SECTION 1079 ENVIRONMENTAL PROTECTION
1. This Item provides the material and execution requirements for the monitoring of
project emissions during paint removal or repair, and for verifying that satisfactory clean
up has been performed upon project completion. Perform the following:
Monitor visible emissions and releases; evaluate the suitability of project clean-up.
Comply with the results of monitoring or analysis including all necessary clean up or
Clean up the project site as stipulated in this Item, including pre-existing litter or
Develop an Environmental Compliance Plan for the protection of the public and the
environment from exposure to harmful levels of dust, lead, and other toxic metals
that may be present in the paint being removed or repaired. Conduct Ambient Air
Monitoring for a period of one week prior to blasting, to two weeks after blasting
start, as a minimum.
2. Implement and maintain programs and procedures which comply with this Item, and all
applicable Federal, State, County, and City regulations. Comply with all applicable
regulations even if the regulation is not specifically referenced herein. If a State, County,
or City regulation is more restrictive than the requirements of this Item, including the
required ambient air monitoring, the more restrictive requirements prevail.
3. Identification of the items below which are of specific interest to the Department in no
way relieves the Contractor of the responsibility to comply with all EPA requirements,
nor should it be construed that the Department, the EPA and DEP, or City and County
regulators are only interested in these items.
1. Containment System – Complete enclosure built around hazardous (toxic metal) paint
removal areas designed to contain debris and prevent emissions to the environment.
2. Competent Person – One who is capable of identifying existing and predictable lead
hazards in the surroundings or working conditions and who has authorization to take
prompt corrective measures to eliminate them.
3. DEP – Pennsylvania Department of Environmental Protection
4. Department – Pennsylvania Department of Transportation, Engineering District 11-0
Page 1 of 10
5. Engineering Controls – The use of technologically feasible controls in the work areas for
the purpose of reducing and maintaining employee exposure to lead to or below the PEL,
and for controlling emissions from the work area. Examples of engineering controls are
mechanical dilution ventilation for the enclosure, or methods which capture the dust at
the point of generation such as vacuum blast cleaning.
6. Emission – A release of material to the air, water, or ground.
7. EPA – The U.S. Environmental Protection Agency. Regulations are contained in Title 40
of the Code of Federal Regulations (40 CFR).
8. Hazardous Waste (lead paint debris) – Waste that is classified as hazardous due to its
concentrations of regulated hazardous substances. Paint debris is classified as hazardous
waste if, after testing by the Toxicity Characteristic Leaching Procedure (TCLP), the
leachate contains any of the 8 metals or other substances in concentrations at or above
limits established in 40 CFR 261, EPA, Identification and Listing of Hazardous Wastes.
9. HEPA – A high efficiency particulate filter (HEPA) that is 99.97% efficient against particles
of 0.3 microns in size or larger.
10. Lead - Metallic lead, all inorganic lead compounds, and organic lead soaps. The lead
pigments used in paints comply with this definition.
11. g/m3 – Micrograms per cubic meter. Common units for reporting airborne
concentrations of lead.
12. NAAQS – National Ambient Air Quality Standards. Federal regulations which establish
limits on allowable pollutants in the ambient air. Lead and particulate matter are
included. Regulations are found in 40 CFR 50.
13. NIOSH – National Institute of Occupational Safety and Health.
14. OSHA – Occupational Safety and Health Administration. Standards are contained in Title
29 of the Code of Federal Regulations, Parts 1910 and 1926 (29 CFR 1910 and 29 CFR
15. PM-10 – Particulate matter of an aerodynamic equivalent diameter of 10 microns or
less. PM-10 is associated with high volume ambient air monitoring.
16. POTW – Publicly Owned Treatment Works.
17. Regulated Area – Area established by the Contractor to demarcate the areas where
airborne concentrations of lead exceed, or can be expected to exceed, the Action Level.
18. TSP – Total Suspended Particulate. Term associated with the collection of airborne
particulate using high volume ambient air samplers. Filters are typically analyzed for
(c) Reference Standards and Regulations
1. The latest edition of the following regulations, guides, and standards form a part of this
2. Code of Federal Regulations (CFR)
40 CFR 50, National Primary and Secondary Ambient Air Quality Standards
40 CFR 58, Ambient Air Quality Surveillance
40 CFR 60, App. A, Method 9, Visual Determination of the Opacity of Emissions from
Page 2 of 10
40 CFR 60, App. A, Method 22, Visual Determination of Fugitive Emissions from
Material Sources and Smoke Emissions from Fires
40 CFR 302, Designation, Reportable Quantities and Notification
40 CFR 355, Emergency Planning and Notification
3. State, County, and City Regulations
State - Title 25, Chapter 123, Pennsylvania Department of Environmental Protection-
Standards for Contaminants
4. EPA Methods
Method 3050, Acid Digestion of Sediment, Sludge, and Soils
5. NIOSH Methods
Method 7082, Lead
6. Society for Protective Coating (SSPC)
Guide 6, Guide for Containing Debris Generated During Paint Removal Operations
SSPC 93-02, Industrial Lead Paint Removal Handbook, 2nd Edition, Volume I
SSPC 95-06, Project Design, Industrial Lead Paint Removal Handbook, Volume II
7. American Industrial Hygiene Association
Environmental Lead Proficiency Analytical Testing Program (ELPAT)
1. Contractor Environmental Compliance Plan: Submit an Environmental Compliance Plan
which establishes programs for the monitoring activities that are the responsibility of the
Contractor, and includes provisions for complying with the results of any monitoring and
analysis conducted. Include the following programs in the Plan and submit the Plan for
Department review and acceptance a minimum of 21 calendar days prior to disturbing
paints containing toxic metals:
Assessments of Visible Emissions and Releases: A written program for the
observation of visible emissions during project activities, and inspections for releases
or spills of dust and debris that become deposited on surrounding equipment and
property. Include the frequency of observations and inspections that will be made,
areas or work activities that will be observed, and methods of observation and
inspection that will be utilized. Include the name(s) and qualifications of the
personnel conducting the observations and inspections.
Final Cleaning/Clearance Evaluations: A written program identifying the procedures
and methods that will be used to conduct final project clean up, and final cleanliness
inspections and evaluations. The purpose of the clearance tests is to assure that the
project area and surrounding surfaces have been properly cleaned in compliance
with this Item.
Compliance With Environmental Monitoring: Include statements in the Plan that
appropriate corrective action will be implemented (e.g., making changes to the
containment and/or work practices) if the results of monitoring and analysis show
that violations of emissions criteria are occurring.
Remediation of Ground (Soil), Water, and Sediment: Include provisions in the Plan
that in the event post-project inspections show unacceptable results, the Contractor
Page 3 of 10
will remove all visible debris from the ground (soil), water, and/or sediment, when
directed by the Department.
High Volume Ambient Air Monitoring: A written program for the instrument
monitoring of emissions to assure compliance with the NAAQS, this Item, and any
applicable City or County regulations. Include procedures to confirm that the
monitoring equipment is properly calibrated, sited, and operated; filters are properly
handled and transported; the laboratory analysis is performed by an accredited
laboratory; and that all monitoring calculations, documentation, and forms will be
sent directly to the Department.
Ground (Soil) Evaluations: A written program for inspection of the ground and soil
prior to commencement of the project and upon completion to determine whether
the ground was impacted by project activities.
Water/Sediment Evaluations: A written program for inspection of the water and
sediment prior to commencement of the project and upon completion to determine
whether the water or sediment was impacted by project activities.
2. Department Review: Do not construe Department acceptance of Contractor submittals
to imply approval of any particular method or sequence for conducting the work, or for
addressing health and safety. Acceptance of the programs does not relieve the
Contractor from the responsibility to conduct the work in strict accordance with the
requirements of this Item, or to adequately protect the health and safety of all workers
involved in the project, the public, and the environment. The Contractor remains solely
responsible for the adequacy and completeness of the programs and work practices, and
adherence to them.
Monitoring, Testing, and Sampling Equipment.
Supply the instrumentation needed for the monitoring of the ambient air, including all
equipment needed for its operation (e.g., generators, batteries, power cords, fuel,
etc.). Include a minimum of 1 TSP and 1 PM-10 Ambient Air Monitors per site and at a
minimum of one week prior to blasting to two weeks after blasting start, unless otherwise
directed by the Department.
Use equipment that is free of loose dust and debris when brought onto each bridge site, and
1. Conduct the work in strict accordance with Federal, state, and local regulations
governing the protection of the public and the environment. State regulations require
Page 4 of 10
that all reasonable actions be taken to prevent particulate matter from becoming
2. All protection requirements apply to Contractor and Subcontractor personnel working
for the Contractor.
Page 5 of 10
(b) Assessment of Visible Emissions and Releases
Conduct visible emissions assessments as defined in this Item, in accordance with 40
CFR 60, Appendix A, Method 22. These assessments are based on total visible
emissions regardless of the opacity of the emission. Conduct visual inspections for
releases or spills of dust and debris that have become deposited on surrounding
property, structures, equipment or vehicles, and bodies of water.
Consider all State, City, or County regulations regarding visible emissions in addition
to, but not in lieu of, the requirements of this Item.
Include procedures in Environmental Compliance Plan for the assessment of the
visible emissions and releases, the frequency of observations and inspections that
will be made, the equipment and work areas (e.g., containment) that will be
observed for visible emissions, and the surrounding property and structures that will
be examined for deposited debris.
2. Acceptance Criteria for Visible Emissions Assessments
Limit random visible emissions from project activities to an SSPC Level 1 (no greater
than 1% of the workday) in accordance with SSPC Guide 6. Conduct visible emission
assessments in accordance with 40 CFR 60, Appendix A, Method 22.
Pennsylvania State Regulation Title 25, Chapter 123.42, Section 123.42 exempts
construction operations from the opacity requirements established under Section
123.1. However, it is the Department's policy, through this specification, that all
bridge projects will comply with the opacity requirements, as established under
Immediately shut down the emission-producing activities if emissions in excess of the
criteria stipulated in this Item are observed. Do not resume the emission-producing
operations until the cause of the violation is corrected.
Immediately shut down the project and initiate corrective action if there are
violations of high volume ambient air monitoring, even if the visible emissions results
Clean up releases of dust and debris outside of the work area that have become
deposited on surrounding property; on the unprotected ground, soil, water or
sediment; around storm sewers or drains; or in areas where rain water could carry
the debris into storm sewers or drains. Conduct the clean up on a daily basis, or
more frequently if directed by the Engineer, and take appropriate corrective action to
change work practices or to modify the containment to provide better controls over
releases in the future.
3. Frequency and Location of Assessments and Inspections
Conduct the visible emissions assessments to account for all locations where
emissions of lead dust might be generated, including but not limited to, the
containment, dust collection and abrasive recovery equipment, and waste
Page 6 of 10
Conduct casual observations and corrections of visible emissions and releases of dust
or debris on an ongoing daily basis, but conduct the specialized assessments and
inspections as described in this Item at least 3 times each day.
Method PD/Lead A4 of SSPC publication 95-06, Project Design, provides guidance on
visible emissions assessments.
4. Reporting of Visible Emissions
Report the results of the daily assessments in a log book or other report form.
Document all cases where work has been halted due to unacceptable visible
emissions or releases of material, the cleanup activities invoked, and the corrective
action taken to avoid a reoccurrence. Provide the written report to the Department
within 48 hours of the occurrence.
(c) High Volume Ambient Air Monitoring
1. Conduct high volume ambient air monitoring during paint removal and clean-up
activities to confirm that emissions do not exceed the EPA National Primary and
Secondary Ambient Air Quality Standards (NAAQS), or specific County or City regulations.
2. Comply with the acceptance criteria established in City or County regulations when
applicable. Comply with the criteria established in 40 CFR 50 as summarized below if
there are no local regulations governing high volume ambient air monitoring:
TSP-Lead (Total Suspended Particulate-Lead) - Do not exceed 1.5 g/m3 averaged
over a 90 day period. Place one (minimum) TSP-Lead Ambient Air Monitor(s) per site
in the location acceptable to the Engineer. Conduct Ambient Air Monitoring for a
period of one week prior to blasting, to two weeks after blasting start, as a minimum.
PM-10 (Particulate Matter 10 Microns and Less in Aerodynamically Equivalent
Diameter) - Do not exceed the equivalent of 150 g/m3 as a 24-hour average. Set up
one per site, @ a minimum, unless otherwise directed by the Department. Place one
(minimum) PM-10 Ambient Air Monitor(s) per site in the location acceptable to the
Engineer. Conduct Ambient Air Monitoring for a period of one week prior to blasting,
to two weeks after blasting start, as a minimum.
3. If the results are acceptable, at the direction of the Engineer, reduce monitoring to one
(1) day per month, but resume if problems appear to be occurring as determined by
visual assessments of the operations, or as otherwise directed by the Engineer. Change
all monitor filters in the presence of the Inspector-In-Charge. Be responsible for damage
or loss of monitors for the life of the contract.
4. If monitoring is conducted and the above criteria is violated, immediately stop work and
make changes to the containment and/or work practices to achieve compliance. Note
that exceedances may also result in City or County violations.
(d) Restrictions on Emissions to Ground (Soil), Water, and Sediment
1. Conduct all activities so that releases to the soil, water, sediment, or storm sewers do
Page 7 of 10
2. If particulate or debris is released beyond the contained or protected areas, immediately
shut down the emission-producing operations until the cause of the emissions is
3. Immediately clean up visible deposits of debris on the unprotected ground, on the soil,
on or in the water or sediment, around storm sewers or drains, or in areas where rain
water could carry the debris into storm sewers or drains. Take the appropriate
corrective action to change work practices or to modify the containment to prevent
emissions from occurring in the future.
(e) Final Cleaning/Clearance Evaluations
Conduct an inspection of the project site and surrounding property and surfaces
located within the likely dispersion zone of project dust and debris upon completion
of project activities, and after all Contractor equipment and materials have been
Thoroughly inspect the property and surfaces for the presence of debris including,
but not limited to spent abrasives or other paint removal media, paint chips,
materials of construction, fuel, and other liter.
Remove all visible abrasive, paint chips, and debris from the project site, even if the
abrasive, paint chips, and debris were a pre-existing condition.
Include procedures in the Environmental Compliance Plan for project clean up,
including the inspections that will be employed to verify that the cleanliness complies
with the acceptance criteria identified in this Item.
2. Cleaning Requirements. Comply with Section 104.05.
Remove all project debris and litter from the project site and surrounding property,
equipment, and structures.
When cleaning paint chips and dust, use vacuuming equipment equipped with HEPA
filters, wet washing, or other means that will effectively remove the dust and debris
without re-dispersing it into the air. Do not use compressed air for cleanup activities
unless it is used in conjunction with a ventilation system designed to capture the
Collect water used for cleaning and dispose of in accordance with Item 9073.
3. Acceptance Criteria - Project Cleanup
Conduct a final inspection with the Engineer after all cleanup activities are
completed. Conduct any additional cleaning identified by the Department. Consider
the site properly cleaned under the following conditions:
Paint chips, spent abrasive and other paint removal media, fuel; materials of
construction, litter, or other project debris are not visible on or around the project
Remove all lead dust from the surface of the completed structure as well as from
surrounding structures and equipment.
4. Report on Clearance Inspections
Page 8 of 10
Prepare a letter report presenting the results of the inspections conducted to verify
the final cleanliness of the project site, surrounding property, waterways, equipment,
buildings, and structures.
Include a summary of any problems or releases that occurred during the project, and
the clean up and corrective action measures that were taken to resolve the problem.
Page 9 of 10
(f) Reportable Releases
1. Clean Water Act – Reportable quantities of hazardous substances in waterways are
addressed in Section 311 of the Clean Water Act. Report such releases to the
Department's Representative, the EPA in accordance with 40 CFR 117 and 40 CFR 355,
and the Pennsylvania DEP. Notify the Fish and Boat Commission, and the Coast Guard,
2. CERCLA – Reportable quantities under CERCLA are found in 40 CFR 302. In the case of
lead, the reportable quantity is a release of 4.5 or more kilograms (10 or more pounds) in
a 24 hour period. If such releases occur, stop work immediately and notify the
Department's Representative, the Pennsylvania DEP, and the National Response Center
1079.4 MEASUREMENT AND PAYMENT— Costs associated with Section 1079 Environmental
Protection, are incidental to Item 9075 Containment.
Page 10 of 10