SOP_27_Remediation_of_Asbestos_Contam_Soils_04-10.pdf

SOP NO. 27

STANDARD OPERATING PROCEDURE

For

REMEDIATION OF ASBESTOS CONTAMINATED SOILS

Denver Federal Center Site-wide RCRA Facility Investigation

Prepared for:

General Services Administration

Rocky Mountain Region Denver, Colorado

Prepared by:

URS Corporation

November 2009

Revision 1.0

Denver Federal Center SOPs Revision No. 1.0

April 2010 Page i of ii

SOP NUMBER 27 REMEDIATION OF ASBESTOS CONTAMINATED SOILS

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1.0 INTRODUCTION .........................................................................................................27-1

2.0 GENERAL SITE DESCRIPTION AND PREPARATION ..........................................27-1

2.1 Type and Extent of Asbestos Material in Soil ...........................................................27-1

2.2 Asbestos Surface Assessment and Type of Controls to be Used for Remediation....27-2

2.3 Worker Training.........................................................................................................27-3

2.4 Mobilization...............................................................................................................27-4

3.0 PLANNED SOIL DISTURBING ACTIVITIES...........................................................27-5

3.1 Soil Removal Techniques ..........................................................................................27-5

3.2 Containment of Contamination..................................................................................27-7

3.3 Site Access Control....................................................................................................27-7

3.4 High Wind Work Stoppage for ACM remediation....................................................27-7

4.0 AIR MONITORING......................................................................................................27-8

4.1 Personnel Monitoring.................................................................................................27-9

4.2 Perimeter Monitoring.................................................................................................27-9

4.3 Positive TEM Results ..............................................................................................27-10

5.0 DECONTAMINATION ..............................................................................................27-10

5.1 Worker Decontamination.........................................................................................27-11

5.2 Decontamination Water Disposal ............................................................................27-11

6.0 WASTE HANDLING..................................................................................................27-12

6.1 Loading ....................................................................................................................27-12

6.2 Packaging.................................................................................................................27-12

6.3 Transportation ..........................................................................................................27-13

6.4 Disposal....................................................................................................................27-13

6.5 Demobilization.........................................................................................................27-13

7.0 CLEARANCE SAMPLING AND INSPECTION ......................................................27-13

7.1 Visual Inspection .....................................................................................................27-14

7.2 Soil Sampling...........................................................................................................27-14

8.0 CLOSURE REPORT...................................................................................................27-15

April 2010 Page ii of ii

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REVISION LOG

Revision Number Description Date

0.0 Original SOP No. 27 (prepared by Pacific

Western Technologies)

November 2009

1.0 SOP No. 27 April 2010

April 2010 Page 27-1 of 27-17

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1.0 INTRODUCTION

Simultaneous with the excavation of the chemical contaminated soils are asbestos-contaminated soil which will be encountered and excavated concurrently. This document outlines the engineering controls and air monitoring requirements that will be followed during the excavation of any grids or lots containing asbestos-contaminated soil (ACS), which includes areas with asbestos-containing material (ACM) and/or detectable concentrations of asbestos. Table 1 (attached) lists the requirements for the different asbestos types discussed in this document.

At the bottom of the SOP is a statement that is required to be signed by a Colorado Certified Asbestos Project Designer doing the remediation and accepting the SOP. This shall be in addition to a formal Soil Characterization and Management Plans (may be: RCRA Facility Investigation report, Corrective Action Work Plan, or other work plan directing remedial actions).

2.0 GENERAL SITE DESCRIPTION AND PREPARATION

Prior to commencing any soil disturbance, a surface asbestos assessment survey is required to be performed. In accordance with SOP No. 26, 25 foot by 50 foot inspection grids shall be established, for each 100 foot by 100 foot lot, in areas requiring inspection, and shall be inspected by a Colorado Asbestos Building Inspector with 6 months of ACS experience (certified state asbestos inspector). If any ACM or ACS is identified, and the grid cannot be cleared by sampling after the removal of all ACM, the grid must be managed in accordance with the protocol outlined in this SOP.

Any equipment stored or used in a contaminated area shall require decontamination in accordance with Section 5 of this SOP and SOP No. 1. Gross decontamination using water spray may be performed on tires of vehicles prior to moving from the contaminated area onto a clean area, or, equipment as it is driven out of a contaminated area on to polyethylene sheeting, or a designated decontamination area. In the latter case, all decontamination water and residual soils will be placed back on a grid which has a commensurate classification for disposal. All decontamination shall be in accordance with Section 5 of this SOP.

2.1 TYPE AND EXTENT OF ASBESTOS MATERIAL IN SOIL

The asbestos assessment will specify four (4) types of contaminated soil. Each type of soil will require slightly different engineering and monitoring controls during excavation and transportation.

• Type One contaminated grids contain friable asbestos as debris, and may also contain asbestos as determined by PLM analysis. These grids must be managed and disposed as friable asbestos.

• Type Two contaminated grids have been broken down into two sub-classifications A, B.

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Type 2A: contain widespread transite, or other non-friable ACM, where limited quantities (less than 25 pieces per grid) of non-friable asbestos debris observed in the soil but no sampling was performed to confirm the presence or absence of asbestos in the soil. These grids are considered potentially friable and asbestos-contaminated for the purpose of engineering and monitoring controls during the excavation process. However, as long as no friable asbestos debris is identified during excavation, soil from these grids will be disposed of as non-friable asbestos waste.

Type 2B: contained widespread asbestos (friable or non-friable asbestos) observed in the soil but all visible asbestos was removed using SOP No. 26 protocols. Soil sampling was performed with ACS detected in the soils. These grids are considered potentially friable and asbestos-contaminated for the purpose of engineering and monitoring controls during the excavation process. However, as long as no friable asbestos debris is identified during excavation, soil from these grids will be disposed of as non-friable asbestos waste.

• Type Three contaminated grids are grids where transite or other non-friable asbestos was observed in the soil but subsequent soil sampling and analysis (PLM analysis) determined no fibers of asbestos in the soil. These grids will require less stringent pre-wetting and air monitoring requirements. Soil from these grids will be disposed of as non-friable asbestos waste.

For purposes of this SOP Type One and, Type Two A&B grids will be excavated using engineering controls and air monitoring for friable asbestos in soil. Type Three grids will be excavated using engineering controls and air monitoring for non-friable asbestos in soil.

2.2 ASBESTOS SURFACE ASSESSMENT AND TYPE OF CONTROLS TO BE USED

FOR REMEDIATION

A surface asbestos assessment will be conducted prior to initiation of any excavation. A shoulder- to-shoulder surface inspection will be conducted per SOP No. 26 by certified asbestos inspector(s). The following procedures will be followed:

• If visible ACM is present in any grid, follow SOP No. 26, including collection of soil samples for PLM analysis.

• Sample for PLM analysis all grids associated with the footprint of former building locations whether or not visible ACM is observed.

• Review all PLM results. If positive for asbestos in soil, schedule excavation of the grid using Type 1 controls/procedures for asbestos. Collect confirmation soil samples for asbestos following excavation in accordance with Section 7 of this SOP.

If PLM is negative and any ACM has been cleaned up per SOP No. 26, grid is considered uncontaminated and cleared for surface asbestos in soil. However, if negative for PLM but visible ACM was observed on the surface at > 3-5 pieces in a 15-foot radius or friable ACM was present (possibly suggesting that the asbestos may be more widespread than currently seen or may be present at depth), these grids, if

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If during the surface asbestos assessment, greater than 25 pieces of ACM are present in any one grid, then the inspector will stop activities in that grid and contact GSA. GSA and CDPHE will then determine, based on the nature and pervasiveness of the ACM, whether to forgo sampling and condemn the grid for Type 2 remediation (if ACM is nonfriable) or Type 1 remediation (if ACM is friable), or continue with the assessment under SOP No. 26.

At the end of the asbestos surface assessment and prior to start of any excavation, an updated map (Figure J-1) will be generated identifying all asbestos grids and the Type of asbestos controls/procedures (Type 1-4) applicable to each grid. The map and sample results will be reviewed and approved by GSA and CDPHE prior to start of excavation in the area. Following completion of excavation, confirmation samples will be collected for PLM analysis per Section 7 of this SOP.

2.3 WORKER TRAINING

Personnel overseeing, directing, inspecting and/or handling asbestos and asbestos contaminated soil (including suspect asbestos soils) shall have, at a minimum and as appropriate to the work activity, the following training and experience:

• Individuals performing soil-disturbing activities in areas where asbestos has not been identified, but where there is reason to believe that asbestos may be encountered, are required to complete two-hour on-the-job asbestos-contaminated soil awareness training.

The training must provide information necessary to perform their duties in a way that ensures compliance with the requirements of Section 5.5 of the Solid Waste Regulations, and must be conducted by a person trained in asbestos identification and management procedures and who has a minimum of six (6) months experience in asbestos-contaminated soil management. On this job site, the awareness training would be for GSA and CDPHE personnel inspecting the work, off site QC and safety personnel who occasional perform inspection on the site, project management, and field support personnel and environmental technicians who are assisting with the chemical remediation.

• Individuals performing soil-disturbing activities in an area with asbestos-contaminated soil are required to complete the on-the-job asbestos-contaminated soil awareness training discussed above, and the OSHA asbestos awareness training set forth at 29 CFR 1926.1101(k)(9)(vii). In addition, excavation equipment operators, workers working in wind enclosure or exclusion zone/in close proximity of active soil disturbing activities, field spotters, field workers operating spraying/misting system at the working face of the excavation, spraying at the load out station shall be current Colorado Certified Asbestos Workers (Air Quality Control Commission, Regulation No. 8, Part B, Part II). Certified Asbestos Workers will be overseen by a Certified Abatement Supervisor.

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• Individuals performing abatement of facility components, in accordance with Section

5.5.1 (B) shall be certified Asbestos Workers. If threshold qualities of facility components are exceed, then Air Quality Control Commission, Regulation No. 8, will be followed with a Certified Management Planner, Project Designer, developing the abatement plan and submitting the permit request.

• Individuals performing inspection and identification of asbestos in soil must have a current Asbestos Building Inspector certification in accordance with Air Quality Control Commission Regulation No. 8 (5 CCR 1001-10, Part B), and must have a minimum of six (6) months experience in asbestos-contaminated soil inspections. Resume documenting asbestos in soil inspection will be provided to GSA for approval.

• Individuals performing air monitoring must have a current Air Monitoring Specialist certification in accordance with Air Quality Control Commission Regulation No. 8 (5 CCR 1001-10, Part B).

In addition, individuals with the potential for exposure to asbestos fibers shall be trained in the proper usage of personnel protective equipment and have a current annual physical with a medical release / respirator usage form.

2.4 MOBILIZATION

For the asbestos remediation portion of the project, mobilization includes perimeter signage with asbestos warning signs, Fact Sheet distribution to the neighboring government employees and off site businesses which border the nearest side of the DFC, placement of personal hygiene and decontamination shower trailers or stations, placement of lined lidded roll off containers for temporary storage of bags of asbestos and PPE, and staging of decontamination stations for trucks and equipment. Haul routes will be reviewed for conformance with the existing transportation plan. Haul roads and loading areas will be located on established roadways or clean areas. Loading areas over contaminated soil will have sufficient cover over the contaminated soil (either clean soil or plastic sheeting) that will prevent cross contamination or the spread of contamination.

For Type One and Type Two A&B contaminated grids, six-foot high windbreak barriers shall be erected around the immediate work area to be impacted prior to commencement of remediation activities. A water misting system or a equivalent system of control approved by CDPHE shall be set up around each work area or direct mounted to the excavation equipment. The misting system may be constructed of PVC piping or hoses that will generate a low energized mist of water droplets large enough to minimize drift but fine enough to control any fiber emissions generated from the work area without over-saturating the soil.

For large projects, with widespread removal of ASC, the requirement for the use of windbreak barriers may be modified or waived by GSA, with concurrence from CDPHE, as long as the remaining engineering controls are deemed adequate to prevent the release of asbestos fibers from the work area.

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3.0 PLANNED SOIL DISTURBING ACTIVITIES

3.1 SOIL REMOVAL TECHNIQUES

Type One and Type Two A&B contaminated grids - Twenty-four hours in advance of soil disturbing activities, the work area will be adequately wetted to prevent any fugitive dust emissions that may be generated during mobilization and site setup. Shorter pre-wetting time frames may be allowed if it can be demonstrated that adequate infiltration is achieved. In order to prepare the work area, amended water shall be applied using a mechanism to allow sufficient penetration of water into the soil, such as application with a sprinkler system, water truck, or use of a series of root watering wands. Surface wetting will be completed in such a manner as to prevent generation of fugitive dust emissions, run-off or splattering. During actual soil disturbing activities, water will be applied to the site of the disturbance as appropriate to suppress any fugitive dust emissions. All soils (Type One and Two A&B) being handled or removed shall be adequately wetted in accordance with the “Asbestos NESHAP Adequately Wet” guidance document issued by EPA in December 1990.

Type Three contaminated grids will not require pre-soaking; however, to prevent emissions from surface soil, pre-wetting of the working surface may take place at approximately thirty minutes prior to commencing excavation activities. Adequate dust control protocols will be instituted whether the soil is chemical or asbestos contaminated during all excavation practices. Removal of asbestos-contaminated soil will be completed with properly equipped heavy equipment to minimize fugitive dust emissions at the point of removal. Performance requirement is issuance of no visible emissions from the excavation area.

Removal equipment: Utilizing equipment appropriate to the site conditions (pound track hoe, water truck with multiple hoses, etc.) soil excavation will proceed within each designated work area. Excavation equipment will be fitted with a spray bar to contain any emissions inadvertently generated during the removal process, as well as a hand held misting system/water spray at the excavation point to ensure adequate soil wetting. Excavation of asbestos-contaminated soil will not overreach the bounds of wetting. For projects involving relatively shallow ACS occurrence, excavation will be conducted in 6 inch and 1 foot lifts to ensure that disturbed soil remains adequately wet. For projects involving ACS at depth, such as a landfill, excavation in lifts may not be practical. In these instances, wetting may take place as the excavation proceeds, with wetting being conducted using hand held, low pressure, hoses. The soil may be mixed within the excavation, using the excavator bucket, until it is adequately wet.

The soil may then be moved from the excavation into the lined trailer. At no time shall soil that is not adequately wet be removed from the excavation. During the removal process, all areas of impact will be kept adequately wet with amended water.

Amended water will be applied at low pressure so as not to generate dust or splattering and will be applied at the point of contact. The excavator will handle the material wet and direct load the soil into a tractor trailer or end dump. For Types Two A&B removals, the trailer will contain a single leak tight liner constructed of 6 millimeter polyethylene sheeting. In the case of Type One

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Removal of asbestos-contaminated soil shall be performed concurrent with removal of chemical contaminated soil. All equipment will remain on clean soil when feasible or staged on sufficient cover to avoid cross contamination as described in the previous section. Uncontaminated soil in the swing radius of heavy equipment will be covered to prevent possible contamination during removal activities.

The Contractor’s project manager, project supervisor, or onsite safety officer will monitor the work area under active soil removal at all times. All asbestos-contaminated soil that is not under active removal will be isolated and marked so as to prevent the spread of contamination. No equipment, hoses, or personnel will operate on or cross over asbestos contaminated grids.

If at any time fugitive dust emissions are observed, all removal activities will immediately cease until such time as the work practices are altered so as to prevent further generation of dust emissions. Occurrences of fugitive dust emissions will be documented in the site record.

Each excavation, whether chemical or ACS, will be monitored by a spotter and a state certified asbestos inspector during removal activities. If subsurface anomalies are encountered, all work in that area will stop and the CONTRACTOR’S project supervisor and GSA shall be notified.

Work should proceed then only when directed by the CONTRACTOR and GSA.

If during a chemical lot excavation where ACM has not been previously identified, ACM is discovered, work will stop and the site will be assessed by the CONTRACTORS supervisor and the state certified asbestos inspector. If the ACM is a localized event of less than three (3) to five

(5) pieces of non-friable ACM in a fifteen foot radius the abatement contractor will follow the clean up procedures in SOP No. 26, bag the material, and continue the chemical excavation. At the end of the chemical excavation of the lot, the area of the ACM material will be sampled as per Section 7 of this SOP. If the non-friable ACM is more than 5 pieces in an area larger than fifteen feet, or the ACM is friable, the area will be delineated into 25 by 50 foot sections and the grids excavated as Type One or Type Two contaminated grids with the appropriate engineering controls and air monitoring. At the end of the excavation, the grids will be sampled per Section 7 of this SOP.

Air monitoring will be conducted in accordance with Section 4 of this SOP during asbestos-contaminated soil removal activities. Air samples will be collected to ensure personnel protection as well as measure the adequacy of engineering and environmental controls employed in the work areas.

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3.2 CONTAINMENT OF CONTAMINATION

The excavation protocols for the project include control of any asbestos-contaminated soil that might fall from the excavation equipment. Asbestos-contaminated soil falling within the work area will fall only on the contaminated portion of the work area or on a 10-ml polyethylene sheeting (or thicker) that is placed below trucks during loading to catch any spilled material.

Spilled material shall be cleaned up immediately and not allowed to dry out or accumulate. The excavator and load station will be moved as required to complete multiple work areas.

Contractor shall direct load excavated asbestos-contaminated soil into the beds of properly lined trailers that will haul the soil to an approved disposal facility. Soil from grids containing only non-friable asbestos debris (Type Two A and Type Three), or detectable asbestos fibers with no asbestos debris (Type Two B), will be loaded into leak tight single poly lined trucks and transported to the specified, pre-approved disposal facility as non-friable asbestos waste. Soil from Type One contaminated grids will be loaded into double lined trucks and transported to the specified, pre-approved disposal facility as friable asbestos waste.

3.3 SITE ACCESS CONTROL

Contractor shall post appropriate warning signs and barrier tape along the perimeter of the entire work area during removal activities. GSA will distribute Fact Sheets to all impacted on-site employees, and off-site businesses, if necessary. Contractor will limit access to the work site and only authorized personnel will be allowed on site. All personnel working on site will sign in and sign out as they enter and leave restrictive work areas.

At no time will vehicle traffic be allowed on surfaces where observable ACM is present or surface samples have shown positive asbestos test results (ACS). In addition to restricted access for vehicles, all other vehicle access will be restricted to established roads or on a reinforced, tear-resistant polyethylene sheeting or equivalent liner. This excludes equipment that is to remain off road throughout the project. The off road equipment may travel on soils that have been excluded for surface contamination and have been saturated for the control of visible emissions. Alternatively, off road equipment traveling only on contaminated soils is allowed.

Any movement off of contaminated soils will require decontamination of the vehicle. This equipment will be decontaminated at the end of the project as described in Section 5 of this SOP.

3.4 HIGH WIND WORK STOPPAGE FOR ACM REMEDIATION

Wind speed will be routinely monitored during all excavation activities, with readings recorded every 30 minutes at a minimum, and during wind gusts, during excavation of asbestos grids. All wind speed measurements will be taken in locations in close proximity to, and representative of, the work area in which soil is being handled.

Shutdown conditions – Soil removal/disturbance operations will immediately and temporarily cease when one or more of the following four (4) conditions have been met:

• any wind gust reaches or exceeds 20 miles per hour as determined by hand-held instruments;

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• sustained wind speeds reach or exceed 12 miles per hour averaged over a period of 10 minutes as determined by hand-held instruments;

• winds produce visible dust emissions or create movement of dust or debris in or near the removal/disturbance area, or

• Winds impact the ability of engineering controls to work as designed.

During wind-related work shutdowns, other work activities not involving soil removal or disturbance (e.g. lining dumpsters) may continue.

Startup conditions – Soil removal/disturbance operations may resume after all of the following 4 conditions have been met:

• all wind gust readings, for a period of 20 minutes, drop below 20 miles per hour as determined by hand-held instruments,

• sustained wind speeds are below 12 miles per hour averaged over a period of 10 minutes,

• winds are no longer producing visible emissions or creating movement of dust or debris in or near the removal/disturbance area, and

• winds are not impacting the ability of engineering controls to work as designed.

To the extent it is feasible, exposed asbestos-contaminated soil will be wetted, covered, or otherwise stabilized during high wind work stoppages. Documentation will be kept as part of the QA/QC record of all wind stoppages. The Contractors’ Site Superintendent in consultation with the QA/QC manager will make the determination when wind stoppage and restart occurs. In the interim, equipment may be moved to areas where chemical excavation may continue.

4.0 AIR MONITORING

During the removal of asbestos-contaminated soil, the Colorado Certified Air Monitoring Specialist (air monitoring specialist) will collect personnel air monitoring samples to assist in determining the adequacy of engineering and environmental controls employed at the site. The air monitoring specialist will maintain a daily air monitoring log. Depending on the size of the work area and the type of soil being removed, air monitoring may include personnel air monitoring only, or personnel monitoring and perimeter air monitoring for large open areas. In general, personnel air monitoring only (i.e., no perimeter monitoring) shall be used when disturbing no more than a lot at a time.

Perimeter monitoring shall be used when disturbing large quantities (greater than a lot) of Type One and Type Two A&B soils. In addition, if the work area is proximate to occupied buildings or areas of public access, perimeter air monitoring may be necessary to demonstrate that no asbestos fibers have left the work area.

Air monitoring for Type One and Type Two A&B shall have samples sent in for TEM as listed below. Type One will have TEM analysis run for every day that Type One soils are excavated.

Type Two A&B soils, after two weeks of daily TEM samples sent into the lab, with non-

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4.1 PERSONNEL MONITORING

Personnel air monitoring will be performed in accordance with OSHA requirements. The personnel air pumps will also be used for area monitoring instead of perimeter monitoring stations for sites less than a lot. For all asbestos contaminated soil excavation activities, at least two (2) different workers or 25 percent of the workers from each distinct area of soil disturbance, whichever is greater, and who are expected to have the worst-case exposure to asbestos during soil-disturbing and loading activities, will be equipped with personnel air pumps. Nominally, the excavation operator (if not in an enclosed cab), the worker spraying the working face, and the worker spraying the bucket as it loads into the truck for disposal. If the excavation operator is in an enclosed cab, the CABI will be monitored. All the air samples collected on the workers shall be submitted for total fiber analysis by phase contrast microscopy (PCM) to a NIST NVLAP accredited laboratory at the end of each work day. The two samples with the highest fiber concentrations by PCM will be analyzed by transmission electron microscopy (TEM) for asbestos fibers. In addition, if any sample with fiber counts greater than 0.01 fibers per cubic centimeter (f/cc), detected by PCM analysis, shall be analyzed by TEM to determine if asbestos is present. Verbal results of PCM analysis will be made available to air monitoring specialist by the start of the next business day or as soon as practical after the start of the next business day, and written results will be made available on-site within 24 hours from the time the verbal result is received. Verbal results of follow-up TEM analysis will be made to the air monitoring specialist as soon as possible, but no later than the start of the next business day, and written results will be made available on-site within 24 hours from the time the verbal result is received.

4.2 PERIMETER MONITORING

Perimeter air monitoring will be conducted for areas greater than one lot. Each distinct area of significant disturbance of Type One and Type Two A&B soils and will consist of the following:

• Four (4) air monitors will be located along the points of the compass. The samples will be placed as near the soil disturbing activities as reasonably possible and relocated as necessary by the air monitoring specialist.

• Two (2) “perimeter floating samples” will be located downwind of the soil disturbing area. The perimeter floating samples will be placed in areas where emitted asbestos fibers are most likely to be detected (e.g., downwind from the excavation area).

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• Additional perimeter monitoring points shall be added if the active area of soil disturbance is larger than approximately one acre in size. As general rule of thumb, one additional monitoring point should be added for each additional 200 linear feet of the active fill area perimeter (approximately 1 sample per additional ¼ acre increase in area).

The air monitoring specialist should place downwind floating samples such that they are at least 50 feet from any other sample point.

Samples will be collected during soil disturbance operations and submitted the same day for PCM analysis. Verbal results of PCM analysis will be made available to air monitoring specialist by the start of the next business day or as soon as practical after the start of the next business day, and written results will be made available on-site within 24 hours from the time the verbal result is received. A minimum of two (2) samples per day (or 25% of the samples) will be submitted for TEM analysis to evaluate engineering controls. The samples selected for TEM analysis will include the samples with the two (2) highest PCM results (based on fiber count);

however, all samples with PCM results exceeding 0.01 f/cc will be analyzed by TEM. TEM analysis will be provided on a 24 hour turn around with verbal results as soon as received by the laboratory.

For Type Three excavations the TEM requirement may be dropped after three days of constant monitoring and a review of the data by CDPHE concurs that the controls are deemed adequate and work practices are sufficient. If site conditions change substantially, the initial Type Three air monitoring procedures will be repeated for three additional days or until CDPHE is satisfied that the new or modified engineering controls are deemed adequate.

4.3 POSITIVE TEM RESULTS

The air monitoring specialist will review the results of all air monitoring samples submitted for TEM analysis. CDPHE shall be immediately notified should any air sample show any concentration of airborne asbestos fibers. In the event asbestos fibers are detected, engineering controls will be reevaluated to ensure that additional fiber releases do not occur. If asbestos fibers are detected in samples collected on subsequent days, all soil-disturbing activities shall immediately cease, the source(s) of emissions identified, and a control plan derived and submitted to the CDPHE and GSA for review. Soil disturbance shall not continue until CDPHE provides verbal and/or written authorization to proceed.

5.0 DECONTAMINATION

All excavation equipment will be cleaned before being mobilized to the work area. Cleaning procedures will be conducted in such a manner as to ensure that all residual soil and contaminants are removed and other hazards are not present on the equipment. All rolling stock and excavators will be inspected daily for leaking fluids and any other deficiencies. Leaking equipment will not be allowed on site and any equipment with an oil leak will be repaired immediately. Trucks will contain spill kits and any oil leak onto the ground will be cleaned up and packaged immediately.

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Once the soil removal process has been determined complete, decontamination of the equipment in direct contact with the contaminated soil (such as the trackhoe bucket) will occur within the lined trailer when possible. Small pieces of equipment that were in contact with the contaminated material will be thoroughly cleaned using amended water and rags and the container then sealed for transportation and disposal. If the excavator or other large pieces of equipment was required to work on contaminated soil the excavator equipment will decontaminated within a decontamination station or catch basin, constructed out of 10 millimeter polyethylene sheeting and at least 12 inches deep for the purposes of collection and filtration of the water generated during the decontamination process. All wastewater shall be filtered to at least 5 microns and disposed in the sanitary sewer or applied to a Type One, Two, or Three waste shipments. All contaminated polyethylene sheeting will be disposed as asbestos contaminated.

All vehicles used in the intrusive removal activities will receive a thorough and invasive cleaning, as described above, prior to being removed from the site. Each vehicle will receive a documented inspection prior to its demobilization.

5.1 WORKER DECONTAMINATION

During all soil-disturbing activities in areas of Type One and Type Two A&B soil, a fully functioning decontamination unit or trailer and will be utilized at the site. The decontamination unit will be centrally located between the investigation areas. The decontamination unit consists of three (3) chambers and has fully operational hot and cold running water for the shower.

At the beginning of each day workers that will be in the area of active soil disturbance will don disposable protective suite, disposable gloves and disposable boot covers.

The decontamination unit, as indicated in the Contractors HASP may be utilized by the workers each time they exit the work area. All contaminated disposable personnel protective equipment shall be containerized and disposed as asbestos waste.

For soil-disturbing activities in Type Three soil, worker decontamination may consist of removal of disposable protective suits (Tyveks), gloves and boot covers, which should then be containerized and disposed as asbestos waste. Workers who enter a Type One or Type Two A&B areas, but do not enter the active work area, may follow the decontamination procedure for Type Three soil.

5.2 DECONTAMINATION WATER DISPOSAL

Water generated from decontamination operations (shower water, equipment decontamination, etc.) with a functioning water filtration unit that will filter the waste water down to 5 microns and discharged to the sanitary sewer with permission from Metro Waste Water. Alternatively, the decontamination water for all of the sources listed above with the exception of shower water, can be used, after filtration to 5 microns, in wetting a Type One soils or other Types that will be

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6.0 WASTE HANDLING

Contractor will be loading both chemically contaminated soil and/or asbestos-contaminated soil during the remediation process. Chemically contaminated soil, that is not asbestos-contaminated, does not require a liner in the bed of the transportation trailer. It should be noted that due to environmental conditions (freezing temperature) that a liner is contusive to unloading a truck. Care will be taken to insure that no asbestos contaminated dirt is loaded into a truck or container without the appropriate liner in place.

6.1 LOADING

As described in Section 3 of this SOP, asbestos contaminated soil will be removed wet and transported directly from the contaminated work area to a waste container that contains a minimum 6-millimeter polyethylene sheeting, leak tight disposal liner. Soil from Type One grids will be loaded into double-lined trailers and sealed (burrito wrapped). Soil from Type Two A&B, and Type Three grids will be loaded into single-lined trailers and sealed. During the process of loading the container, the excavator will lower the bucket as close as possible to the interior of the container before dumping.

Throughout the entire loading process, amended water will be applied to suppress any fugitive dust emissions that might occur. The swing radius of the excavator will have a 6 millimeter polyethylene liner over the clean ground surface to control cross contamination as material is excavated and loaded into the trailer. Once the trailer has been loaded to a safe level for transportation, it will be sealed and transported for disposal. Polyethylene liners that have come in contact with ACS may be added to a load of ACS before it is sealed and transported for disposal.

In the event that a Type Two A&B or Type Three are being excavated into a single liner lined truck and friable asbestos is encountered, a second liner can be added into the truck bed and loading continued. This truck will be sent to a landfill able to accept friable asbestos.

Additionally, if chemically contaminated soils are being excavated and a discovery of asbestos in soils occurs, the prerequisite liners can be added to the truck. If necessary, a partially loaded chemical contaminated truck will be sent to the landfill and a lined truck will be brought up for the excavation and disposal of the asbestos-contaminated soil.

6.2 PACKAGING

The end dump and side dump trailers will be lined with 6 millimeter polyethylene sheeting. Type One contaminated grids with known friable asbestos in the soil will be double-lined and sealed.

Soil from Type Two A&B and Type Three contaminated grids will be single lined with 6-millimeter polyethylene sheeting and sealed.

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A double-lined lidded roll off container or lockable structure will also be staged on site to temporarily store any double bagged and labeled asbestos waste collected concurrently with excavation work. This waste is anticipated to be collected in the chemical contaminated lots where a small or minor amount of asbestos may be encountered and collected as per SOP No. 26.

Asbestos waste will be double bagged, and labeled appropriately.

6.3 TRANSPORTATION

The transportation coordinator will direct the schedule of transportation of all contaminated soil.

When loaded, each truck will be assigned a preprinted manifest to serve as the shipping document for that particular load. The waste will then be hauled to the specified, pre-approved disposal facility.

6.4 DISPOSAL

All soils leaving the DFC shall be under a manifest. GSA personnel identified will sign all manifests.

Generated asbestos-contaminated or chemically contaminated soil shall not be reused onsite, or sold as backfill, but must be disposed of at a facility licensed to accept this type of material.

Properly packaged and labeled asbestos-contaminated soil will be documented and transported for disposal to an approved landfill in accordance with 6 CCR 1007-2, Part 1, Section 5.5.7.

Signed documentation (manifest) stating that the soil originating from the Denver Federal Center shall be included with each load. Each load of asbestos-contaminated soil must be transported with documentation that the soil is asbestos-contaminated and shall not be used as daily cover or clean fill. Weight tickets will be collected for each load at the landfill(s) and recorded each day on an established tracking system. These may be used as documentation for a pay item.

In accordance with 6 CCR 1007-2, Part 1, Section 5.5.7, Type One soil shall be disposed as friable asbestos waste in accordance with 6 CCR 1007-2, Part 1, Section 5.3. Type Two A&B and Type Three soils shall be disposed as non-friable asbestos waste in accordance with 6 CCR 1007-2, Part 1, Section 5.2.

6.5 DEMOBILIZATION

After the project is completed, the equipment and site trailers will be removed, decontaminated and the site restored as outlined the CMWP or similar document.

All waste containers will be removed from the site and transported to an approved landfill for disposal. Any remaining protective barriers will then be removed from the site.

7.0 CLEARANCE SAMPLING AND INSPECTION

After the grids containing asbestos-contaminated soil have been excavated to the appropriate depth as established by the certified asbestos inspector, the grid will be confirmed clean through

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All clearance sampling and inspections will use appropriate GSA documentation form.

Forms can be found in SOP No. 26 and other associated SOPs.

All of the individuals that will be inspecting and observing the excavation process, performing visual inspection and collecting confirmation samples, will be CDPHE certified asbestos inspectors with a minimum of six (6) months experience in asbestos-contaminated soil abatement.

7.1 VISUAL INSPECTION

As removal activities progress, visual inspection will be performed to ensure all visible asbestos-contaminated soil has been removed from the work area. Inspections will be performed for each work area remediated on a daily basis and included in the daily QA/QC report. If visible contamination is allowed to remain over-night, the area will be stabilized with an appropriate cover so as to prevent disturbance of the material.

Because the project may involve both chemical and asbestos remediation, final visual inspections will be conducted when the immediate site excavation area is completed. Adequate drying time will be allowed before a final visual inspection is conducted.

The presence of any visible asbestos debris will not pass final visual inspection. If visible asbestos debris is observed, the area will be adequately wetted and additional excavation will be conducted. A subsequent visual inspection will be conducted after each additional excavation event until the area passes visual inspection.

7.2 SOIL SAMPLING

Once a CDPHE certified asbestos inspector has determined that the remediation has passed visual inspection, the following protocol will be followed for collection of clearance bulk samples:

1. after the desired depth is attained in each work area, collect one ten-point composite sample from exposed excavation floor and each exposed sidewall for every 1,250 square feet of excavation;

2. submit composite samples to laboratory for asbestos PLM analysis;

3. review results to determine whether depth and extent of excavation are adequate or if over excavation is required;

4. for projects the target clean up level is non-detect, analytical results will be non-detect before a grid is cleared.

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5. if depth of excavation is not adequate (based on analytical results of floor screening samples), then excavate an additional 6 inches and collect another ten-point floor sample as directed in (a);

6. if extent of excavation is not adequate (based on analytical results of sidewall screening samples), then remove an additional 6 inches from appropriate sidewall(s) and collect additional sidewall sample(s) as directed in (a); and

7. if floor and sidewall sample analytical results are non-detect , the area shall be deemed complete and cleared.

The excavation will be backfilled only after final visual inspection and final clearance sampling demonstrate that asbestos-contaminated soil has been remediated in accordance with this SOP and any associated CDPHE approved work plan.

8.0 CLOSURE REPORT

Contractor will maintain complete documentation of the project. A project close-out report will be prepared as per contract requirements. At a minimum the portion of the report covering the activities listed in this SOP will include the following:

• property description and description of area(s) with asbestos-contaminated soil,

• description of soil disturbing activities,

• description of all field operations or daily logs,

• containment logs (where appropriate),

• personnel air monitoring logs and analytical results,

• description/results of all asbestos sampling events, including sample locations,

• analytical results,

• disposal summaries and manifests,

• maps showing excavation profiles, and

• photographs showing pre- and…