6.0 TRAVEL

Contractor travel may be required. All travel costs shall be built in and included in the pricing of line items for which travel may be required and in total fixed price amount.

7.0 PROJECT COORDINATION AND SITE ACCESS

The Contractor shall coordinate all activities and access through the Contracting Officers Representative (COR).

8.0 COR

Emilio Paleo Environmental Engineer USDOT/Volpe Center/V326 22 Binney Street Cambridge, MA 02142 Tel: (617) 494-3614 Cell: (857) 270-8344 Email: emilio.paleo@dot.gov

9.0 Government Furnished Information (GFI)

1. Site Location

2. Site Layout

3. Volpe SOP-024 - Hazardous Building Materials Survey

Attachment 1 Site Location mailto:emilio.paleo@dot.gov

¯0 400 800 1,200 1,600 Feet

Attachment 1 Site Location

Field Sampling Plan

Frog, Switch & Manufacturing Company 600 East High St

Carlisle, PA

U.S. Department of Transportation Volpe National Transportation Systems Center

May 2025

Spatial Reference:

NAD 1983 UTM Zone 18N Upper Left: 1027895E 14611347.97N ft

Sources: Sources: Esri, TomTom, Garmin, FAO, NOAA, USGS, (c) OpenStreetMap contributors, and the GIS User Community, Sources: Esri, TomTom, Garmin, FAO, NOAA, USGS, © OpenStreetMap contributors, and the GIS User Community, Esri, USGS, Maxar

0 40 80 Miles

Property Boundary (approx.)

02-21-0318-353

-21

-03 -04

-2 1- -0

-2 1- -0

-2 1- -0

-2 1- -0

-2 1- -0

02-21-0316-047

-2 1- -3

-2 1- -3

0 250 500 Feet

Tax Parcels

Site Location

Attachment 2 Site Layout

¯0 100 200 300 400 Feet

0 500 1,000 Feet

Notes:

1) Approximate square footage of site structures and accessibility is currently unknown.

Attachment 2 Site Layout

Hazardous Material Survey Frog, Switch & Manufacturing Company

600 East High Street, Carlisle, PA

U.S. Department of Transportation Volpe National Transportation Systems Center

May 2025

Spatial Reference:

NAD 1983 StatePlane Pennsylvania South FIPS 3702 Feet Upper Left: 2127931.38E 317495.71N ft

Sources: Sources: Esri, TomTom, Garmin, FAO, NOAA, USGS, © OpenStreetMap contributors, and the GIS User Community, Maxar

Legend

Property Boundary (approx.)

Attachment 3 Volpe SOP-024 - Hazardous Building Materials Survey

SOP 024 – Hazardous Building Materials Survey Page 1 of 4

1.0 Introduction

Environmental investigations may include the assessment of buildings or structures that potentially contain hazardous building materials. This can include but is not limited to asbestos-containing materials, lead-based paints, and PCB-containing materials. This Volpe SOP outlines the procedures for conducting a hazardous building materials survey and should be used by Volpe in conjunction with the professional judgement of an accredited inspector.

This SOP does not cover the proper use of respiratory protection which should be appropriately utilized by the inspector in accordance with the contractor’s HASP and SOPs.

2.0 Definitions

1. Asbestos-containing Material (ACM) – a material that contains greater than 1% asbestos

2. Friable – ACM that can be crumbled, pulverized, or crushed into a powder with hand pressure when dry

3. Surfacing Material (SM) – ACM that is sprayed, troweled, or otherwise applied to surfaces (walls, ceilings, structural members) for acoustical, fireproofing insulation, or for other purposes such as decoration.

4. Thermal System Insulation (TSI) – ACM applied to pipes, boilers, tanks, ducts, etc. to prevent heat loss, heat gain, or water condensation

5. Miscellaneous (MISC) – ACM that does not include SM or TSI

6. Lead-based Paint – Paint that contains lead at concentrations greater than or equal to 0.5% by weight, or 5,000 mg/kg

7. Polychlorinated biphenyl (PCB)-containing material – a material that contains PCBs at greater than or equal to 50 parts per million by weight

3.0 Equipment

1. Personal protective equipment (PPE)

2. Warning signage

3. Site-specific Health and Safety Plan (HASP)

4. Field notebook

5. Camera

6. Contractor/Inspector-supplied sampling equipment

7. Paint scraper

8. Utility knife

9. Hand tools (e.g. screwdriver, wrench, etc.)

10. Pocket scale

Standard Operation Procedure (SOP) Prepared: J. Klaybor

Title: Hazardous Building Materials Survey Reviewed: C. Fry

No: 024 Ver. 1.0 Date: 06/09/23 Approval: M. Heimgartner

SOP 024 – Hazardous Building Materials Survey Page 2 of 4

11. Sample containers

4.0 Procedures

1. Once a building inspection is deemed necessary, Volpe shall contract the appropriate person(s) to complete the work. Volpe will share the survey scope and pertinent details with the inspector including building plans, photographs, and previous inspection survey reports as they are available. Volpe shall inform the inspector whether or not destructive samples may be collected as part of the survey.

2. The inspector shall be accredited under the Asbestos Hazard Emergency Response Act (AHERA) to conduct an asbestos building inspection. The inspector must additionally be licensed by the state in which the building is located, if applicable. The inspector shall provide a copy of all certifications and licenses to the Volpe Program Manager prior to conducting the work.

3. Volpe will coordinate building access with the site owner and EPA during a time that minimizes disturbances.

Ensure that all parts of the building will be accessible and unlocked. If any parts of the building are unsafe or otherwise inaccessible, communicate this with the inspector and ensure that this information is included in the final survey inspection report.

4. Begin the inspection by performing a building walk through with the inspector and site owner to review the building layout and identify areas where sampling will be required.

4.1 Asbestos

5. An asbestos building inspection may be included as part of the hazardous building materials survey. The inspector shall inspect for friable and non-friable ACM by either collecting bulk samples and having them analyzed or assuming a material contains asbestos. The inspector shall coordinate with Volpe to develop a sampling plan, which should generally include the collection of the following bulk material samples for asbestos analysis:

a. For surfacing material, a minimum of three samples shall be collected from each homogeneous area that is 1,000 ft2 or less, five from each homogenous area that is greater than 1,000 ft2 but less than or equal to 5,000 ft2, and seven from each homogeneous area that is greater than 5,000 ft2.

b. For thermal systems insulation, a minimum of three samples shall be collected from each area plus one sample per patched section if the patch is less than six square or linear feet. No samples need to be collected from any homogenous area of thermal system installation if the inspector determines that the TSI is fiberglass, foam, rubber, or other non-asbestos-containing building material.

c. For miscellaneous material, a minimum of two samples shall be taken from each homogeneous area of friable miscellaneous material.

d. A material may be assumed to be ACM instead of sampled.

6. If bulk material samples are to be collected, the area should be secured so that all persons not directly involved in the sample collection are excluded from the work area. Warning signs shall be posted at each entrance.

7. The inspector shall don all appropriate PPE according to regulations, the HASP, and contractor SOPs. This includes but is not limited to a properly fitting respiratory protection, gloves, eye protection and, if friable asbestos is expected to be disturbed, protective clothing.

8. The inspector shall collect bulk samples according to their own SOPs but should follow best practices including ensuring that the area being sampled is sufficiently wet, decontaminating sampling tools between sample locations, and minimizing disturbance to the material being sampled.

SOP 024 – Hazardous Building Materials Survey Page 3 of 4

9. The inspector shall map the location of all samples on a drawing that includes the building layout and sample IDs.

10. All bulk material samples shall be sent to a state-certified laboratory to be analyzed by either transmission electron microscopy (TEM) or polarized light microscopy (PLM) as deemed appropriate by the inspector. Positive stop analysis may be utilized when asbestos is identified at a concentration greater than 1% in one of multiple samples of similar material.

11. The inspector shall prepare and submit an asbestos building inspection survey report that includes a summary of materials identified or assumed to be ACM. A description of each ACM shall include the material’s location, condition, friability, length or area, and a photograph. The sample location drawings, laboratory analytical results, and inspector certifications shall be appended to the report.

4.2 Lead

12. Paints produced prior to 1978 may be lead-based. A hazardous building materials survey may include the analysis of paints to determine lead concentrations. Paint may be surveyed by a contracted inspector or by Volpe field staff who have been trained in sample collection if the surfaces to be sampled are known to not be ACM.

13. Each unique color and layer of paint on the building’s interior and exterior shall be sampled.

14. The sampler shall don appropriate PPE according to the HASP, which includes gloves and eye protection.

15. Use a razor-sharp scraper to remove a four-square inch section of paint from the painted surface.

16. Place the paint in a sample container and ship to the laboratory for lead analysis. Handle samples in accordance with Volpe SOP-019.

17. For non-destructive sampling or sample screening, an X-ray fluorescence (XRF) handheld scanner may be used by a trained individual to estimate lead content.

18. Photographs, location drawings, and sample results shall be included in the survey report. Field activities should be recorded in the field notebook by Volpe Staff in accordance with Volpe SOP-001.

4.3 PCBs

19. Building materials produced between 1950 and 1979 such as paints, caulks, and coatings may contain PCBs. A hazardous building materials survey may include the analysis of building materials to determine PCB concentrations. Materials may be surveyed by a contracted inspector or by Volpe field staff who have been trained in sample collection if the surfaces to be sampled are known to not be ACM.

20. Each unique building material that may include PCBs on the building interior and exterior shall be surveyed.

21. The sampler shall don appropriate PPE according to the HASP, which includes gloves and eye protection.

22. Use a razor-sharp scraper to remove approximately 10 grams of material.

23. Place the paint in a jar and ship to the laboratory for PCB analysis. Handle samples in accordance with Volpe SOP-

019.

24. Light ballasts may also be included in the survey. Ballasts that do not have a “No PCBs” sticker may be assumed to contain PCBs.

25. Photographs, location drawings, and sample results shall be included in the survey report. Field activities should be recorded in the field notebook by Volpe Staff in accordance with Volpe SOP-001.

4.4 Other Materials

26. Hazardous materials other than asbestos, lead, and PCBs may be included in a hazardous building materials survey

(such as mold, etc.) and should be assessed in accordance with best practices and industry standards as identified in an inspector’s work plan and approved by the Volpe Program Manager.

SOP 024 – Hazardous Building Materials Survey Page 4 of 4

5.0 Quality Assurance and Control (QA/QC)

The Volpe Program Manager is responsible for ensuring that the inspector is accredited according to applicable regulations. Volpe Field Staff are responsible for ensuring that the survey is completed according to scope and under the appropriate procedures. All samples for analysis shall be sent to a state-certified laboratory.

6.0 Limitations and Precautions

Asbestos and other hazardous building materials pose a risk to human health. Inspections that disturb these materials should be handled with extreme care and follow best practices. This SOP does not cover the use of respiratory protection, which should be appropriately utilized by the inspector in accordance with applicable regulations and contractor’s HASP and SOPs. Hazardous building materials surveys should only be conducted by an inspector who is appropriately certified and/or licensed according to applicable federal and state regulations. The professional judgement of the inspector and applicable local laws may and should supersede the procedures of this SOP when necessary and as approved by the Volpe Program Manager.

7.0 References

EPA. (2013). Guidance Document: Bulk Sampling for Asbestos; SESDGUID-104-R1

EPA (2021). PCBs In Building Materials: Determining the Presence of Manufactured PCB Products in Buildings or Other Structures

HUD. (n.d) Appendix 13.2 Paint Chip Sampling