1072COATINGS WASTE MANAGEMENT, CONTAINMENT, ENVIRONMENTAL PROTECTION, AND SAFETY

ENVIRONMENTAL PROTECTION, AND SAFETY

1072.1DESCRIPTION—This work is waste management, containment, environmental protection , and

protection of workers during removal of existing coatings and application of new coatings. This work includes the following:

• Properly collecting, handling, storing, classifying, transporting, and disposing of hazardous and non- hazardous waste according to applicable Federal, State, and Local regulations.

• Furnishing and installing c ontainment systems to control emissions of dust, lead , and other toxic metals that may be present in the coatings being removed or abrasive blast media being used to remove coatings.

• Having a program in place for the safety and protection of workers from over exposure to lead and other toxic metals that may be present in the coatings being removed or abrasive blast media being used to remove coatings.

• Conducting environmental monitoring during removal of existing coatings , and ensuring the site is properly cleaned after coatings operations are complete.

1072.2MATERIALS—

intact and operational to prevent the escape of debris by wind, spilling of the contents, or access by unauthorized personnel.

type for the hazardous and residual waste generated on the project. Use containers that are resistant to rust and corrosion (coated, if constructed of steel), that have tight fitting lids or covers, and are water resistant and leak proof.

waste. Use containers that are free of loose debris when brought on-site.

coating debris, water, or other waste.

activities, hygiene facilities, and laundry facilities if cleaning of protective clothing is performed on site.

Guide 6 and applicable Federal, State, and Local regulations . Only use containment materials that are flame retardant.

onto each bridge site, and upon removal.

LUX (0.0 - 50.0 foot-candles).

including equipment needed for its operation.

needed for contractor workers, and for two Representatives each shift, including proper cleaning, training in use, and disposal. Repair or replace PPE as required to ensure that it continues to provide its intended purpose.

each bridge site, and upon removal. Properly handle and dispose of hygiene water, cleaning materials, and PPE that cannot be cleaned for reuse.

and sensitive receptors are located within 500 feet of the work areas, supply the instru mentation needed for monitoring ambient air. Install multiple monitors , when necessary, to ensure the protection of public health according to SSPC Technology Update No. 7 (SSPC TU-7), as determined by the Sensitive Receptor Survey provided in the Environmental Compliance Plan, and according to Local permit requirements. Provide a dditional monitors to ensure coverage of all areas where multiple, separate dust -generating activities are simultaneously being performed.

and upon removal.

Suspended Particulate (TSP) ambient air monitors as required in the permit . Provide all materials and equipment required by the permit.

1072.3CONSTRUCTION—

the Department will be the generator for permitting purposes, and will provide the EPA provisional identification number. However, the Contractor is responsible for the collection, handling, storage, testing, transportation and disposal of all wastes.

limited to rags, tape, disposable coveralls, filters, coating debris, and paint cans. Contain the waste within the legal right-of-way.

storage area for hazardous waste . Once a container of hazardous waste in the work area is full, transport the waste to the secured storage area within three days, or at an approved frequency.

collection, handling, transportation and disposal of hazardous, non -hazardous, and residual waste and wastewater. When collecting and storing waste, prevent the dispersion of debris or dust during filling or moving containers and comply with the worker protection requirements as specified in Section 1072.3(h).

a minimum of 30 calendar days before the start of coating removal operations.

1.a Disposal of Waste . A written program that addresses the proper handling and disposal of waste. Include the procedures that will be followed for the collection of representative samples of the waste; the procedures for the site handling, storage, and packaging of the waste; a nd contingency plans if a spill occurs.

1.b Executive Summary. Include an executive summary and contingency plan. The summary should be readily available at the project site. At a minimum, the Summary is to include the types of hazardous and non-hazardous waste expected to be generated at the site and the associated hazards, an estimate of the quantity of hazardous and non -hazardous waste generated, a description of the waste accumulation location, a map or description of the access/evacuation routes in case of a spill of hazardous waste or emergency, and the name and contact information of the emergenc y coordinator according to 40 CFR 262.

1.c Transporter Information. The names, addresses, license or permit numbers, insurances, and qualifications of the proposed haulers of hazardous waste, non-hazardous waste, and wastewater.

1.d Disposal Facility. Advise legally permitted recycling or waste disposal facilities that bridge coating debris will be generated and identify the toxic metals that the waste will likely contain. Based on that information, request a letter from the hazardous waste recycling or disposal facilities stating that the facility can accept this type of waste, is authorized to accept the waste under the laws of the state of residence, has the required capability to treat and dispose of the materials , and will provide or assure the ultimate disposal method indicated on the Uniform Hazardous Waste Manifest.

1.e Municipal Landfill. Submit the name and address of the permitted municipal waste landfill that will accept the non-hazardous and residual waste generated by the Contractor.

1.f Wastewater. Provide a letter from the proposed facility that will be accepting the wastewater for disposal, indicating that the facility has the capability to handle and properly dispose of the water. Advise the facility of any toxic metals that may be present in the water.

1.g Laboratory Qualifications. Provide the name, address, experience, and qualifications of the laboratory and firm that will be used for the waste sampling and analysis required under this Section.

2.a Design and Loading Calculations. Include calculations, data, and assumptions used for the design of the containment and ventilation system and the imposed loads on the existing structure. Do not allow the containment system to induce a load on the existing structure that will create an overstress condition or otherwise effect the structural integrity of the structure. For S SPC Guide 6 abrasive blasting containments, include calculations of the design air flows within the containment, descriptive information and fan curve for the dust collector(s), and the locations and sizes of duct work and air inlets. Include calculations for system static pressure losses through the dust collector, duct work, and containment. Provide analysis for the anticipated dead and live loads including but not limited to material to be stored on the containment, waste, equipment, workers, and the effects of wind forces on the containment system and existing structure. Provide the maximum allowable load for the floor/platform. Design cables not to exceed 5% sag over the length of the span once in their final secured position. Include sag calculations. Determine attachment points. Make attachment points to substantial framing members only. Drilling or welding to structural steel is prohibited. Do not make permanent attachments or fastenings to the structure. Analyze both global and localized loading at all attachment points. Do not allow the system to encroach upon the required clearances.

2.b Engineering Drawings. Provide detailed containment drawings stamped by a Professional Engineer registered in the State . Include the maximum allowable load for the floor/platform and required clearances in the drawings. Provide details and procedures for staging, installation, moving, and removing the containment. Provide attachment locations, details, and installation procedures.

2.c Inclement Weather. Provide provisions for dropping the containment in inclement weather, for movement out of navigation lanes, and the controls exercised to prevent excessive sagging during cable installation to ensure the protection of traffic. Include calculations for an allowable wind speed which will be used in the field to determine the threshold for dropping the containment. Include the procedures to be followed for ensuring that waste is not released when the containment is dismantled as a result of inclement weather.

2.d Technical Data. Include technical data sheets, catalog cut sheets, specification sheets, any other information needed to thoroughly describe the containment plan and materials proposed for use. Provide the manufacturer’s specifications for the proposed enclosure material(s) including information on light transmittance, flame spread, burst strength, abrasion durability, and unit weight.

2.e Lighting. Plans for providing lighting according to SSPC Guide 12 and for maintaining navigational lighting during the work.

2.f Access. Provide a description of how the containment and platform is to be accessed. Identify the fall protection, edge protection, and prevention systems to be utilized inside the containment.

contain lead or other toxic metals, submit a written project-specific compliance program prepared under the direction of, and signed by a Certified Industrial Hygienist (CIH) according to 29 CFR 1926.62. Verify that Subcontractors are included in the program or in a separate program. If Subcontractors are operating under a separate program, include the program with the submittals. Revise and update the program(s) a minimum of every six months during the portion(s) of the project which involve the disturbance of toxic metals. Verify that the CIH signs off on six-month reviews and revisions. Upload revisions and CIH sign-off to project files for review and approval. Include in t he Compliance Plan, a detailed checklist for site inspections by the competent person.

3.a Personnel Qualifications. Provide the name, experience, and qualifications of both the CIH overseeing the development of the compliance program, and the competent person assigned to the project conducting routine inspections . The competent person is required to have successfully completed the SSPC-C3 training course. On projects where the contractor is required to maintain a SSPC QP -2 certification (field removal of hazardous coatings), the competent person is required to have received the 8-hour SSPC C5 refresher training within the past 12 months.

3.b Outside Laundry. Provide the name, address, and qualifications of the launderer, if one will be used, for the cleaning of reusable clothing. Provide a letter from the laund erer indicating that it is allowed to handle clothing contaminated with lead and other toxic metals of concern.

3.c Laboratory Qualifications. Provide the name of the laboratory and firm that will be used for the worker and area exposure monitorin g. Verify that the analytical laboratory is American Industrial Hygiene Association (AIHA) accredited for metals analysis and has successfully participated (previous 12 months at a minimum) in the AIHA Environmental Lead Proficiency Analytical Testing (ELPAT) program.

3.d Personal Protective Equipment for Department Use. Acknowledge that protective clothing and equipment, laundering or disposal, fit testing as needed, and hygiene facilities will be provided for two Representatives at each site for each shift.

3.e Training for Representatives. Acknowledge that site training according to 29 CFR 1926.62 will be provided for two Representatives at each site per shift if there is the potential for lead exposures on the project. Include training as appropriate for other toxic metals that are present in the coating or abrasive being used.

activities and includes provisions for complying with the results of monitoring and analysis. Include the following:

4.a Sensitive Receptor Survey (for hazardous coatings/abrasives). Provide a map or written narrative identifying sensitive receptors. Sensitive receptors include, but are not limited to, schools, hospitals, childcare facilities, nearby residences, and locations where the public has access (bridge sidewalks, parks, ball fields, recreational waterways).

4.b Assessments of Visible Emissions and Releases (for hazardous and non -hazardous coatings/abrasives). Submit a written program for the observation of visible emissions during project activities, and inspections for releases or spills of dust and debris that become airborne and deposited on surrounding equipment and property. Include the frequency of observations a nd 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.

4.c High Volume Ambient Air Monitoring (for hazardous coatings/abrasives). Submit a written program for the instrument monitoring of emissions to assure compliance with this Section and any applicable City, Township, County, State or Federal regulations. Include procedures to confirm that the monitoring equipment is properly calibrated, s ited, and operated; filters are properly handled and transported; the laboratory analysis is performed by an accredited laboratory; and that monitoring calculations, documentation, and forms will be uploaded directly to the project files. Include information on monitoring frequency, as well as the proposed number and locations of ambient air monitors. Submit the name of the independent third-party monitoring firm who will be performing the ambient air monitoring.

4.d Ground (Soil) Evaluations (for hazardous and non-hazardous coatings/abrasives). Submit a written program for the visual inspection of the ground before commencement of the project and upon completion to determine whether the ground was impacted by project activities.

4.e Water/Sediment Evaluations (for hazardous and non -hazardous coatings/abrasives). Submit a written program for the visual inspection of the water and sediment before commencement of the project and upon completion to determine whether the water or sediment was impacted by project activities. Include plans for the collection and removal of debris from the surface of water when working over streams, rivers, lakes, and other bodies of water.

4.f Compliance with Environmental Monitoring (for hazardous and non -hazardous coatings/abrasives). Include corrective action measures that will be implemented if the results of monitoring and analysis show that violations of emissions criteria are occurring.

4.g Remediation of Ground (Soil), Water, and Sediment. Include corrective action measures that will be implemented if the post-project inspections show unacceptable results, and how debris from the ground (soil), water, and sediment will be removed.

4.h Final Cleaning/Clearance Evaluations. Include the procedures and methods that will be used to conduct final project clean up, and final cleanliness inspections and evaluations. Clearance tests ensure the project area and surrounding surfaces have been properly cleaned.

the hazardous waste manifest.

• Containerizing, testing (classifying), handling, and storage of all waste.

• Contracting with licensed and permitted waste transporters for the transportation of hazardous, residual, and non-hazardous waste, as well as wastewater.

• Contracting with licensed and permitted recyclers or disposers of waste.

• Locations for waste storage together with appropriate measures to ensure that the area is secure.

• Completed Waste Characterization Data Sheets for Department signature.

• Completed hazardous and residual waste manifests for Department signature.

• Bill of Lading for non-hazardous waste and wastewater.

• Collect representative samples of the coating debris generated by project activities. Collect samples under the observation of the Representative.

• Collect samples according to SW-846, "Test Methods for Evaluating Solid Waste - Physical/Chemical Methods." Describe the sampling methods in the Waste Handling Plan.

• For paint containing lead or other toxic metals, handle and treat the waste generated using steel abrasives as hazardous regardless of the TCLP results. Collect and analyze a minimum of one representative sample of the steel grit debris to identify the composition of the waste.

• Collect and have analyzed, a minimum of four representative samples of other waste streams (i.e., waste streams which do not contain steel abrasives). Use a random sampling technique to collect the samples.

• Complete the initial sampling of each waste stream immediately and send samples to the laboratory for analysis.

• Unless directed or required by state regulations or the waste recycling or disposal facility, once each waste stream is sampled, tested, and classified, additional sampling and analysis are not required for subsequent shipments unless the waste stream changes.

2.a Laboratory. Direct the laboratory to test the waste according to 40 CFR 261, Appendix II, Method 1311 Toxicity Characteristic Leaching Procedure (TCLP), to determine if it is hazardous.

2.b TCLP. Analyze the samples from each waste stream by TCLP for all eight RCRA metals and other hazardous substances. If expendable abrasives are used, also analyze the samples for arsenic. When chemicals strippers are used, test liquids and sludge. Include pH to determine corrosivity.

3.a RCRA Metals. Coating debris is classified as hazardous waste if the leachate contains any of the 8 RCRA metals or other hazardous substances in concentrations at or above the limits established in 40 CFR 261. The presence of these substances at lower concentrations classifies the waste as residual.

Arsenic - 5.0 mg/L Barium - 100.0 mg/L Cadmium - 1.0 mg/L Chromium - 5.0 mg/L Lead - 5.0 mg/L Mercury - 0.2 mg/L Selenium - 1.0 mg/L Silver - 5.0 mg/L

3.b Use of Steel Abrasives. Where lead-containing paint is being removed, debris that is generated by steel abrasives has been classified by the Department as hazardous for lead even though it passes the TCLP test. In Box 9b of the waste manifest, identify this waste as "paint chips -hazardous."

3.c Other Hazards. The above includes only those elements typically associated with coatings. Other substances may be present which can cause debris to be classified as hazardous waste as defined in 40 CFR 261.

4.a Timeline. Have the laboratory send the test results directly to the Representative with copies of the test results to the Contractor. Issue reports no later than ten (10) calendar days after the representative samples are collected, and no later than 40 days after project start-up.

4.b Test Results. At a minimum, include the following information in each report: Identity of the waste stream(s) analyzed, the number of samples collected and tested, dates of sampling and testing, laboratory test procedures utilized, the names and signatures of the individuals collecting the samples and conducting the laboratory tests, and an inter pretation of the test results. Include copies of the chain -of- custody forms in the documentation.

4.c Waste Characterization Data Sheet (WCDS). Prepare the Waste Characterization Data Sheet and provide to the Representative for review and signature. Once approved, submit the original WCDS to the Department.

Chapters 260a-266a, 266b and 268a-270a for the on-site handling, packaging, and storage of hazardous waste generated by the project. Comply with Pennsylvania Title 25, Chapters 285 and 299 for the handling, packaging, and storage of residual and municipal construction non -hazardous waste. Comply with additional Federal, State, County and City regulations including PennDOT’s Publication 611 Waste Management Guidance Manual. Do not place hazardous or residual waste on the unprotected ground. Utilize impermeable tarpaulins or similar under all waste storage . Locate in a secure area with signs around the perimeter and shield adequately to prevent dispersion of the waste by wind or water. If the waste is determined to be hazardous, enclose in fenced area with locking gate until transport. If using a roll off st yle dumpster with a locking lid, or hermetically sealed vacuum box, a fence is not required. Contact the Representative for approval of the storage location(s). Collect and store all waste at the end of each working day in storage drums or containers such that no waste is left exposed overnight, at a minimum. Use DOT -approved containers for hazardous and residual waste storage. Cover containers immediately upon filling and confirm that lids are attached except when filling. Verify that labels remain intact. Store non-hazardous, residual, and hazardous waste separately. Do not co-mix hazardous waste with non-hazardous waste. Do not mix different types of hazardous waste together unless specifically approved by the Representative and the disposal facility. Arrange containers in the storage area for easy accessibility. Stage the containers together in lots no greater than two rows of five containers each. Maintain a minimum lane clearance of 36 inches between each lot of ten containers. Provide written documentation to verify that waste (hazardous, residual, and non -hazardous) is transported to the appropriate recycling or disposal facility in the required timeframe based on PennDOT’s Waste Management Guidance Manual (Publication 611). Large Qu antity Generators (LQGs) can accumulate hazardous waste on the site for up to 90 days. Improper waste storage is cause for immediate project shut down until appropriate corrective action is completed. Train personnel in the proper handling of the hazardous waste at the work site according to 40 CFR

265.16. Include procedures in the Waste Handling Plan that will be followed if a release or spill occurs,

required notifications, and methods to be used for cleanup. Maintain training records on -site. Do not fill container or roll-off in excess of the capacity marked on the container.

If soil remediation is required, place the soil into separate containers and assume costs for disposal. Do not place contaminated reusable materials (i.e., tarps, duct hoses) on the unprotected ground. Clean, seal, or cover to prevent release of contaminants onto the ground. Inspect the residual and hazardous waste storage area(s) for compliance with the specifications and State regulations. Inspect storage areas on a weekly basis. Document inspections.

contents. Label containers of spent abrasive as "BRIDGE BLAST ABRASIVE WASTE". Include the Contract Number and the Bridge Identification Number or SR and SEC Number. Provide similar labels on containers of other project waste and debris. Apply hazardous waste labels after the TCLP test results are received if the waste tests hazardous. Label each container or roll -off of hazardous waste according to 40 CFR 262, 49 CFR 171 -179, and Pennsylvania Title 25, Chapters 260a-266a, 266b and 268a-270a. Include the following minimum information:

• Hazardous Waste. Federal law prohibits improper disposal. If found, contact the nearest police, or public safety authority, or the U.S. Environmental Protection Agency.

• Proper DOT Shipping Name

• Manifest Document Number

• Generator Name, Address, and EPA ID Number

• Date of Accumulation

• EPA Waste Number

Affix a label to the container indicating the hazards associated with exposure to the contents of the container. If the container contains lead, then affix the following label according to the latest OSHA guidelines:

DANGER: LEAD MAY DAMAGE FERTILITY OR THE UNBORN CHILD CAUSES DAMAGE TO THE CENTRAL NERVOUS SYSTEM

Label containers of used protective clothing as lead-contaminated clothing if the clothing is disposable. Apply hazardous waste labels as appropriate after testing. Apply non-hazardous, municipal, or residual waste classification labels, as applicable, on other project waste according to Pennsylvania Title 25, Chapter 285 and 299. Enter the above information using permanent marking material, printed in English, and displayed on a background of contrasting color unobscured by other labels or attachments. Locate labeling away from other markings that could substantially reduce its effectiveness. Complete the labeling, marking, and placarding activities under the observation of the Representative, before storing or transporting container or roll off.

7.a Hazardous Waste.

• Upon receipt of TCLP results, prepare Waste Characterization Data Sheet(s) and provide to the Department for review and signature.

• Prepare the hazardous waste manifest for each shipment and provide to the Representative for review and signature.

• Arrange for the transportation of hazardous waste by a licensed transporter according to 40 CFR 263, 49 CFR 171 -179, and Pennsylvania Title 25, Chapters 260a -266a, 266b and 268a -270a.

Also comply with applicable County or City regulations. Verify that waste is completely covered during transport.

• Arrange for the recycling or disposal of hazardous waste according to 40 CFR 264, 40 CFR 268, and Pennsylvania Title 25, Chapters 260a -266a, 266b and 268a -270a. Verify that only licensed recycling or TSD facilities are used.

• Comply with the manifesting, certification, labeling, and reporting requirements for hazardous waste according to 40 CFR 262, 40 CFR 268 and Pennsylvania Title 25, Chapters 260a -266a, 266b and 268a-270a, including certificates of final disposal for each shipment.

• Upload to project files a certification for each manifested shipment that the waste was accepted by the recycling or disposal facility, and properly treated and disposed.

• Provide copies of bills of lading within 7 days of shipment.

7.b Residual and Non-Hazardous Municipal/Construction Waste.

• Transport and dispose of residual and non-hazardous municipal construction waste according to Pennsylvania Title 25, Chapters 271, 273, 279, 285, and 299.

• Verify that waste is completely covered during transport.

• Verify that the truck is properly designated with a residual waste sign measuring 6 inches in height when transporting residual waste.

• Verify that the transportation vehicle has a Pollution Prevention and Contingency Plan and carries the following information: County and state where waste originated, name and address of the carrier, name and location of disposal facility, and fire extinguisher.

• Comply with additional County and City regulations as applicable.

7.c Special Handling and Disposal Conditions for Wastewater.

• Provide containers for the collection and retention of wastewater, including but not limited to the water used for hygiene purposes, laundering of clothing if done on site, pressure washing, and cleanup activities.

• Filter visible paint chips and particulate from the water before placing it into the containers. Before disposal, test the water for total toxic metals and provide ample filtration of 5 microns or better through a m ulti-stage filtration system until the water is not classified as hazardous. Provide documentation of wastewater sampling results to the Representative, including: the number of samples collected and tested, dates of sampling and testing, laboratory test procedures utilized, the names and signatures of the individuals collecting the samples and conducting the laboratory tests, and an interpretation of the results. Include copies of the chain -of-custody forms with the documentation. Unless directed or required by the disposal facility, once the in itial wastewater sample has been analyzed, additional sampling and analysis is not required unless the waste stream changes.

• Make disposal arrangements with the local publicly owned treatment works (POTW), sanitation company, or other appropriate permitted facility. Provide the Representative with documentation signed by an official of the facility stating that the facility will accept the waste, and that the levels of lead remaining in the water are acceptable.

• Provide the Department with the name and address of the transporter and disposal facility for acceptance before use.

• Provide copies of bills of lading within 7 days of shipment.

7.d Recordkeeping. Provide the following information to the Representative: documentation of laboratory analyses, waste characterization data sheets, manifests and bills of lading, a listing of the type and quantity of waste generated, certificate of disposal, and the transportation and disposal facilities used for waste.

Follow the containment requirements as specified in this Section, and as stipulated in SSPC Guide 6 for the selected method of removal. Erect and maintain containment systems based on the coating removal method as follows:

• Abrasive blast cleaning………………………… SSPC Class 1A (lead); Class 2A (non-lead)

• Wet abrasive blast cleaning……………………. SSPC Class 1W (lead); Class 2W (non-lead)

• Power tool cleaning……………………………. SSPC Class 1P (lead); Class 3P (non-lead)

• Power tool cleaning with vacuum attachment…. SSPC Class 3P (lead); ground tarps (non-lead)

• Pressure washing/water jetting…………………. SSPC Class 2W (lead); Class 4W (non-lead)

For abrasive blasting projects in Allegheny County, in addition to the containment requirements as specified in this Section, comply with permit requirements as stipulated in the Allegheny County Health Department, Bureau of Environmental Quality Abrasive Blast Cleaning Permit. Complete and submit Part B of the “Abrasive Blasting Project Notice and Permit Application” to the Allegheny County Health Department, Bureau of Environmental Quality for approval. The Department is to complete Part A of the permit. For abrasive blasting projects in the City of Philadelphia, complete and submit for approval the City of Philadelphia Department of Public Health, Air Management Services “Process Equipment Installation Permit Application for Minor Emission Source”.

and licensed Professional Engineer field verify and certify in writing that the containment system has been assembled as shown on the approved, signed and sealed drawings. Verification through review of photographs and third-party reviewers is prohibited. Submit the written certification of containment installation to the Department before starting any work within the containment. If deviations from the accepted containment drawings are present, have the Professional Engineer note deviations from the design in the certification letter and indicate that the deviations will not affect the intended performance of the containment system or safety; or submit revised drawings and calculations for acceptance showing the deviations. Do not begin surface preparation or coating removal activities until the certification or revised drawings have been received and accepted.

by the Department. Do not allow equipment and workers to be present or to operate over lanes that are open to traffic, unless specifically approved.

with air and dust impenetrable materials such as solid panels of plywood or flexible materials such as tarpaulins, if it serves as the base of the containment. Maintain the materials throughout the project to avoid losing debris through rips, tears, or breaks in the coverings.

Tarpaulins are not required on the decking/containment platform unless the platform is not preventing the release of spent abrasive, dust, and debris. If spent abrasive, dust, or debris is observed falling through gaps in the decking, seal the decking so that emissions are controlled or install tarpaulins over the decking. Verify that the platform and its components are designed and constructed to support at least 4 times its maximum intended load without failure with wire cables capable of supporting at least 6 times their intended load without failure, if a suspended or elevated platform is constructed to serve as the base of the containment. Follow applicable OSHA regulations regarding scaffolding. Design each SSPC Guide 6 Class 1A or 2A containment system to meet minimum air flow velocities of 60 feet per minute down-draft or 100 feet per minute cross-draft. Remove debris from the containment materials and equipment before relocation to another point along the structure. Clean to the extent that debris or dust are not dislodged by winds or physical contact during handling and transportation.

and equipment on site to contain inadvertent spills or releases of dust and debris, when working over or near water. Materials and equipment that are typically acceptable include water booms and boats with skimmers. Remove project-related dust and debris from the surface of the water or from sediment immediately.

that the containment will extend below the bottom of the bridge (i.e. below the bottom chord) when operating in the navigation channel. Maintain this distance to the absolute minimum required. Obtain advance approval from the Coast Guard any time that the work necessitates partial or total restrictions to the movement of vessels beneath the bridge. Provide the Coast Guard with the request at least 30 days before the need to commence such activities. Design the containment to allow it to be moved out of the navigation channel within 24 hours of notification that ships needing additional clearance require passage, unless otherwise directed by the Coast Guard. Provide the Representative and the Coast Guard with a 24 -hour telephone number and contacts for discussions regarding the containment system. Notify the Army Corps of Engineers and PA Fish and Boat Commission, where applicable, of the intended work, and comply with any restrictions or conditions.

plan to the Department for approval in advance.

inspection work according to the guidelines established in SSPC TU -12. Increase the lighting if workers or inspectors have difficulty in seeing. Use explosion-proof lighting.

project activities. Keep protective systems clean and operational throughout the entire project. Remove visible debris from the protective devices or from areas where rainwater could carry th e debris into drains or storm sewers at the end of each workday at a minimum. Conduct more frequent cleaning as directed. Identify the methods that will be used to route run-off from the existing deck drains through the containment enclosure. Do not close bridge deck drains without approval.

air for cleaning only inside a contained area equipped with an operating ventilation system capable of capturing the dust and debris. Remove equipment and materials upon completion of project activities. Thoroughly HEPA vacuum, wash, or otherwise decontaminate reusable items until loose surface dust and debris have been removed. These items include, but are not limited to, coating removal equipment, containment materials, ground covers, and scaffolding. Treat materials as a separate waste stream and dispose of properly, if adequate cleaning is not possible. Collect water used for cleaning and dispose of as specified in this Section.

protection of workers from all jobsite hazards. Worker protection requirements apply to Contractor and Subcontractor personnel working for the Contractor. Requirements identified are based primarily on the OSHA Lead in Construction Standard, 29 CFR 1926.62, however, protection of employees from exposure to other toxic metals which may be present in the coating, abrasive or substrate is required by law. Establish methods for complying with this Section and OSHA standards published for the toxic metals present in the coating or abrasive being used. Include statements that the workers will not be exposed above the PEL established for the metal as identified in 29 CFR 1926.55, when toxic metals are present in the coating for which OSHA has not developed a comprehensive health and safety standard. Identify the methods of compliance that will be used to reduce worker exposures to toxic metals. Rely on respiratory protection only after feasible engineering and work practice controls have been first implemented to reduce airborne exposures.

beginning of the coating removal work (at project start-up) for each exposure producing activity to determine employee exposures to lead and other toxic metals that might be present in the coating or abrasive. Collect full shift ( minimum of 7 hours) air samples for each job classification in each exposure area, including Representatives. Submit results of the analysis within the same five-day notification period required for the employees, but no later than 14 days after collection. Protect workers during the initial monitoring to the anticipated exposure levels as dictated by 29 CFR

1926.62and as specified below when lead is present. Activities in addition to those dictated by OSHA are

included. Use the same level of protection when other toxic metals are found in the coating, unless OSHA has developed a comprehensive health and safety standard for that metal . In those cases, implement the protection requirements of the standard for that metal. Before receiving the personal air monitoring test results, employers must assume that workers are subject to the following exposures (based on work task according to OSHA 29 CFR 1926.62) .

• Assume an exposure of at least 50 µg/m 3 during m anual demolition of structures (e.g. drywall) , manual scraping, manual sanding, heat gun applications, power tool cleaning with dust collection systems, and spray painting with lead containing coating. Although not identified in 29 CFR 1926.62, include chemical stripping, water washing, and the operation of abrasive grit recovery equipment in this category.

• Assume an exposure of at least 500 µg/m 3 when u sing lead containing mortar, lead burning, or conducting the following activities where lead containing coatings are present: rivet busting, power tool cleaning without dust collection systems, cleanup activities where dry expendable abrasives are used, and the movement and removal of abrasive blasting enclosures. Although not identified in 29 CFR 1926.62, include water jetting and wet abrasive blasting removal of coating in this category.

• Assume an exposure of more than 2,500 µg/m 3 during activities involving lead containing coatings on structures disturbed by abrasive blasting, welding, cutting, and torch burning.

Provide appropriate respiratory protection, personal protective clothing and equipment, change areas and washing facilities, blood lead and zinc protoporphyrin monitoring, and employee training during the above activities. Maintain the protection as specif ied above until the test results are received, then modify the protection measures as necessary. Collect and analyze air samples according to the appropriate National Institute for Occupational Safety and Health (NIOSH) method, or equivalent, for the metal of concern. Conduct periodic worker and Representative exposure monitoring and provide written employee notifications within five days of receipt of results according to the applicable OSHA standard for the metal of concern. This requires monitoring at project start up and after changes in work practices are made that could have an effect on airborne exposures. Conduct the monitoring and employee notification based on OSHA 29 CFR 1926.62. Provide the Department with the results of subsequent monitoring within the same five-day notification period required for the employee, but no later than 14 days after collection.

metals that may be present in the coating being disturbed or the abrasive being used are as follows:

• Lead - 30 µg/m3

• Cadmium - 2.5 µg/m3

• Inorganic arsenic - 5 µg/m3

• Beryllium – 0.1 µg/m3

• Hexavalent chromium – 2.5 µg/m3

For other metals that are found in the coating, and for which no Action Level exists, establish the Action Level at 1/2 of the PEL. Invoke the following protective measures when the airborne exposure to a toxic metal found in the coating exceeds the Action Level:

• Exposure Monitoring

• Housekeeping

• Employee Medical Surveillance and Medical Removal Protection

• Employee Information and Training

• Signs and Regulated Areas

• Record keeping

Limit for lead and other toxic metals that may be present in the coating being disturbed or the abrasive being used are as follows:

• Lead – 50 µg/m3

• Cadmium – 5.0 µg/m3

• Inorganic arsenic - 10 µg/m3

• Beryllium – 0.2 µg/m3

• Hexavalent Chromium – 5.0 µg/m3

The PELs for other metals can be found in 29 CFR 1926.55. In addition to complying with the requirements identified when exceeding the Action Level, invoke the following protective measures when the airborne exposure to a toxic metal found in the coating exceeds the PEL:

• Compliance Program

• Respiratory Protection

• Protective Clothing and Equipment

• Hygiene Facilities and Practices

exposures to lead and other toxic metals below the PEL after feasible engineering controls and work practices have been implemented. Require the use of respirators for employees, inspectors, o bservers, or other personnel who enter areas where airborne exposures exceed or are expected to exceed the PEL, or when entering regulated areas. Provide respiratory protection for two Representatives at each site for each shift, including fit tests. The Department is responsible for verifying that the Representatives are medically fit to wear respirators. Develop a written Respiratory Protection Program in compliance with 29 CFR 1926.103, including commitments to provide the necessary medical examinations. Include the provisions of the associated OSHA standards for each toxic metal that is present in the co ating being disturbed or the abrasive being used. Address the selection, use, maintenance and inspection of respirators, and qualifications for respirator users. Treat used respirator cartridges as hazardous waste and dispose of according to this Section and Federal regulations.

are worn by employees whose exposures exceed the PEL. Provide required protective clothing and equipment for use by two Representatives at each site for each shift. Do not allow workers to wear street clothing beneath protective clothing in areas where exposures to toxic metals exceed the PEL. Clean or replace the protective clothing as required by the appropriate OSHA standard for the toxic metal that is present. In the case of lead, clean or replace the clothing weekly if the airborne exposure levels are less than 200 µg/m3 as an 8-hour TWA, or daily if the exposure levels are greater than or equal to 200 µg/m3. In the case of inorganic arsenic, the threshold for daily versus weekly cleaning is 100 µg/m3. Do not use disposable clothing for longer then one day. Do not remove or clean the clothing by means which reintroduces the toxic metals into the ambient air such as brushing, shaking, or blowing. Use vacuums equipped with HEPA filters for cleaning. Store the used clothing in sealed containers. If the clothing is to be laundered and has been exposed to lead, label the containers with the following:

"DANGER: CLOTHING AND EQUIPMENT CONTAMINATED WITH LEAD. MAY DAMAGE FERTILITY OR THE UNBORN CHILD. CAUSES DAMAGE TO THE CENTRAL NERVOUS SYSTEM. DO NOT EAT, DRINK, OR SMOKE WHEN HANDLING. DO NOT REMOVE DUST BY BLOWING OR SHAKING. DISPOSE OF LEAD CONTAMINATED WASH WATER IN ACCORDANCE WITH APPLICABLE LOCAL, STATE, OR FEDERAL REGULATIONS" .

Modify the above text accordingly if the clothing has been exposed to other toxic metals.

at a minimum. Clean more frequently if visible accumulations are observed that could be carried outside of the regulated area by wind, workers shoes, rainwater, or other means. If grit, dust, or debris containing lead or other toxic metals is disco vered outside of containment, clean immediately. Containerize the debris for proper disposal. Conduct cleaning with HEPA -filtered vacuums and deposit dust and debris in sealed containers. Do not use compressed air for housekeeping purposes unless it is used in conjunction with a ventilation system capable of capturing the resulting airborne particulate.

according to OSHA sanitation standard 29 CFR 1926.51. Locate the hand washing facilities near the coating removal operation, in an area that is convenient for washing before eating or smoking. Provide showers when exposures exceed the PEL. Confirm that employees whose exposures exceed the PEL shower before leaving the project site. Testing and disposal requirements for wastewater are as specified in Section 1072(a)12. Prohibit eating, drinking, smoking, chewing of food or tobacco products, or the application of cosmetics in areas where the

exposure to toxic metals exceeds the PELs or within regulated areas, and confirm that workers thoroughly wash hands and face before undertaking these activities. Provide clean lunch and break areas for use by employees and maintain airborne concentrations in these areas below the Action Levels. Provide clean change area(s) for employees whose exposures exceed the PELs. Equip the change area(s) with separate storage facilities for street clothing that are adequately segregated to prevent cross - contamination from work clothing. Ensure that employees do not leave the project site wearing clothing that was worn while performing activities where exposures exceeded the PELs. Clean the decontamination facilities, lunch area, and hand wash station(s) at least daily.

periodic blood and zinc protoporphyrin (ZPP) sampling and analysis, and medical surveillance as required by the published OSHA health and safety standards that exist for the metal of concern. Verify that the blood analysis is conducted by laboratories certified by the PA Department of Health and meets OSHA accuracy requirements in blood lead proficiency testing (PT). For employees exposed to hexavalent chrom ium, inorganic arsenic, silica , or beryllium, provide the specialized medical surveillance required by the associated OSHA comprehensive health standard. Conduct blood sampling and analysis at a minimum of once every two months for the first six months of exposure, and at six -month intervals thereafter when lead is present. Conduct exit blood tests for each worker upon completion of his/her project activities which involve exposure to lead, even if this occurs before the completion of the Contractor's work on the project. Do not use workers with initial blood lead tests of 40 µg /dl for work activities involving exposure to lead above the Action Level. Provide for the temporary removal of employees from exposures above the Action Level for the metal of concern when the blood analysis indicates that unacceptable results are occurring . Protect employee’s benefits during period of medical removal and conduct tests required by the appropriate OSHA standards during the removal period. In the case of lead, return workers to exposures above the PEL only after two consecutive blood tests are below 40 µg /dl. Provide physical examinations as required by the appropriate OSHA standards for metal(s) of concern and verify that examinations are performed by or under the direct supervision of the licensed physician. Provide exam information and test results to the employees in writing within 5 days of receipt. Submit a letter report signed by a CIH or physician that summarizes examination results. Provide the reports within 10 days of testing.

who will be exposed to toxic metals above the respective Action Levels on any one day in a 12 -month period. Include the elements of training that are required by the appropriate OSHA standard. Use the training outlined in 29 CFR 1926.62 as the basis of the training program highlighting the differences as appropriate for the other metals of concern, if a standard for the metal does not exist. Provide the necessary training for two Representatives at each site for each shift in addition to the training of the Contractors' personnel. Notify other contractors or employers of the nature of the lead exposure work, the need to remain out of exposure areas, the warning signs and labeling system in effect, and the potential need for them to take measures to protect their employees according to the applicable OSHA regulations when they are present at the site.

might generate airborne emissions of lead, cadmium, chromium, inorganic arsenic, or other toxic metal in excess of the Action Level. Use ropes, ribbons, tape, or other visible means to define the areas and prohibit entrance into the regulated areas by unprotected or untrained personnel to ensure that they are not exposed to toxic metals from project activities. Unless directed, until test results are available to establish the perimeter of the regulated area, initially establish the boundary a minimum of 4.6 m (15 feet) away from equipment or operations that might generate airborne emissions of toxic metals. Post caution signs around the regulated area. If a regulation does not exist for the metal of concern, use the legend for the CAUTION sign as found in 29 CFR 1926.62 as the basis, inserting the name(s) of the other toxic metals. Sign requirements for lead, cadmium, and inorganic arsenic are as follows:

DANGER LEAD WORK AREA LEAD MAY DAMAGE FERTILITY OR THE UNBORN CHILD. CAUSES DAMAGE TO THE CENTRAL NERVOUS SYSTEM. DO NOT EAT, DRINK OR SMOKE IN THIS AREA

Use signs that are a minimum of 215 mm (8 1/2 inches) by 275 mm (11 inches) in size with black block lettering on a white, yellow, or orange background. Do not use caution ribbons as a substitute for signs. Conduct sampling according to NIOSH Method 7082 or equivalent for lead and other metals of concern at the pre-established boundaries of the regulated area(s). Collect the samples throughout an entire work shift upon commencement of the coating removal activities (at project-start-up). If the monitoring confirms that project emissions at the established boundary do not exceed the Action Level as an eight-hour TWA, establish the boundary at that location and discontinue monitoring. If the monitoring shows that the emissions exceed the Action Level, modify and improve work practices and containment to provide better controls over the emissions or reestablish the boundary at a different location. Repeat the monitoring in either case. After the boundaries have been established through instrument monitoring, additional monitoring is not required unless directed, if suspect visible emissions occur, or there are changes to the work practices or equipment being used within the regulated areas. In these cases, conduct add itional monitoring to confirm the adequacy of the control systems in place, and to verify the suitability of the existing regulated area(s). Verify that cassettes are only analyzed by laboratories that have been accepted for use by the Department. Have the laboratory provide results within 72 hours of the field sampling. Provide the test results to the Department verbally within one day of receipt, and in writing within one week thereafter. Verify that workers who enter the regulated area have had the proper training, blood analysis and medical examinations, and are wearing the required protective clothing and equipment. Prohibit eating, drinking, smoking, and chewing of food or tobacco products in areas where the exposures exceed the Action Level.

called Histoplasma capsulatum. Protect workers exposed to bird manure (e.g. pigeon) or bat droppings according to National Institute for Occupational Safety and Health (NIOSH) Publication Number 2005-109.

monitoring, respirator fit testing, inspections by a competent person, and other related project documentation on file at the project site. Provide the Department with letter reports signed by a CIH that summarize examination results that are indicative of worker exposures to (or which demonstrate proper protection from) toxic metals. In the case of lead, summarize the blood lead and ZPP resul ts, indicate observed trends, and identify worker removal provisions that were invoked based on the results. Workers should be identified by a unique identification number and not by name. Provide summary reports of the test results before worker exposures to project activities, periodic surveillance results, and results upon completion of site exposures. Provide a copy of each signed report within 10 calendar days after issuing the test results to the employees, and no later than 21 days of testing. Retain records for the duration of employment plus 30 years.

and local regulations governing the protection of the public and the environment. Remove visible abrasives, paint chips, and debris from the project site, even if the abrasives, paint chips, and debris were a pre-existing condition. Include the cost for clean-up of pre-existing debris in the bid. Comply with Title 3 of the Philadelphia Code, the Air Management Code, for work occurring in Philadelphia County. Comply with Philadelphia County Air Management Regulation II, Section VIII, (relating to Fugitive Dust), for work occurring in Philadelphia County.

Comply with Allegheny County - Article XXI, Rules and Regulations of Allegheny County Bureau of Environmental Quality, Section 2105.51 (relating to Abrasive Blasting), for work occurring in Allegheny County.

established in this Section according to 40 CFR 60, Appendix A, Method 22, Visual Determination of Fugitive Emissions from Material Sources and Smoke Emissions from Flares. These assessments are based on total fugitive emissions and cannot be used to determine the opacity of the emission. Conduct visual inspections for releases or spills of dust and debris that have become airborne even when the paint being removed does not contain lead or other toxic metals. 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, with special consideration of sensitive receptors identified in the Plan. Comply with Federal, State, City, or County regulations and statutes regarding emissions of hazardous, visible or fugitive air contaminants, in addition to, but not as a replacement for, the requirements as specified in this Section.

from project activities to an SSPC Level 0 (any sustained visible emission regardless of its duration) according to SSPC Technology Update No. 7. Conduct visible emission assessments according to 40 CFR 60, Appendix A, Method 22. Immediately shut down the emission -producing activities if emissions in excess of the criteria stipulated in this Section 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 rainwater could carry the debris into storm sewers or drains immediately.

assessments according to this Section and SSPC Technology Update No.7. Conduct the visible emissions assessments to account for locations where emissions might be generated, including but not limited to, the containment, dust collection and abrasive recovery equipment, and waste containerizing areas for at least a 15-minute duration during each observation period. Document the name of the assessor , the date and time, and the results of observations, even if no emissions are observed. Have the daily records available on site for Department review. Conduct casual observations and corrections of visible and fugitive air contaminant emissions and releases of dust or debris on an ongoing daily basis but conduct the specialized assessments as described in this Section at least once per hour during dust producing activities. Conduct casual observations at the project perimeter and adjacent and nearby properties, especially those identified in the Sensitive Receptor Survey, and correct fugitive emissions and releases of dust or debris on an ongoing daily basis.

other report form. Record the results of the assessments as soon as possible following the observations, but no later than the end of the work shift on that day. Maintain the logbook or reports on site for review by the Department. Document cases where work has been halted due to unacceptable emissions or releases of visible, fugitive, or hazardous air contaminants or 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.

paint or abrasive, conduct high volume ambient air monitoring for lead during coating removal and clean - up activities using the procedures specified in 40 CFR 50 Appendix B & G, and in compliance wit h this Section. Comply with the acceptance criteria established in City, Township, County, State or Federal

regulations when applicable. Comply with the criteria below if there are no local regulations governing high volume ambient air monitoring for lead. Ambient air monitoring is to be performed by an independent third-party monitoring firm. TSP-Lead (Total Suspended Particulate-Lead) – The National Ambient Air Quality Standard for TSP- lead is 0.15 µg/m3 as a 90-day rolling average. However, for the purposes of evaluating the effectiveness of the containment system in limiting emissions, do no t exceed 1.5 µg/m3 averaged over the specified sampling period detailed below. For the purposes of establishing a daily allowable limit, the acceptance criteria are extrapolated using the formulas identified in SSPC TU -7. Note that some local agenc ies establish their own acceptance criteria - do not exceed these criteria. Place TSP-Lead ambient air monitors at the nearest location(s) required to ensure that the public’s health is protected and to reduce public concerns, as specified in the Plan, and in the location(s) acceptable to the Representative or designee. In many ca ses, and as determined in the Sensitive Receptor Survey, more than one monitor may be required because the designated monitoring targets may be located at different distances and different directions from the work areas. On large structures, the required monitoring locations may change as the work areas change. The third-party monitoring firm will select air monitoring locations, subject to review and approval by the Representative or designee. Conduct background ambient air monitoring daily for a period of 3 days before blasting. The 3 days of background ambient air monitoring is to be conducted for 8 hours each day, during the hours of the day when dust generating activities such as abrasive blasting will typically be performed. Identify the proposed background monitoring locations in the Environmental Compliance Plan. Background concentrations of TSP-lead may be subtracted from the acceptance criteria identified above. Conduct daily full -time continuous ambient air monitoring for TSP -lead during dust producing operations that are performed within 500 feet of potential public receptors. After review of a minimum of two weeks of monitoring data, the Representative may approve suspension of the daily monitoring requirement. Resume daily ambient air monitoring if control problems with blasting emissions become apparent, as determined by visual assessments of the operation. Instruct the third-party monitoring firm to provide analytical laboratory results within 72 hours after field sampling has been performed, unless local requirements are more stringent. Instruct the laboratory to analyze the filters according to 40 CFR 50, Appendix G and report results directly to the Department in micrograms per cubic meter. The report must identify the monitoring locations and work activities performed for each sample collected. If monitoring is conducted and the above criteria is violated, immediately stop work and make changes to the containment and work practices to achieve compliance. Note that exceedances may also result in City, Township, County, State or Federal violations.

releases to the soil, water, sediment, or storm sewers do not occur. If particulate matter or debris is released beyond the containment or ground protection, immediately shut down the emission-producing operations until the cause of the emissions is corrected.

property, equipment, and structures. When cleaning paint chips and dust that contain lead or other toxic metals, 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 as specified in this Section.

surrounding property and surfaces located within the likely dispersion zone of project dust and debris upon completion of project activities, and after equipment and materials have been removed. Visually inspect the property and surfaces for the presence of debris including, but not limited to spent abrasives or other coating removal media, paint chips, materials of construction, fuel, and other litter. Conduct a final visual inspection with the Representative after clean-up activities are completed.

Conduct additional cleaning identified by the Department. Consider the site properly cleaned when visible paint chips, spent abrasives and other coating removal media, fuel, materials of construction, litter, or other project debris are not visible on or around the project site. Remove visible dust from the surface of the completed structure as well as from surrounding structures and equipment.

conducted to verify the final cleanliness of the project site, surrounding property, waterways, equipment, buildings, and structures. Provide the report to the Department within 7 days following the inspection. Include a summary of problems or releases that occurred during the project, and the clean -up and corrective action measures that were taken to resolve the problem.

11.a 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 Representative, the EPA according to 40 CFR 117 and 40 CFR 355, and the DEP. Notify the Fish and Boat Commission, and the Coast Guard, when applicable.

11.b 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 Representative, the DEP, and the National Response Center (800/424-8802).

11.c City of Philadelphia. If reportable releases or emissions pose an imminent danger to public health, safety, welfare, or the environment, or violate permit conditions, immediately notify the Department of Public Health, Air Management Services.

1072.4MEASUREMENT AND PAYMENT—

Includes collection, testing, handling, storage, transportation, and disposal of waste (hazardous, residual, and non-hazardous including wastewater). Partial payment may be made for this item. Payment will be made only after the Department receives properly executed waste disposal documentation, including certificates of disposal. If there are discrepancies in quantities or in any of the documentation requirements, payment will be withheld until the discrepancies are resolved.

Price includes containment and ventilation materials and equipment, engineering, drawings, and equipment or facilities needed to install, operate, move, clean, dismantle, and remove the containment system from the project site. Partial payments for containment will be made based on the percentage of the structure that has been prepared and fully primed. Environmental monitoring and protection are incidental to containment.

Price includes protection of Contractor personnel, including protective clothing and equipment, medical surveillance, hygiene facilities, laundering, establishment and maintenance or regulated areas, and documentation. Price also includes protective clothing and equipment for two Representatives at each site for each shift, as well as lead training according to 29 CFR 1926.62. Partial payments for worker protection will be made based on the percentage of the structure that has been prepared and fully coated.