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(a) General

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
       project debris.

      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.

(b) Definitions

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

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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
       Stationary Sources

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        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)

(d) Submittals

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

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       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.

1079.2 MATERIAL—

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
upon removal.


(a) General

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

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   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.

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(b) Assessment of Visible Emissions and Releases

1. General
    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
      Section 123.1.
    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
      are acceptable.
    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
      containerizing areas.

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     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
   not occur.

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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

1. General
    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
      airborne particulate.
    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

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   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.

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(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,
   when applicable.
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.

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