evaluation of corrective action …...evaluation of corrective action alternatives & corrective...

EVALUATIONOFCORRECTIVEACTIONALTERNATIVES

&CORRECTIVEACTIONPLAN1,3,5CANADASTREETANDMUNICIPALLOTAT

MERCHANTSROWSwanton,VT

SMSSite#2016‐4658PreparedforNorthwestRegionalPlanningCommission

FileNo.4091.00April2018

TABLE OF CONTENTS

EXECUTIVE SUMMARY .............................................................................................................................. I

1.0 INTRODUCTION .............................................................................................................................. 1 1.1 Objectives and Scope of Services ............................................................................................... 1 1.2 Site Description and History ........................................................................................................ 2 1.3 Abutters ............................................................................................................................................... 3 1.4 Summary of Previous Environmental Investigations ........................................................ 3 1.5 Current and Proposed Future Use ............................................................................................. 3

2.0 CONCEPTUAL SITE MODEL ....................................................................................................... 4 2.1 Site Hydrogeology ............................................................................................................................ 4 2.2 Potential Contaminant Sources and Pathways ..................................................................... 5

2.2.1 Petroleum Impacts – Soil and Groundwater .................................................................. 5 2.2.2 Impacts to Soil Gas ................................................................................................................... 7 2.2.3 Hazardous Building Materials ............................................................................................. 8

2.2.3.1 Universal Waste .......................................................................................................... 9 2.2.3.2 Recommendations ..................................................................................................... 9

2.3 POTENTIAL RECEPTOR EVALUATION .................................................................................... 9

3.0 PERFORMANCE STANDARDS - CLEANUP GOALS AND APPLICABLE GUIDELINES .................................................................................................................................. 10

4.0 EVALUATION OF CORRECTIVE ACTION ALTERNATIVES ....................................... 11 4.1 Remedial Action Objectives ...................................................................................................... 11 4.2 Evaluation of Cleanup Alternatives ....................................................................................... 11 4.3 Justification for the Selected Remedial Alternative ......................................................... 12

5.0 CORRECTIVE ACTION PLAN .................................................................................................. 13 5.1 Redevelopment Plan .................................................................................................................... 13 5.2 Basis of Design and Materials Construction ....................................................................... 13 5.3 Best Management Practices for Green and Sustainable Remediation ..................... 14 5.4 Waste Management Plan ............................................................................................................ 14 5.5 Health and Safety .......................................................................................................................... 14 5.6 Permitting ........................................................................................................................................ 15 5.7 Reporting ......................................................................................................................................... 15 5.8 Schedule............................................................................................................................................ 15 5.9 Project Contractors ...................................................................................................................... 15 5.10 Opinion of Cost – Selected Alternatives ............................................................................... 16

7.0 INSTITUTIONAL CONTROLS – CERTIFICATE OF COMPLETION........................... 16

8.0 ADDITIONAL CONSIDERATIONS ......................................................................................... 17

9.0 REFERENCES ................................................................................................................................ 17

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10.0 LIMITATIONS ................................................................................................................................ 18

11.0 PROFESSIONAL ENGINEER’S REVIEW ............................................................................. 19 TABLES Table 1 Summary of Groundwater Elevations Table 2 Summary of Analytical Results - Soil Table 3 Summary of Analytical Results – Groundwater Table 4 Summary of Analytical Results – Soil Gas Table 5 Summary of Environmental Contamination, Evaluation of Inferred Sources and

Potential Receptors Table 6 Evaluation of Remedial Alternatives FIGURES Figure 1 Locus Plan Figure 2 Site Vicinity Plan Figure 3 Groundwater Elevation Contour Plan Figure 4 Soil Contaminant Distribution Plan Figure 5 Groundwater Contaminant Distribution Plan Figure 6 Soil Gas Contaminant Distribution Plan APPENDICES Appendix A Site Redevelopment Plan Appendix B Public Notice with Parcel Map/Abutters

Appendix B.1 Public Notice Appendix B.2 Parcel Map/Abutters

Appendix C FEMA Flood Map Appendix D RPF’s HBM Reports

Appendix D.1 January 4, 2017 HBM Report Appendix D.2 March 23, 2018 HBM Report

Appendix E RPF’s HBM Abatement Specifications Appendix E.1 Asbestos Abatement Specifications Appendix E.2 Lead-Based Paint Abatement Specifications Appendix E.3 Universal Waste Abatement Specifications

Appendix F Stego Wrap Product Sheet and Installation Instructions Appendix G Opinion of Cost Tables

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EXECUTIVE SUMMARY On behalf of the Northwest Regional Planning Commission (NRPC), Sanborn, Head & Associates, Inc. (Sanborn Head) prepared this Evaluation of Corrective Action Alternatives (ECAA)/Corrective Action Plan (CAP) for the 1-3-5 Canada Street and the Municipal Lot at Merchants Row (the “site”) located in Swanton, Vermont (SMS Site #2016-4658). This ECAA/CAP was prepared to address soil, groundwater, and soil vapor contamination, as well as hazardous building materials (HBMs) identified as part of Phase II Environmental Site Assessment (ESA) activities performed at the site. The site consists of three parcels: the “Municipal Lot”, with Memorial Building and connected Warehouse Building, and separate small Swanton Chamber of Commerce building, 1 Canada Street (the Prouty Building), 3 Canada Street (the Theatre Building), and the connector building (5 Canada Street). Together, the three parcels comprising the site total approximately 1.4 acres. The site owner intends to redevelop a portion of the Memorial Building/Warehouse Building into a mixed retail and commercial building, remove the Prouty Building (1 Canada Street), renovate the Theatre Building (3 Canada Street) and the connector building (5 Canada Street) along Canada Street, and relocate or remove the Swanton Chamber of Commerce building. The ECAA/CAP addresses remedial actions that will be required during redevelopment of the property to prevent future exposure of site users to site contaminants. Findings of the Phase II ESA indicated that soil contaminated at the site is limited to one area north of the Warehouse Building (an exceedance of the benzo(a)pyrene Vermont Residential Toxicity Equivalence Quotient [TEQ] Soil Screening Value [SSV]), at a depth of 7.5-8.5 feet below ground surface (ft bgs). The soil sample was collected beneath a former fuel oil underground storage tank (UST) located north of the Warehouse Building, and based on the absence of detectable volatile organic compounds (VOCs) and total petroleum hydrocarbons (TPHs), and the presence of low-level mid- to high-molecular weight Polycyclic aromatic hydrocarbon (PAHs) in two of the UST soil samples, the presence of benzo(a)pyrene is inferred to be related to urban fill soil conditions, and not indicative of a petroleum release. No exceedances of the Vermont Industrial SSVs were detected as part of Phase II ESA activities. The soil excavation associated with site redevelopment is not anticipated to disturb the 7.5-8.5 ft bgs interval, and further, a building is proposed to be constructed over the soil sampling location, which would prevent direct contact. Soil disturbed as part of site redevelopment will be reused on-site. Groundwater results from on-site monitoring wells indicated concentrations of the petroleum-related VOC analytes, PAHs, and TPH fingerprinting were consistent with an off-site petroleum release – most likely gasoline – located to the south of the site. Chlorinated VOCs were not detected in the groundwater samples, and exceedances of the Vermont Groundwater Enforcement Standard (ES) and Preventative Action Level (PAL) were limited to aromatic VOCs (AVOCs): ethylbenzene, toluene, naphthalene, and 1,2,4-trimethylbenzene. Based on these findings, and the availability of public water at the site, a prohibition on groundwater extraction is proposed as part of corrective measures.

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While low-level petroleum-related and other VOCs were detected in soil gas, exceedances of the Vermont Department of Environmental Conservation (VT DEC) Vapor Intrusion (VI) Screening Values were limited to tetrachloroethene (PCE), chloroform, and naphthalene, which all indicated at least one exceedance of the VT DEC Residential VI Screening Level. Chloroform and naphthalene are not considered site-sourced contaminants and are not considered to represent VI risk as part of site redevelopment. PCE was detected beneath the Memorial Building at concentrations exceeding the VT DEC Residential VI Screening Level, but below the VT DEC Industrial VI Screening Level. Based on the site redevelopment plans as mixed retail and commercial space, the PCE in soil gas does not represent unacceptable risk. Nevertheless, as part of site redevelopment, the site owner plans to fill and seal the Memorial Building basement to be flush with the surrounding grade. The basement filling is considered a further measure to mitigate VI potential. Asbestos-containing material (ACM) and lead-based paint (LBP) were documented to be present in site buildings. Universal waste (i.e., mercury containing fluorescent lighting and possible PCB-containing light ballasts) were also inventoried at the site. These HBMs are proposed for removal as part of site redevelopment. The CAP recommends activities to be performed as part of site redevelopment to serve as protective remedial measures to mitigate potential risks to human health and the environment. The recommended remedial actions include: 1. Implementation of institutional controls on the site property in the form of a Certificate

of Completion (COC) under the State of Vermont Brownfields Reuse and Environmental Liability Limitation Act (BRELLA). Limitations on property proposed to be included in the COC include:

a. Notice within the COC that requires notification to DEC if any future soil disturbance will occur in areas where contamination has been identified.

b. A Deed Restriction to prohibit groundwater extraction.

2. Filling and sealing the Memorial Building basement to mitigate potential VI impacts.

3. Abatement of HBMs.

1.0 INTRODUCTION On behalf of the Northwest Regional Planning Commission (NRPC), Sanborn, Head & Associates, Inc. (Sanborn Head) prepared this Evaluation of Corrective Action Alternatives (ECAA)/Corrective Action Plan (CAP) for the 1-3-5 Canada Street and the Municipal Lot at Merchants Row (the “site”) located in Swanton, Vermont (SMS Site #2016-4658). Refer to Figure 1 for a Locus Plan for the site. Phase II sampling was performed at the above-referenced property, as well as on the adjacent 7 Merchants Row property, where a multi-unit apartment building is located. Based on the findings of a Phase II sampling, corrective actions are required at the site to prevent unacceptable risk of exposure to site users to: direct contact with contaminated soils, ingestion of contaminated groundwater, and volatile organic compounds (VOCs) through the vapor intrusion (VI) pathway. We understand the site owner intends to redevelop a portion of the Memorial Building/Warehouse Building into a mixed retail and commercial building, remove the Prouty Building (1 Canada Street), renovate the Theatre Building (3 Canada Street), and the connector building (5 Canada Street) along Canada Street, and relocate or remove the Swanton Chamber of Commerce building. Refer to Appendix A for a site redevelopment plan. Sanborn Head’s services were performed under NRPC’s U.S. Environmental Protection Agency (USEPA) hazardous waste Brownfields assessment grant. Sanborn Head prepared this ECAA/CAP pursuant to our Work Plan and Budget Estimate, dated January 29, 2018. This ECAA/CAP and Sanborn Head’s related services are subject to the limitations provided in Section 9. A list of project contacts is included below:

Exhibit 1. Summary of Project Contacts Contact Organization Telephone E-mail

Greta Brunswick, Senior Planner

Northwest Regional Planning Commission

802-524-5958 [email protected]

Tim White, Project Manager

Sanborn, Head & Associates, Inc.

603-415-6139 [email protected]

Kim Caldwell, Environmental Analyst

VT DEC 802-461-5857 [email protected]

Dorrie Paar, Project Officer

USEPA Region 1 617-918-1432 [email protected]

1.1 Objectives and Scope of Services

This ECAA/CAP has been prepared to evaluate and select options to mitigate the risk of exposure to site users through direct contact with contaminated soils, ingestion of contaminated groundwater, and potential inhalation of VOC-contaminated air via the VI pathway.


This ECAA/CAP was prepared in accordance with Investigation and Remediation of Contaminated Properties Rule (I-Rule), effective July 27, 2017, and includes: Development of an Executive Summary and Public Notice that includes:

Description of the contamination;

Review of results of the investigations; and

A description of the chosen corrective actions.

Listing of the Public Notice (refer to Appendix B);

A description of the contaminants present on the site with a summary of available data;

A list of sensitive receptors, impacted or potentially impacted third parties, and adjacent landowners;

A description of the site remedial goals, including applicable regulatory standards and screening values being addressed as part of the corrective action;

A description of the proposed remedies including the objectives and methods of implementation;

A list of the institutional controls proposed to be included in the Certificate of Completion (COC);

A cost estimate and schedule for implementing the corrective action; and

A detailed site redevelopment plan (provided as Appendix A).

1.2 Site Description and History

The following summary of site history is based on information provided in Sanborn Head’s September 2016 Phase I ESA. The approximate midpoint of the site is located at approximately 44°55’12.20”N, 73°07’31.63”W (refer to Locus Plan [Figure 1] and Site Vicinity Plan [Figure 2]).1

Municipal Lot

We understand that the Memorial Building was constructed in the 1940s and served as a Veterans’ Hall until the 1970s. In the 1970s, the Warehouse Building was constructed and attached to the eastern wall of the Memorial Building. A food and clothing distribution business is located on the second floor of the Memorial Building and the Warehouse Building, and the Swanton Teen Center occupies the first floor (basement) portion of the Memorial Building. To the southwest of the Memorial Building on the Municipal Lot property is an

1 Latitude/longitude (NAD 83 [2011]) identified based on the surveyed coordinates of monitoring well MW-

123. Use geographic coordinates: 44°55’12.20326”N, 73°07’31.63311W to locate the site.


approximately 250 square foot (ft2) building that houses the Swanton Chamber of Commerce.

1-3-5 Canada Street

The 1-3-5 Canada Street properties total approximately 0.15 acres and contain an approximately 12,000 ft2 multi-level masonry retail and apartment space that formerly housed a variety of businesses including a grocery store, flooring store, hair salon, theatre, and other businesses since the 1800s. The structure at 1 Canada Street is referred to as the Prouty Building. The structure at 3 Canada Street is referred to as the Theatre Building. The Theatre Building and neighboring 7 Canada Street are connected by a low roofed building referred to as 5 Canada Street. 1.3 Abutters

Properties abutting the site are indicated on Figure 2, and a parcel map is shown in Appendix B, and summarized below on Exhibit 2.

Exhibit 2. Summary of Abutting Properties General Direction

From Site Abutter North Marble Mill Park (Swanton Village) East 15 Canada Street (Peoples United Bank)

South/East 7 Canada Street (The Parts Store [auto parts store])

Northwest 21 Merchants Row (Roy Insurance building)

West • Vacant lot • 7 Merchants Row (apartment building)

1.4 Summary of Previous Environmental Investigations

As discussed below, Sanborn Head performed Phase I and Phase II ESA activities at the site. In addition to Sanborn Head’s Phase I & II ESAs, we understand an environmental investigation related to the Former E.J. Barrette Ford (currently owned by Bourne’s Energy) property at 10 Canada Street (SMS Site #1989-0420) is on-going with oversight by VT DEC. The Former E.J. Barrette Ford site is located south (upgradient) of the Municipal Lot/1-3-5 Canada Street parcels, and we understand the Barrette Ford investigation includes groundwater monitoring on the site. The former Swanton Gulf site (SMS Site # 2013-4357) is also located south (upgradient) of the site, and received a Site Management Activity Completed (SMAC) letter from VT DEC on September 28, 2015. Based on available documentation, no prior remedial activities have been performed at the site to address the contaminants discussed in this report. 1.5 Current and Proposed Future Use

Based on information gathered during the Phase I ESA, we understand the Municipal Lot property now serves as a distribution business (located in the Warehouse Building and


upper level of the Memorial Building) and also houses the Swanton Teen Center on the lower level of the Memorial Building. The 1-3-5 Canada Street properties are currently vacant. We understand that the prospective purchaser intends to redevelop a portion of the Memorial Building into a mixed retail and commercial building, remove the Prouty Building (1 Canada Street), and renovate the Theatre Building (3 Canada Street), and the connector building (5 Canada Street) along Canada Street (refer to the redevelopment plan in Appendix A). The soil excavation associated with site redevelopment is not anticipated to disturb the interval where benzo(a)pyrene was detected above the Vermont Soil Screening Value (SSV). Further, a building is proposed to be constructed over the soil sampling location (refer to Appendix A), which would prevent direct contact. Soil disturbed as part of site redevelopment will be reused on-site. 2.0 CONCEPTUAL SITE MODEL This conceptual site model (CSM) presents an interpretation of available information and observations from the Phase II ESA regarding potential contamination sources and pathways at the site. The CSM was first described in the February 2017 Phase II ESA Report, and updated in subsequent Soil Gas Phase II ESA reports, including information compiled as part of the adjacent 7 Merchants Row Soil Gas Phase II ESA activities. 2.1 Site Hydrogeology

Based on groundwater level measurements collected as part of Phase II ESA activities, the inferred direction of groundwater flow is to the north-northwest, towards the Missisquoi River. This flow direction is consistent with the ground surface topography for the site vicinity, which slopes downward to the north toward the northeasterly flowing Missisquoi River, the inferred discharge location for site groundwater. Refer to Figure 3 for groundwater elevation contours (groundwater elevations from May 24 and 25, 2017 are indicated on Table 1 and Figure 3). Based on the findings of the Phase II ESA, the site is underlain by a layer of overburden soil, generally composed of a thin (i.e., 1 to 7 ft) fill unit overlying natural sand that becomes finer with depth. The fill layer consists of dark gray, medium to fine sand, with varying amounts of silt, gravel, and anthropogenic material (e.g., bricks). The underlying natural unit consists of fine to medium sand (typically light brown and changing to gray with depth) with variable silt content (up to 10%). The sand unit extended to the bottom of each boring at approximately 15 ft bgs and no borings encountered refusal or bedrock. The groundwater table was present within the sand unit, typically at a depth of approximately 10 ft bgs. Based on soil borings/monitoring wells completed on the site, bedrock was not encountered, and is located at depths greater than 15 ft bgs. Bedrock was not observed at the site, but was observed approximately 150 feet north of the site along the Missisquoi River at an elevation of approximately 40 feet below the site elevation. Based on the U.S. Geological Survey (USGS) Bedrock Geologic Map of Vermont (as reviewed on the USGS Geographic Information System


[GIS] website), underlying bedrock is classified as the Iberville Formation, an Upper Ordovician-age dark gray shale with thin discontinuous beds of cross-bedded and graded dolomitic siltstone for much of the site. The observed bedrock north of the site along the Missisquoi River was consistent with the USGS description (Ratcliffe, et al., 2011). Site groundwater elevation in May 2017 ranged from approximately 130 feet above mean sea level (amsl) to 134 ft amsl. To the north of the site in Marble Mill Park, the groundwater elevation was approximately 104 feet amsl, with an inferred steep decline from the site to the park, which is reflected in the ground surface slope. The overburden groundwater elevation at the site is inferred to be about 30-35 feet higher than the water level in the Missisquoi River north of the site, noting that the surface topography at the site is about 40 feet higher than the surface water level at the river. According to FEMA Flood Zone Map 5000600001B, the site is located within a Zone C of the Missisquoi River (refer to Appendix C), where minimal flooding is expected because the site is located on a terrace about 40 feet higher than the River. 2.2 Potential Contaminant Sources and Pathways

The data collected during the Phase II ESA activities indicate the following contamination issues and areas: Polycyclic aromatic hydrocarbon (PAH) and petroleum VOC-related (primarily gasoline)

impacts to soil, soil gas, and groundwater.

Localized tetrachloroethene (PCE) impacts to soil gas beneath and adjacent to the Memorial Building.

Presence of HBMs in site buildings (refer to HBM reports in Appendix D).

2.2.1 Petroleum Impacts – Soil and Groundwater

TPH fingerprinting results demonstrated gasoline-related impacts in site soil and groundwater samples collected near the groundwater table, with the exception of soil and groundwater samples from SH-5W which indicated: a mixture of gasoline and diesel/No. 2 fuel oil (soil – 9-10 ft bgs interval [inferred to be within the groundwater table “smear” zone]); and a mixture of gasoline and lubricating oil (groundwater). A review of historical information for the site did not indicate gasoline storage on-site. Further, two upgradient sites have documented gasoline releases, including investigation on a portion of the site subject to this assessment. The 9-10 ft bgs soil sample at monitoring well SH-2W (located near the southwest corner of the Prouty Building near Canada Street) indicated exceedances of the residential soil SSVs for several petroleum-related analytes (i.e., ethylbenzene, naphthalene, total trimethylbenzenes, dibenzo(a,h)anthracene, and the BaP TEQ) within the groundwater table smear zone. Therefore, the 9-10 ft bgs interval at SH-2W is considered to be representative of groundwater, rather than vadose soil conditions. Based on groundwater flow direction relative to the documented gasoline releases, and the general absence of gasoline-impacted


vadose zone soil on the subject site, the inferred source of gasoline-related impacts is understood to be from off-site, likely the Former E.J. Barrette Ford site and/or the Former Swanton Gulf site, and urban fill soil conditions may also be present (as evidenced by the PAHs detected in the sample). Site redevelopment is not anticipated to extend to the 9-10 ft bgs interval at SH-2W. As indicated on the site redevelopment plan in Appendix A, the SH-2W location will be located beneath the new site driveway, which will preclude ready access to soil in the 9-10 ft depth. Based on information provided by VT DEC (refer to Appendix B.3 of the February 2017 Phase II ESA Report), soil excavation related to waterline replacement in Canada Street north of the Former Swanton Gulf and Former E.J. Barrette Ford sites (where petroleum releases have been documented) was performed in June 2016 on behalf of the Village of Swanton, and included field screening with a PID. According to the July 11, 2016 summary prepared by Ross Environmental Associates, Inc. (Appendix B.3 of the February 2017 Phase II ESA Report), field screening of soils excavated down to approximately 7 ft bgs results indicated PID concentrations less than 8.8 parts per million by volume (ppmv). No dewatering was reportedly performed as part of the excavation, indicating that groundwater migrating north from the Former Swanton Gulf and Former E.J. Barrette Ford sites is greater than 7 ft bgs. Based on the findings of the Phase I ESA, Sanborn Head performed Phase II ESA soil and groundwater sampling. Two underground storage tanks (USTs) were previously located on-site: “UST West” an approximately 3,000-gallon capacity single wall steel tank located near the northwest corner of the Memorial Building, and “UST-East” an approximately 1,000-gallon capacity single wall steel tank. Both former USTs were reportedly used for on-site heating purposes, and both USTs and associated piping were removed in spring 2017 as part of Sanborn Head’s Brownfields Phase II ESA activities, performed on behalf of NRPC under the Brownfields assessment grant. Following removal, the USTs and related piping were cleaned and transported offsite for recycling. Soils immediately surrounding both USTs were sampled and only one sample (UST-East/S2 sample [7.5 to 8.5 ft bgs] indicated an exceedance of the Residential VT DEC SSV. Benzo(a)pyrene was detected in the UST-East/S2 sample at a concentration of 0.083 mg/kg, in exceedance of the Vermont Residential Toxicity Equivalence Quotient (TEQ) SSV (0.076 mg/kg), but below the Vermont Industrial TEQ SSV (1.54 mg/kg)2. Other PAHs detected and contributing to a lesser degree to the total TEQ of 0.099 mg/kg for this sample include: benzo(a)anthracene, benzo(k)fluoranthene and chrysene. Fluoranthene, phenanthrene and pyrene were also detected in this sample at concentrations well below SSVs.

The soil samples from beneath both UST-West and UST-East were non-detect for VOCs. PAHs were not detected in the UST-West samples, nor in the UST-East/S1 sample. PAH concentrations in the UST-East/S2 sample were below the Vermont Industrial SSVs. The BaP

2 "Vermont SSVs" were obtained from Appendix A.1 of the "Investigation and Remediation of Contaminated

Properties Rule" ("I Rule"), effective July 27, 2017. http://dec.vermont.gov/sites/dec/files/wmp/Sites/07.11.2017.Adopted.Rule_.for_.SOS_.filing.pdf; downloaded on July 19, 2017. The USEPA Regional Screening Levels included in the I Rule were updated to reflect the June


concentration in the UST-East/S2 sample was the only exceedance of the Vermont Residential SSVs detected at the site. The soil analytical results from sampling beneath the USTs are summarized in Table 2, shown on Figure 4. Groundwater results from on-site monitoring wells indicated concentrations of the petroleum-related VOC analytes, PAHs, and TPH fingerprinting were consistent with an off-site petroleum release – most likely gasoline – located to the south of the site. Chlorinated VOCs were not detected in the groundwater samples, and exceedances of the Vermont Groundwater Enforcement Standard (ES) and Preventative Action Level (PAL)3 were limited to aromatic VOCs (AVOCs): ethylbenzene, toluene, naphthalene, and 1,2,4-trimethylbenzene.

2.2.2 Impacts to Soil Gas

While low-level petroleum-related and other VOCs were detected in soil gas, exceedances of the VT DEC VI Screening Values were limited to PCE, chloroform, and naphthalene, which all indicated at least one exceedance of the VT DEC Residential VI Screening Level. Only chloroform exceeded the VT DEC Industrial VI Screening Values on the site (one location: in the basement of the Prouty Building, which is planned for demolition). Because of the planned demolition of the Prouty Building, chloroform does not pose an unacceptable VI risk for future commercial use of the site. The soil gas analytical results are shown on Figure 6. As summarized on Table 4, only PCE is inferred to represent conditions related to a potential on-site release. Given that PCE and chloroform were not detected in soil or groundwater samples collected as part of the Phase II investigations, there is no definitive on-site source for these compounds. As indicated in the table above, chloroform in soil gas is most likely related to the presence of chlorinated water from municipal water and/or sewer lines. NRPC provided Sanborn Head with excerpts of subsurface utility plans maintained by the Village of Swanton. Approximate subsurface utility locations identified by Sanborn Head are indicated on Figure 2. These plans include information regarding subsurface utilities in the Merchants Row and Canada Street rights-of-way, but do not indicate utilities adjacent to the Memorial Building. The purpose of reviewing the utility information was to identify potential preferential subsurface migration pathways in the site vicinity. The subsurface utilities are inferred to be above the groundwater table, and therefore are not anticipated to influence contaminant migration in groundwater. However, given that soil gas migrates along preferential pathways, including potentially along formerly excavated areas associated with subsurface utilities, the information regarding the location of subsurface utilities was compiled. There does not appear to be a utility corridor connecting the Former Greers Dry Cleaner (an area of inferred potential historical PCE use, but with no confirmed release) to the Memorial Building. Only one utility (a water line) was identified leading from Merchants Row to the Memorial Building (refer to Figure 2).

3 "Vermont Primary Groundwater "PAL" and "ES" Standards are Primary Groundwater Standards from the

State of Vermont Agency of Natural Resources Department of Environmental Conservation "Chapter 12 of the Environmental Protection Rules: Groundwater Protection Rule and Strategy" (December 16, 2016), including the March 4, 2016 Interim Groundwater Quality Standards. "ES" is Enforcement Standard; "PAL" is Preventive Action Level.


Given the absence of PCE detections in soil gas in locations along Merchants Row, migration of PCE from off-site in this area is not indicated. Floor drains in the basement of the Memorial Building were inspected, and only one floor drain near the southern basement entrance of the Memorial Building indicated the presence of sediment. The sediment in that floor drain was analyzed for VOCs, which were not detected. Further, the floor drains were observed to be connected to the sanitary sewer. Based on this information, the floor drains could not be confirmed or ruled out as a source of PCE in soil gas. However, given the distribution of PCE in soil gas, the data are consistent with a limited PCE release to the subsurface beneath or adjacent to the Memorial Building. Soil gas sampling performed west/northwest of the Memorial Building indicated PCE concentrations are non-detect. 2.2.3 Hazardous Building Materials

Hazardous building materials surveys were performed by RPF Environmental, Inc. (RPF) of Northwood, New Hampshire, on December 6, 2016 and February 28, 2018. Due to the age of the site buildings, HBMs including: asbestos, lead-based paint, and universal wastes (e.g., fluorescent bulbs and ballasts, mercury switches) were observed in one or more of the site buildings. A summary of RPF’s findings is provided below and copies of RPF’s reports are included in Appendix D.

Exhibit 3. Summary of HBM Findings

Location ACM >1%

Lead-Based Paint

(>0.5% by weight)

PCB Light

Ballasts Fluorescent

Bulbs Mercury Switches

Other Potential

Hazardous Materials

1 Canada Street

- Category I & II Nonfriable - Roof: Category I & II Nonfriable

Yes

Leachable lead >5 mg/l – portions

anticipated to require disposal

as characteristically

hazardous

Yes

Yes

Yes None observed

3 Canada Street

- Friable - Category I Nonfriable - Category II Nonfriable - Friable RACM - Roof: Category I & II Nonfriable

Yes

Leachable lead

<5 mg/l

Yes

Yes

Yes

Solvents, oil, paints

5 Canada

Street

- Category II Nonfriable - Roof: Category I Nonfriable

Lead results <0.5%

Leachable lead

<5 mg/l

Yes

Yes No Refrigerators


Location ACM >1%

Lead-Based Paint

(>0.5% by weight)

PCB Light

Ballasts Fluorescent

Bulbs Mercury Switches

Other Potential

Hazardous Materials

Memorial Building

- Friable RACM - Category II Nonfriable - Roof: Potential ACM to remain in place as part of redevelopment

Lead results <0.5%

Yes

Yes

Yes

AC unit, refrigerator, various paints and electrical components

Warehouse - Category II Nonfriable - Roof: Potential ACM to remain in place as part of redevelopment

Lead results <0.5%

Yes

Yes

No None Observed

Chamber of Commerce

- Category II Nonfriable Lead results <0.5%

No No No AC unit

Notes: 1. This summary was prepared based on the findings from the Hazardous Building Materials (HBM) survey performed on December 6, 2016 by

RPF of the Memorial Building and connected Warehouse, as well as the retail strip occupying 1-3-5 Canada Street. Refer to RPF’s reports in Appendix D for additional detail regarding HBM findings.

2. PCBs were not detected in the building materials sampled by RPF. 3. We recommend RPF’s HBM reports be provided to the contractor performing the abatement project design in advance of the start of site work.

ACM = asbestos-containing material RACM = Regulated Asbestos-Containing Material; defined as: (a) friable asbestos material; (b) Category I nonfriable ACM that has become friable; (c) Category I nonfriable ACM that will be or has been subjected to sanding, grinding, cutting or abrading; or (d) Category II nonfriable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations.

2.2.3.1 Universal Waste

Remediation of universal wastes (i.e., PCB ballast & mercury-containing fluorescent lamps) in the site buildings is considered a presumptive remedial measure as removing these items from the site building is the only alternative that will allow the successful development of the site as planned.

2.2.3.2 Recommendations

Abatement of HBMs identified at the site will be required as part of site redevelopment. Abatement specifications prepared by RPF are included in Appendix E. We recommend the HBM reports and specifications be provided to the contractor performing the abatement project design in advance of the start of site work. Abatement must be performed and documented by qualified and licensed contractors. 2.3 POTENTIAL RECEPTOR EVALUATION

Based on the findings of Phase II sampling, Sanborn Head completed an evaluation to identify potential sensitive receptors located at or proximate to the site that may be impacted by the presence of petroleum or hazardous substances at the site. Please note that this is a preliminary screening, and not a quantitative risk assessment in accordance with U.S. Environmental Protection Agency (USEPA) guidance.


Under the current site configuration, potentially sensitive receptors at the site include: children/teens visiting the Swanton Teen Center, and potentially, workers inside the Memorial and Warehouse Buildings. Under the planned redevelopment scenario, we understand the site use would include: new construction for commercial (retail) purposes, and potential receptors would be construction workers during site redevelopment, and following redevelopment, potential receptors would be on-site workers and customers, with generally low likelihood of direct contact with petroleum or hazardous materials during the course of normal daily activities. An evaluation of potential receptors is summarized on Table 5. 3.0 PERFORMANCE STANDARDS - CLEANUP GOALS AND APPLICABLE

GUIDELINES The goal relative to the identified site contamination is to eliminate or manage the risks to human health and the environment through proper abatement, management, mitigation, and/or disposal of identified contaminated material consistent with planned site reuse. To achieve this objective, the following cleanup goals and guidelines will be applicable to the cleanup.

Exhibit 4. Summary of Performance Standards Media Standards/Screening Levels Values

Soil EPA Regional Soil Screening Levels – Industrial Soil

Refer to Table 2 for a comparison of screening levels relative to individual compounds detected in site soil.

Ground-water

VT DEC Primary Groundwater Enforcement Standards (which incorporate EPA Maximum Contaminant Levels [MCLs]) and Preventative Action Levels

Refer to Table 3 for a comparison of standards relative to individual compounds detected in site groundwater.

Soil Gas • VT DEC Air Screening Levels – Industrial Air

• EPA Regional Air Screening Levels – Industrial Air

Refer to Table 4 for a comparison of screening levels relative to individual compounds detected in site soil gas.

HBMs Asbestos: Vermont Regulations for Asbestos Control (V.S.A. Title 18, Chapter 26 Effective February 1987; Amended November 1995). Construction work involving exposure or potential exposure to ACM is regulated by OSHA 29 CFR 1910.1001.

ACM is defined as material that contains any type of asbestos in an amount greater than 1% by weight or area either alone or mixed with other fibrous or non-fibrous materials. Cleanup goals will be that any ACM to be impacted by renovation or demolition activities be properly removed prior to these activities, and that post renovation conditions in the site building are safe for re-occupancy consistent with V.S.A. Title 18, Chapter 26. All asbestos removal, handling and oversight will be conducted by appropriately trained and certified personnel. Confirmatory air sampling will be conducted by third party Vermont-certified asbestos air monitor.


Media Standards/Screening Levels Values Lead-based paint: Construction work involving exposure or potential exposure to any concentration of lead is regulated by OSHA’s Lead in Construction Standard 29 CFR 1926.62.

Cleanup goals will be that LBP is removed and properly disposed. Demolition Disposal shall include evaluation of LBP as potentially characteristically hazardous waste (40 CFR 261.24 - Toxicity characteristic). A lead screening level for demolition debris of 5 milligrams per liter (mg/L; evaluation as potentially characteristically hazardous waste) by Toxicity Characteristic Leaching Procedure (TCLP) analysis shall be used.

4.0 EVALUATION OF CORRECTIVE ACTION ALTERNATIVES This section provides information pertaining to potential remedial options for the site during redevelopment. A CAP under the guidance of VT DEC requires an Evaluation of Corrective Action Alternatives as part of the process to evaluate the best suited remedial option. Based on this requirement, we have evaluated alternatives for the following media: soil, groundwater, soil gas, and HBMs. The summary of alternatives is provided below. 4.1 Remedial Action Objectives

The objectives of this proposed remediation are as follows: 1. Implement an Institutional Control (e.g., land use restriction) to require Notice within

the COC that requires notification to DEC if any future soil disturbance will occur in areas where soil contamination above applicable standards has been identified.

2. Implement an Institutional Control (e.g., land use restriction) to prohibit groundwater extraction.

3. Limit future site occupant health risk inside the Memorial Building/Warehouse from VI by backfilling the Memorial Building basement, installation of a vapor barrier, and capping with a new concrete floor slab.

4. Limit future building occupant health risk from HBMs by performing an HBM abatement by qualified professionals.

5. Obtain a COC with the above controls/restrictions on the property from the VTDEC Brownfields Program once all work has been performed.

4.2 Evaluation of Cleanup Alternatives

To address PAH-contaminated soils present in the 7.5-8.5 ft interval of soil in a localized portion of the property, petroleum-related VOC impacts to groundwater across the site, chlorinated VOC impacts to soil vapor beneath the Memorial Building/Warehouse, and HBMs detected in site structures, four different remedial alternative groups were considered including:


Exhibit 5. Summary of Cleanup Alternatives

Media Alternative

Soil

1a No Action

1b

On-site soil reuse/Notice within the COC that requires notification to DEC if any future soil disturbance will occur in areas where contamination has been identified

1c Targeted Soil Excavation with Off-Site Soil Disposal

Groundwater 2a No Action 2b Deed Restriction to prohibit groundwater extraction

Soil Vapor

3a No Action.

3b Deed Restriction or zoning change for Memorial Building to preclude residential use.

3c Memorial Building Basement Filling and Sealing

HBMs 4a No Action 4b Abatement of HBMs

To satisfy VT DEC requirements in the I-Rule, the following criteria were considered prior to selecting a recommended cleanup alternative: compliance with legal requirements, overall protection of human health and the environment, long-term effectiveness and permanence, reducing toxicity, mobility, or volume through treatment, short-term effectiveness, implementability, cost, environmental impact and sustainability4, and community acceptance of each alternative. Table 6 contains a summary of the evaluation of the I-Rule criteria. 4.3 Justification for the Selected Remedial Alternative

Based on the evaluation of the remedial alternatives presented in Table 6, the “no action” alternatives were not considered to be protective of human health and the environment. Therefore, the no action alternatives were not selected. The selected alternatives are indicated below:

4 The evaluation of remedies included goals listed the EPA Region 1 Green Remediation Policy1 including:

Minimize total energy use and maximize use of renewable energy; Minimize air emissions and greenhouse gas generation; Minimize water use and impacts to water resources; Reduce, reuse, and recycle materials and wastes; and Protect and minimize adverse impacts to land and ecosystems.


Exhibit 6. Summary of Selected Alternatives

Media Selected Alternative Comments

Soil 1b

On-site soil reuse/Notice within the COC that requires notification to DEC if any future soil disturbance will occur in areas where contamination has been identified.

Alternative #1b is the most viable option for soil, is as effective, has lower cost, and is more sustainable than Alternative 1c.

Groundwater 2b Deed Restriction to prohibit groundwater extraction

Alternative 2b is “green”, effective and reliable, and provides greater protection of human health and the environment than Alternative 2a.

Soil Vapor 3c Memorial Building Basement Filling and Sealing

Alternative 3c is effective and reliable and can be integrated into site redevelopment, and provides greater protection of human health and the environment than Alternative 3a.

HBMs 4b Abatement of HBMs

Alternative 4b is effective and reliable and can be integrated into site redevelopment, and provides greater protection of human health and the environment than Alternative 4a.

5.0 CORRECTIVE ACTION PLAN We conclude that Alternatives #1b, 2b, 3c, and 4b are the most viable options for remediation at the site. This section describes the recommended design elements of the selected remedial alternatives. 5.1 Redevelopment Plan

The site owner intends to redevelop a portion of the Memorial Building/Warehouse Building into a mixed retail and commercial building, remove the Prouty Building (1 Canada Street), renovate the Theatre Building (3 Canada Street) and the connector building (5 Canada Street) along Canada Street, and relocate or remove the Swanton Chamber of Commerce building (34 Merchants Row). Appendix A contains the site redevelopment plan. 5.2 Basis of Design and Materials Construction

Only Alternative 3c includes an engineered control (vapor barrier liner in Memorial Building). Engineered barriers are the design basis by which the potential for human inhalation of CVOCs from soil gas (VI pathway) beneath the Memorial Building will be mitigated. The proposed vapor barrier liner to be used is a 20-mil Stego® (polyolefin resin) Wrap Vapor Barrier5. Stego Wrap product information and installation instructions are included as Appendix F.

5 https://www.stegoindustries.com/products/vapor-barrier-20-mil

https://www.stegoindustries.com/products/vapor-barrier-20-mil


As part of building renovation, the basement of the Memorial Building will be filled with sand and gravel, a vapor barrier liner will be placed/sealed on top of the sand/gravel, and a new concrete floor slab poured on top of the vapor barrier and made flush with surrounding grade. We understand the site owner’s contractor will install concrete plugs in the floor drains in the Memorial Building. We understand subslab venting will not be required by VT DEC to allow unrestricted use of the Memorial Building. The subslab soil gas sampling points in the Memorial Building and Warehouse Building will also be filled with concrete flush with surrounding grade. The exterior soil gas sampling points will be decommissioned by removing the tubing and the roadbox at each location. 5.3 Best Management Practices for Green and Sustainable Remediation

In accordance with ASTM E2893-16e1, Standard Guide for Greener Cleanups, the proposed best management practices (BMPs) for remedial activities have been selected to address the core elements of energy consumption, air quality, water quality, materials and waste, and land and ecosystems. The proposed BMPs specific to site remedial actions include: 1. If off-site disposal is required, use of contaminated soils as alternative daily cover at the

disposal facility.

2. Implementation of an idling management plan for trucks and excavators.

3. Use of local staff (including subcontractors) when possible to minimize resource consumption.

4. Establishment of green requirements (for example, BMPs) as evaluation criteria in the selection of contractors and include language in RFPs, RFQs, subcontracts, contracts, etc.

5. Implementation of erosion control measures in accordance with the Vermont Low Risk Site Handbook for Erosion Prevention and Sediment Control.

6. Use of phosphate free detergents or biodegradable cleaning products instead of organic solvents or acids to decontaminate sampling equipment.

5.4 Waste Management Plan

Identified universal and HBM wastes in the site buildings will be removed and properly disposed by qualified personnel in accordance with 310 CMR 30.00 – Hazardous Waste Management Regulations, including Section 30.1000 – Standards for Universal Waste Management. Documentation of HBM disposal will be provided to VT DEC in a remedial action report. 5.5 Health and Safety

Due to the presence of contaminated media at the site, all construction activities should be performed using appropriate health and safety precautions. Contractors performing intrusive activities, where a risk of exposure to contaminated soil is present, will be required


to do so under the supervision of a qualified environmental professional (QEP). A QEP will also provide oversight of the installation of the engineered barrier in the Memorial Building. Contractors are expected to work under their own Health and Safety Plans prepared pursuant to the OSHA HAZWOPER regulations (29 CFR 1910.120). A Health and Safety Plan for completion of the remedial activities will be provided by the contractor prior to start of construction. 5.6 Permitting

Proper notification of asbestos abatement projects to the Vermont Department of Health will be required for abatement of ACM. Notification to VT DEC should be made regarding the soil excavation activities and placement of the vapor barrier liner in the Memorial Building. We understand the site owner has/will have obtained necessary permits to support site redevelopment. No other permits are anticipated to be required as a part of this remediation project. 5.7 Reporting

Following the completion of the remedial activities, a remediation completion report will be prepared and submitted to VT DEC. The completion report will include a description of site activities including dates of work and as-built construction diagrams. In the event that future site renovations or maintenance could potentially penetrate or affect the effectiveness of the engineered barrier in the Memorial Building, notification to VT DEC is required. 5.8 Schedule

Upon approval of the CAP, the proposed schedule for completion of the corrective action plan is provided below:

Exhibit 7: Proposed Schedule Task Duration Anticipated Start Date

Corrective Action Plan issued - April 25, 2018 Public Comment Period 30 days April 25, 2018 Corrective Action Plan (final following public comment)

- May 25, 2018

Bidding/Contracting by Site Owner 1 month May 2018 Prouty Building Demolition/utility re-locate 3 months June 15, 2018 Memorial Building basement fill/new pour 6 weeks October 1, 2018 Remedial Action Report by Site Owner To be determined November 15, 2018 The proposed schedule is contingent upon several factors, including approval of the CAP by the agencies and contractor availability. 5.9 Project Contractors

Contractors are being arranged by the site owner. Contractors anticipated to be used for the project include:


RMB Excavating Inc

645 Route 36 Fairfield VT 05455

802 827 3040

Andy Leduc Construction, LLC 111 Canada St

Swanton, VT 05488 802 868 2745

5.10 Opinion of Cost – Selected Alternatives

Sanborn Head has prepared an opinion of cost for the corrective actions discussed above, including installation of an engineered barrier in the Memorial Building, and subsequent remedial completion reporting to support issuance of a COC by VT DEC. The costs presented below are representative of the remedial design elements, as described within this CAP, that are necessary to mitigate exposure to site contaminants. Site civil, structural, architectural, and other components of the site’s redevelopment design are not included within these costs.

Exhibit 8. CAP Opinion of Cost Media Selected Alternative Opinion of Cost

Soil 1b

On-site soil reuse/Notice within the COC that requires notification to DEC if any future soil disturbance will occur in areas where contamination has been identified.

$1,219

Groundwater 2b Deed Restriction to prohibit groundwater extraction $1,219

Soil Vapor 3c Memorial Building Basement Filling and Sealing $133,720

HBMs 4b Abatement of HBMs $68,132

Total: $204,290

Note: A 10% contingency has been included as a recognition of likely variations in contractor bids, changes in redevelopment plans, and unforeseen circumstances.

Costs tables for recommended alternatives (1b, 2b, 3c, and 4b) are provided in Appendix G. Costs for non-recommended alternatives (1c and 3b) are also included in Appendix G. No action alternatives 1a, 2a, 3a, and 4a do not have associated costs. 7.0 INSTITUTIONAL CONTROLS – CERTIFICATE OF COMPLETION Following approval of the CAP, pursuant to the objectives of the BRELLA program, the site owner will proceed with remedial activities. Following completion of remedial actions and documentation in a remediation completion report, we understand the site owner will request a COC for the site from the VT ANR Secretary. The COC to be emplaced on the site property deed under the BRELLA program shall serve as the institutional control.


8.0 ADDITIONAL CONSIDERATIONS Although not directly related to corrective actions, we offer the following information for the site owner’s consideration based on Phase II ESA findings: Although no release of polychlorinated biphenyls (PCBs) to soil from the transformer

was identified as part of Phase II ESA sampling, we understand the electrical transformer located on the northeastern corner of the Memorial Lot parcel is owned by Swanton Village Electric. Therefore, we recommend the site owner consider pursuing a lot line adjustment that would allow the transformer to remain on property owned by Swanton Village.

The site owner should coordinate with VTDEC and the parties conducting the monitoring of the Former E.J. Barrette Ford site (SMS #1989-0420) to establish an access agreement and maintain monitoring wells located on the 1-3-5 Canada Street and Municipal Lot properties to facilitate monitoring of the Former E.J. Barrette Ford site.

9.0 REFERENCES Federal Emergency Management Agency. 1983. Flood Insurance Rate Map, Village of Swanton, Vermont. Community-Panel Number 5000600001B. Effective date March 16, 1983. Ratcliffe, N.M., Stanley, R.S., Gale, M.H., Thompson, P.J., and Walsh, G.J., 2011, Bedrock Geologic Map of Vermont, U.S. Geological Survey Scientific Investigations Map 3184, 3 sheets, scale 1:100,000. Sanborn, Head & Associates, Inc. 2016. Phase I Environmental Site Assessment Municipal Lot at Merchants Row and 1-3-5 Canada Street. Dated September 20, 2016. Sanborn, Head & Associates, Inc. 2017a. Phase II Environmental Site Assessment Municipal Lot at Merchants Row and 1-3-5 Canada Street. Dated February 23, 2017. Sanborn, Head & Associates, Inc. 2017b. Supplemental Phase II Environmental Site Assessment Municipal Lot at Merchants Row and 1-3-5 Canada Street. Dated August 29, 2017. Sanborn, Head & Associates, Inc. 2017c. Draft Additional Soil Gas Phase II Environmental Site Assessment Municipal Lot at Merchants Row and 1-3-5 Canada Street. Dated November 10, 2017. Sanborn, Head & Associates, Inc. 2018. Draft 7 Merchants Row Soil Gas Phase II Environmental Site Assessment. Dated March 21, 2018. USEPA. 2012. Clean and Greener Policy for Contaminated Sites, USEPA Region 1 Office of Site Remediation and Restoration, Revised February 2012.


USEPA. 2016. Consideration of Greener Cleanup Activities in the Superfund Cleanup Process. Memorandum to Regional Superfund National Program Managers, Regions 1-10; Regional Counsels, Regions 1-10. August 2, 2016. Vermont Agency of Natural Resources. 2018. http://anr.vermont.gov/maps/biofinder/. Accessed March 16, 2018. Vermont Agency of Natural Resources. 2018. https://anrmaps.vermont.gov/websites/ANRA5/default.html. Accessed March 16, 2018. Vermont Department of Environmental Conservation. 2017. "Investigation and Remediation of Contaminated Properties Rule" ("I Rule"), effective July 27, 2017. http://dec.vermont.gov/sites/dec/files/wmp/Sites/07.11.2017.Adopted.Rule_.for_.SOS_.filing.pdf; downloaded on July 19, 2017. Vermont HydroGeo, LLC. 2016. Progress Report Former E.J. Barrette Ford Swanton, Vermont SMS #1989-0420. 10.0 LIMITATIONS We have prepared the Evaluation of Corrective Action Alternatives/Corrective Action Plan for the properties at 1-3-5 Canada Street (Town of Swanton Tax Map Book 194, Pages 7-9 Parcels CN001, and CN001A) and the Municipal Lot at Merchants Row (Town of Swanton Tax Map Parcel LC0003) Swanton, Vermont in conformance with the scope and limitations of the I-Rule and for the following objective: to mitigate the risk of exposure to site users through direct contact with contaminated soils, ingestion of contaminated groundwater, and potential inhalation of VOC-contaminated air via the VI pathway, such that the results of the investigation can be used by NRPC to inform potential site use and redevelopment strategies with respect to potential remediation, as warranted. Our conclusions regarding the site are based on observations of existing site conditions, our interpretation of available site history and site usage information. In preparing this ECAA/CAP, Sanborn Head has endeavored to conform with generally accepted practices of other consultants undertaking similar studies at the same time and in the same geographical area. Sanborn Head has attempted to observe a degree of care and skill generally exercised by the technical community under similar circumstances and conditions. Sanborn Head’s findings and conclusions must be considered probabilities based on professional judgment, rather than certainties, concerning the significance of the limited information gathered during the Phase I/Phase II ESA and Corrective Action Planning activities.


11.0 PROFESSIONAL ENGINEER’S REVIEW The signatures of the environmental professionals contributing to this ECAA/CAP are provided below. I certify under penalty of perjury that I am an environmental professional and that all content contained within this deliverable is to the best of my knowledge true and correct.

Timothy M. White, P.G. Senior Project Manager

Charles A. Crocetti, Ph.D., P.G. Senior Vice President and Principal

Brian J. Beaudoin, P.E. Vice President and Senior Associate

P:\4000s\4091.00\Source Files\CAP\20180425_Swanton_ECAA-CAP.docx

TABLES

TABLE1SummaryofGroundwaterElevations

1,3,5CanadaStreetandMunicipalLotatMerchantsRowCorrectiveActionPlanSwanton,VermontSMSSite#2016‐4658

DepthsandelevationsinfeetReferenceElevations May24&25,2017

TPVC WellCapDepthtoWater

ReferencePoint

GroundwaterElevation

SH‐2W 142.88 143.04 9.03 TPVC 133.85SH‐3W 141.34 141.54 10.38 TPVC 130.96SH‐4W 142.18 142.48 10.44 TPVC 131.74SH‐5W 140.27 140.50 10.30 TPVC 129.97SH‐6W 139.85 139.94 10.66 TPVC 129.19MW‐103 142.13 142.40 8.65 TPVC 133.48MW‐104 140.85 141.01 8.13 TPVC 132.72MW‐106 140.03 140.22 8.30 TPVC 131.73MW‐107 139.48 139.63 9.97 TPVC 129.51MW‐108 140.53 140.70 8.88 TPVC 131.65MW‐109 142.08 142.26 7.72 TPVC 134.36MW‐110 140.43 140.55 8.80 TPVC 131.63MW‐111 109.24 109.38 5.84 TPVC 103.40MW‐114 107.84 107.96 4.00 TPVC 103.84MW‐116 142.10 142.34 6.67 TPVC 135.43MW‐117 142.48 142.70 8.25 TPVC 134.23MW‐118 142.38 142.57 8.18 TPVC 134.20MW‐120 142.21 142.39 7.96 TPVC 134.25MW‐121 141.20 141.39 8.08 TPVC 133.12MW‐122 141.34 141.56 8.31 TPVC 133.03MW‐123 141.14 141.29 9.30 TPVC 131.84MW‐124 141.38 141.68 9.88 TPVC 131.50

MonitoringWell

Notes:

1. Reference point and ground surface elevations were surveyed by Vermont Survey andEngineering Inc. on December 20, 2016 and May 27, 2017. The elevations shown are referenced to ahorizontal datum of NAD 83 (2011) SPC (4400 VT) and a vertical datum of NAVD 88.

2. Water level measurements for the monitoring wells were recorded by Sanborn Head on the datesindicated using an electronic water level probe and are presented in feet.

3. "TPVC" indicates top of PVC well riser."TOC" indicates top of protective casing.

4. Fluctuations in groundwater elevations may occur due to variations in temperature, rainfall,and/or other factors.

P:\4000s\4091.00\SourceFiles\CAP\409100_Tables.xlsx Page1of1 Sanborn,Head&Associates,Inc.

TABLE2SummaryofAnalyticalResults‐SoilandSediment


Concentrationsinmg/kg

SH‐2W SH‐3W SH‐4WSH‐4WDUP‐2

SH‐5W SH‐6W SS‐1 SS‐2 SS‐3SS‐3DUP‐1

UST‐East/S1 UST‐East/S2

Depth:9‐10' Depth:9‐10' Depth:9‐10' Depth:9‐10' Depth:9‐10' Depth:5‐6.5' — — — — Depth:7.5‐8.5' Depth:7.5‐8.5'

VSLResidential

USEPARSLResidential

USEPARSLIndustrial

12/12/2016 12/12/2016 12/13/2016 12/13/2016 12/13/2016 5/10/2017 12/13/2016 12/13/2016 12/13/2016 12/13/2016 5/9/2017 5/9/2017

VOCsAVOCs

Butylbenzene(sec‐) NS 7,800 120,000 7.0 <0.1 <0.1 <0.1 <0.1 <0.3 <0.1 <0.1Ethylbenzene 2.21 5.8 25 3.4 <0.1 <0.1 <0.1 <0.1 <0.3 <0.1 <0.1

Isopropylbenzene(Cumene) NS 1,900 9,900 7.7 <0.1 <0.1 <0.1 <0.1 <0.3 <0.1 <0.1Isopropyltoluene(4‐) NS NS NS 4.2 <0.1 <0.1 <0.1 <0.1 <0.3 <0.1 <0.1

Naphthalene 1.42 3.8 17 5.8J <0.2 <0.2 <0.3 <0.2 <0.6 <0.2 <0.2Propylbenzene(n‐) NS 3,800 24,000 41 <0.1 <0.1 <0.1 <0.1 <0.3 <0.1 <0.1

Trimethylbenzene(1,2,4‐) 264# 300 1,800 220 <0.1 <0.1 <0.1 <0.1 <0.3 <0.1 <0.1Trimethylbenzene(1,3,5‐) 264# 270 1,500 100 <0.1 <0.1 <0.1 <0.1 <0.3 <0.1 <0.1

TotalTrimethylbenzene 264# NS NS 320 ND ND ND ND ND ND NDXylene(m,p‐)φ NS 550 2,400 18 <0.1 <0.1 <0.1 <0.1 <0.3 <0.1 <0.1Xylene(o‐) NS 650 2,800 1.1 <0.1 <0.1 <0.1 <0.1 <0.3 <0.1 <0.1

TotalXylenes 575 580 2,500 19.1 ND ND ND ND ND ND NDTotalAVOCs NS NS NS 728.2 ND ND ND ND ND ND ND

CVOCsDichloroethene(cis‐1,2‐) 146 160 2,300 <0.9 <0.1 <0.1 <0.1 <0.1 <0.3 <0.1M <0.1

TotalCVOCs NS NS NS ND ND ND ND ND ND ND NDTotalVOCs NS NS NS 728.2 ND ND ND ND ND ND ND

PAHsBenzo(a)anthracene NS 1.1 21 <0.12 <0.12 <0.11 <0.11 <0.12 <0.056 0.086Benzo(a)pyrene 0.076/1.54* 0.11 2.1 <0.12 <0.12 <0.11 <0.11 <0.12 <0.056 0.083

Benzo(k)fluoranthene NS 11 210 <0.60 <0.58 <0.54 <0.56 <0.59 <0.056 0.067Chrysene NS 110 2,100 <0.60 <0.58 <0.54 <0.56 <0.59 <0.056 0.087

Dibenzo(a,h)anthracene NS 0.11 2.1 0.21 <0.12 <0.11 <0.11 <0.12 <0.056 <0.055Fluoranthene NS 2,400 30,000 <0.60 <0.58 <0.54 <0.56 <0.59 <0.056 0.18

Indeno(1,2,3‐cd)pyrene NS 1.1 21 0.15 <0.12 <0.11 <0.11 <0.12 <0.056 <0.055Methylnaphthalene(2‐) NS 240 3,000 39 <0.58 <0.54 <0.56 <0.59 <0.056 <0.055

Naphthalene 1.42 3.8 17 14 <0.58 <0.54 <0.56 <0.59 <0.056 <0.055Phenanthrene NS NS NS <0.60 <0.58 <0.54 <0.56 <0.59 <0.056 0.20

Pyrene NS 1,800 23,000 <0.60 <0.58 <0.54 <0.56 <0.59 <0.056 0.18TotalPAHs NS NS NS 53.36 ND ND ND ND ND 0.883

Benzo(a)pyreneTEQ‡ 0.076/1.54* 0.11 2.1 0.23‡ ND ND ND ND ND 0.099‡TPH

TPHC10‐36 ¥ ¥ ¥ 3,000 <120 <110 <110 7,600 150B <100

FingerprintResembles

predominantlygasoline

— — —

Resemblesamixtureoflubricating/motor

oilandlesserweatheredNo.2fuel

oil/diesel

Concentrationistoolowforvalidindentification

PCBsTotalPCBs NS NS NS ND ND ND ND

Analyte VermontSSVs




VSLResidential

USEPARSLResidential

USEPARSLIndustrial

VOCsAVOCs

Butylbenzene(sec‐) NS 7,800 120,000Ethylbenzene 2.21 5.8 25

Isopropylbenzene(Cumene) NS 1,900 9,900Isopropyltoluene(4‐) NS NS NS

Naphthalene 1.42 3.8 17Propylbenzene(n‐) NS 3,800 24,000

Trimethylbenzene(1,2,4‐) 264# 300 1,800Trimethylbenzene(1,3,5‐) 264# 270 1,500

TotalTrimethylbenzene 264# NS NSXylene(m,p‐)φ NS 550 2,400Xylene(o‐) NS 650 2,800

TotalXylenes 575 580 2,500TotalAVOCs NS NS NS

CVOCsDichloroethene(cis‐1,2‐) 146 160 2,300

TotalCVOCs NS NS NSTotalVOCs NS NS NS

PAHsBenzo(a)anthracene NS 1.1 21Benzo(a)pyrene 0.076/1.54* 0.11 2.1

Benzo(k)fluoranthene NS 11 210Chrysene NS 110 2,100

Dibenzo(a,h)anthracene NS 0.11 2.1Fluoranthene NS 2,400 30,000

Indeno(1,2,3‐cd)pyrene NS 1.1 21Methylnaphthalene(2‐) NS 240 3,000

Naphthalene 1.42 3.8 17Phenanthrene NS NS NS

Pyrene NS 1,800 23,000TotalPAHs NS NS NS

Benzo(a)pyreneTEQ‡ 0.076/1.54* 0.11 2.1TPH

TPHC10‐36 ¥ ¥ ¥

Fingerprint

PCBsTotalPCBs NS NS NS

Analyte VermontSSVs

Concentrationsinmg/kg Concentrationsinµg/L

UST‐West/S1UST‐West/S1

DUP‐1UST‐West/S2 SB‐1 SB‐2 SED‐1 TB‐101 TB‐202 EB‐1 TB‐1

Depth:6.9‐7.9' Depth:6.9‐7.9' Depth:6.9‐7.9' Depth:1‐2' Depth:1‐2' Depth:0‐0.1' ― ― ― ―

5/10/2017 5/10/2017 5/10/2017 5/24/2017 5/24/2017 5/24/2017 5/9/2017 5/22/2017 5/10/2017 5/9/2017

<0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <2 <2<0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <2 <2<0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <2 <2<0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <2 <2<0.3 <0.3 <0.2 <0.1 <0.1 <0.1 <0.2 <0.1 <5 <5<0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <2 <2<0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <2 <2<0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <2 <2ND ND ND ND ND ND ND ND ND ND<0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <2 <2<0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <2 <2ND ND ND ND ND ND ND ND ND NDND ND ND ND ND ND ND ND ND ND

<0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 0.1B <2 <2ND ND ND ND ND ND ND 0.1 ND NDND ND ND ND ND ND ND 0.1 ND ND

<0.053 <0.052 <0.053 <0.5<0.053 <0.052 <0.053 <0.2<0.053 <0.052 <0.053 <0.5<0.053 <0.052 <0.053 <0.5<0.053 <0.052 <0.053 <0.5<0.053 <0.052 0.061 <0.5<0.053 <0.052 <0.053 <0.5<0.053 <0.052 <0.053 <0.5<0.053 <0.052 <0.053 <0.5<0.053 <0.052 <0.053 <0.5<0.053 <0.052 0.063 <0.5ND ND 0.124 NDND ND ND ND

<110 <110 <110 150B

Concentrationistoolowforvalidindentification




Notes:1. Soil samples were collected by Sanborn Head personnel on the dates and at the depths indicated and submitted to AbsoluteResource Associates (ARA) of Portsmouth, New Hampshire for analysis for volatile organic compounds (VOCs) using USEPAMethod 8260C, polycyclic aromatic hydrocarbons (PAHs) using USEPA Method 8270C, total petroleum hydrocarbons (TPH)using USEPA Method 8100 (mod), and PCBs using USEPA Method 8082Awith Soxhlet extraction.

2."FormerVermontSSVs"indicatesVermontSoilScreeningValuesreferredtoin"InvestigationandRemediationofContaminatedPropertiesProcedure"(IROCP)(April2012withDecember2013update).AsdirectedintheIROCP,current"USEPARSLResidential"and"USEPARSLIndustrial"valuesareUSEPARegionalScreeningLevels(RSLs)(https://www.epa.gov/risk/regional‐screening‐levels‐rsls‐generic‐tables‐november‐2017,November2017,HI=1.0).

"VSL Residential" values were obtained from Appendix A.1 of the "Investigation and Remediation of Contaminated PropertiesRule" ("I Rule"), effective July 27, 2017.http://dec.vermont.gov/sites/dec/files/wmp/Sites/07.11.2017.Adopted.Rule_.for_.SOS_.filing.pdf; downloaded on July 19,2017.

3."AVOCs"indicatesaromaticVOCs.Total(e.g.,TotalAVOCs)indicatesthesumofthedetectedconcentrationsoftherelevantanalytes.

4. Only those analytes detected in one or more samples are shown. Refer to the analytical laboratory reports for the full list ofanalytes.

5. "NS" indicates no value is listed in the source document for this analyte."†" indicates the standards shown are for total xylenes. The sum of detected concentrations (i.e., non‐detects assumed as

zero) is compared to the standards."¥" The Residential/Industrial TPH RSLs are segregated by molecular weight as well as aliphatic and aromatic compounds."£" indicates the standards shown are for total PCBs. The sum of detected concentrations (i.e., non‐detects assumed as

zero) is compared to the standards."‡" refer to the text and the Data Quality Assessment (Appendix D) for additional information on the benzo(a)pyrene

toxicity equivalence quotient (TEQ)."φ" indicates the Proposed Vermont SSVs are for m‐xylene. The USEPA Residential RSL for p‐xylene is 560 mg/kg."*" contains residential and industrial B(a)P soil screening values."#" indicates the standard shown is for the combined isomers of 1,2,4‐trimethylbenzene and 1,3,5‐trimethylbenzene. The

sum of detected concentrations (i.e., non‐detects assumed as zero) is compared to the standard.

6. "<" indicates the analyte was not detected above the indicated laboratory reporting limit."ND"indicates theanalytewasnotdetectedabovethelaboratoryreportinglimit.Ablankcellindicatesthesamplewasnotanalyzedforthisparameter."J"indicatesestimatedvalues.SeeDataQualityAssessment(AppendixEoftheFebruary2017PhaseIIESAReport)for

additionaldetails."B"indicatesalowlevelofthisanalytewasdetectedinthemethodblank(AppendixDoftheSupplementalPhaseIIESA

ReportforMay2017results)."M"indicatestheMS/MSDshowedrecoveriesbelowtheacceptancecriteria(AppendixDoftheSupplementalPhaseIIESA

ReportforMay2017results).Bold indicates the detected concentration exceeds the Residential USEPA RSL.Italics indicate the detected concentration exceeds the VSL.No detected concentrations exceed the Industrial Screening Value.


TABLE3SummaryofAnalyticalResults‐Groundwater


Concentrationsinµg/L

PAL ES Residential Industrial 12/21/2016 5/25/2017 5/25/2017 12/21/2016 12/21/2016 12/21/2016 12/20/2016 12/20/2016 12/20/2016 12/21/2016 12/21/2016 12/21/2016 5/25/2017 5/25/2017 5/25/2017 5/25/2017 5/25/2017VOCsAVOCs

Butylbenzene(sec‐) NS NS NS NS <20 <10 <2 <2 <10 <10 <10 <10 4 <2 <2 <2 <2Ethylbenzene 350 700 6.3 28 1,000 970 <2 <2 590M 600 1,100 840 2 6 6 <2 <2

Isopropylbenzene(Cumene) NS NS 1,900 7,800 68 39 <2 <2 39 38 52 47 16 <2 <2 <2 <2Isopropyltoluene(p‐) NS NS NS NS <20 <10 <2 <2 <10 <10 <10 <10 2 <2 <2 <2 <2

Naphthalene 10 20 3.5 28 340 240J <5 <5 220J 240J 190J 140J 30J 40 50 <5 <5Propylbenzene(n‐) NS NS 4,700 20,000 200 100 <2 <2 110M 110 120 120 38 4 4 <2 <2

Toluene 500 1,000 33,000 14,000 540 230 <2 <2 360M 360 440 170 <2 <2 <2 <2 <2Trimethylbenzene(1,2,4‐) 175¥ 350¥ 57 240 1,400 1,000 <2 <2 960M 970 900 940 380 47 51 <2 <2Trimethylbenzene(1,3,5‐) 175¥ 350¥ NS NS 370 210 <2 <2 240M 240 200 220 23 <2 <2 <2 <2

TotalTrimethylbenzene 175¥ 350¥ NS NS 1,770 1,210 ND ND 1,200 1,210 1,100 1,160 403 ND ND ND NDXylene(m,p‐) NS NS NS NS 3,100 410 <2 <2 1,700M 1,700 3,100 1,800 13 <2 <2 <2 <2Xylene(o‐) NS NS NS NS 1,300 24 <2 <2 800M 790 1,300 710 5 <2 <2 <2 <2

TotalXylenes 5,000‡ 10,000‡ 700 2,900 4,400 434 ND ND 2,500 2,490 4,400 2,510 18 ND ND ND NDTotalAVOCs NS NS NS NS 8,318 3,223 ND ND 5,019 5,048 7,402 4,987 513 97 111 ND NDTotalVOCs NS NS NS NS 8,318 3,223 ND ND 5,019 5,048 7,402 4,987 513 97 111 ND ND

PAHsAcenaphthene NS NS NS NS <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 0.9 0.7 <0.5Fluorene 140 280 NS NS <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 1.0 0.7 <0.5

Methylnaphthalene(2‐) NS NS NS NS 13 <0.5 95M 81 39 21 9.9 14 5.2 <0.5Naphthalene 10 20 3.5 28 120 <0.5 180M 180 160 95 12 14 9 <0.5

TotalPAHs NS NS NS NS 133 ND 275 261 199 116 21.9 29.9 15.6 NDTPH

TPHC10‐36 NS NS NS NS 3,000 150B 3,800 3,400 3,000 2,000 2,400 370B 370B 170B

Fingerprint NS NS NS NSResembles

predominantlygasoline

Resemblespredominantly

gasoline


gasoline


gasoline


gasoline

Resemblesamixtureofgasolineandalubricating/

motoroil


gasoline


gasoline

Concentrationistoolowfor

valididentification

MetalsLead 1.5 15 NS NS 44 <5 <5 <5 <5 <5

TB‐2 EB‐2 EB‐3SH‐6WSH‐6WDUP2

SH‐5WMW‐104 MW‐108 MW‐117MW‐117DUP‐2

MW‐123MW‐104MW‐104DUP‐3Analyte SH‐2W

SH‐2WDUP‐1

SH‐3W SH‐4WVTDECVI

ScreeningValues

VermontPrimaryGroundwater

(2016)

Notes:

1. Groundwater samples were collected by Sanborn Head personnel and submitted to Absolute Resource Associates (ARA) of Portsmouth, New Hampshire for analysis for volatile organic compounds (VOCs) using USEPA Method 8260C, polycyclic aromatic hydrocarbons (PAHs) using USEPA Method 8270C, total petroleum hydrocarbons (TPH) using USEPA Method 8100 (mod), and lead using USEPAMethod 6020A.

2. "Vermont Primary Groundwater "PAL" and "ES" Standards are Primary Groundwater Standards from the State of Vermont Agency of Natural Resources Department of Environmental Conservation "Chapter 12 of the Environmental Protection Rules: Groundwater Protection Rule and Strategy" (December 16, 2016), including the March 04, 2016 Interim Groundwater Quality Standards. "ES" isEnforcement Standard; "PAL" is Preventive Action Level.

"VTDECVIScreeningValues"wereobtainedfromAppendixA.2ofthe"InvestigationandRemediationofContaminatedPropertiesRule"("IRule"),effectiveJuly27,2017.http://dec.vermont.gov/sites/dec/files/wmp/Sites/07.11.2017.Adopted.Rule_.for_.SOS_.filing.pdf;downloadedonJuly19,2017.Thesescreeningvaluesarepresentedonthistableforinformationalpurposesonly;the vaporintrusionpathwaywasevaluatedusingsoilgassampling.Refertothetextfordiscussion.

3. "AVOCs" are aromatic VOCs.Total (e.g., Total AVOCs) indicates the sum of the detected concentrations of the relevant analytes.

4. Only those analytes detected in one or more samples are shown. Refer to the analytical laboratory reports for the full list of analytes.

5. "NS" indicates no value is listed in the source document for this analyte."‡" indicates the standard shown is for xylenes (no isomer specified). The sum of detected concentrations (i.e., non‐detects assumed as zero) is compared to the standard."¥" indicates the standard shown is for the combined isomers of 1,2,4‐trimethylbenzene and 1,3,5‐trimethylbenzene. The sum of detected concentrations (i.e., non‐detects assumed as zero) is compared to the standard. Standards listed in the March 04, 2016 Interim Groundwater Quality Standards.

6. Ablankcellindicatesthesamplewasnotanalyzedforthisparameter."<"indicatestheanalytewasnotdetectedabovetheindicatedlaboratoryreportinglimit."J"indicatesestimatedvalues.SeeDataQualityAssessment(AppendixEoftheFebruary2017PhaseIIESAReport)foradditionaldetails."M"ThepercentrecoveryintheMS/Dwasoutsideacceptancecriteria.SeeDataQualityAssessment(AppendixEoftheFebruary2017PhaseIIESAReport)foradditionaldetails."B"indicatesthisanalytewasdetectedintheassociatedmethodblank.SeeDataQualityAssessment(AppendixEoftheFebruary2017PhaseIIESAReportforDecember2016resultsandAppendixDoftheSupplementalPhaseIIESA ReportforMay2017results)foradditionaldetails.Bold indicatesthedetectedconcentrationexceedstheVermont PreventiveActionLevel(PAL).ItalicindicatesthedetectedconcentrationexceedstheVermontEnforcementStandard(ES).


TABLE4SummaryofAnalyticalResults‐SoilGas


Concentrationsinµg/m³

— — — — — Depth:0‐0.5' Depth:0‐0.5' Depth:0‐0.5' Depth:0‐0.5' Depth:0‐0.5' Depth:0‐0.5' Depth:0‐0.5' Depth:6.5‐7.0' Depth:0‐0.5' Depth:0‐0.5'

VOCsAVOCs

Benzene 4.3 35 1.4J <0.639 <0.639 <0.639 <0.639 1.2J 0.86J <0.639 <0.639 <0.639 1.2J <0.639 2.6J 1.0J 0.96JEthylbenzene 37 160 <4.2 <0.869 <0.869 <0.869 <0.869 <5.3 <4.5 <0.869 <0.869 <0.869 <4.9 <0.869 <4.5 <4.6 <4.6

Isopropyltoluene(4‐) NS NS <1.10 <1.10 <1.10 <1.1 <1.10 <1.10 <1.10 <1.10Naphthalene 1.0 8.0 <1.05 <0.262 <0.262 <0.262 <1.05 <1.05 <0.262 <1.05

Propylbenzene(n‐) 33,000 150,000 <4.7 <0.983 <0.983 <0.983 <0.983 <6.0 <5.1 <0.983 <0.983 <0.983 <5.5 <0.983 <5.1 <5.2 <5.3Styrene 33,000 150,000 <4.1 <0.852 <0.852 <0.852 <0.852 <5.2 <4.4 <0.852 <0.852 <0.852 <4.8 <0.852 <4.4 <4.5 <4.6Toluene 170,000 730,000 0.96J <0.754 <0.754 <0.754 <0.754 2.9J 0.82J <0.754 <0.754 <0.754 2.4J <0.754 14 2.8J 4.6

Trimethylbenzene(1,2,4‐) 2,100 8,700 <4.7 <0.983 <0.983 <0.983 <0.983 1.5J <5.1 <0.983 <0.983 <0.983 <5.5 <0.983 <5.1 <5.2 <5.2Trimethylbenzene(1,3,5‐) 2,100 8,700 <4.7 <0.983 <0.983 <0.983 <0.983 <6.0 <5.1 <0.983 <0.983 <0.983 <5.5 <0.983 <5.1 <5.2 <5.3

Xylene(m,p‐) 3,300 15,000 <4.2 <1.74 <1.74 <1.74 <1.74 0.81J 0.89J <1.74 <1.74 <1.74 1.0J <1.74 1.3J 0.98J 1.1JXylene(o‐) 3,300 15,000 <4.2 <0.869 <0.869 <0.869 <0.869 <5.3 <4.5 <0.869 <0.869 <0.869 <4.9 <0.869 <4.5 <4.6 <4.6

TotalXylenes 3,300 15,000 ND ND ND ND ND 0.81 0.89 ND ND ND 1.0 ND 1.3 0.98 1.1TotalAVOCs NS NS 2.36 ND ND ND ND 6.41 2.57 ND ND ND 4.6 ND 17.9 4.78 6.66

CVOCsChloroform(Trichloromethane) 4.0 18 <4.7 <0.977 <0.977 <0.977 <0.977 <6.0 <5.1 <0.977 <0.977 <0.977 <5.5 <0.977 4.6J 27 5.1J

Chloromethane 3,100 13,000 <20UJ 1.10 0.971 1.03 1.11 <25UJ <21UJ <0.413 <0.413 <0.413 <23UJ <0.413 <21UJ <22UJ <22UJDichlorobenzene(1,4‐) 8.7 37 <5.8 <1.20 <1.20 <1.20 <1.2 1.9J <6.2 <1.20 <1.20 <1.20 <6.7 <1.20 <6.2 <6.3 <6.4

MethyleneChloride(Dichloromethane) 3,300 40,000 1.2J 4.66 <1.74 2.95 4.72 <43 <36 <1.74 <1.74 3.54 <39 1.78 1.8J 1.4J <37Tetrachloroethene(PCE) 21 170 <6.5 <1.36 <1.36 <1.36 <1.36 10J 15J 21 26.7 24.7 3.4J 5.89 <7.0 <7.1 <7.2Trichloroethane(1,1,1‐) 170,000 730,000 <5.2 <1.09 <1.09 <1.09 <1.09 <6.7 <5.7 <1.09 <1.09 <1.09 <6.1 <1.09 <5.6 <5.7 <5.8Trichloroethene(TCE) 6.7 23 <5.2 <1.07 <1.07 <1.07 <1.07 <6.6 <5.6 <1.07 <1.07 <1.07 <6.0 <1.07 <5.6 <5.6 0.98J

TotalCVOCs NS NS 1.2 5.76 0.971 3.98 5.83 11.9 15 21 26.7 28.24 3.4 7.67 6.4 28.4 6.08OtherVOCs

Acetone 1,100,000 4,700,000 6.2J 11.2 6.32 4.28 5.08 25J 30 <2.38 <2.38 <2.38 18J 6.10 44 25 41Bromodichloromethane 2.5 11 <6.4 <0.134 <0.134 <1.34 <1.34 <8.2 <7.0 <0.134 <0.134 <0.134 <7.5 <0.134 <6.9 <7.0 <7.2

Butadiene(1,3‐) 3.1 14 <2.1 <0.044 <0.044 <0.442 <0.442 <2.7 <2.3 <0.044 <0.044 <0.044 <2.5 <0.044 <2.3 <2.3 <2.4Butanone(2‐)(MEK) 170,000 730,000 <11 <1.47 <1.47 <1.47 <1.47 <14 3.8J <1.47 <1.47 <1.47 3.4J 2.25 <12 2.1J 3.9JCarbonDisulfide 24,000 100,000 0.47J <0.623 <0.623 <0.623 <0.623 0.77J 0.73J <0.623 <0.623 <0.623 1.0J <0.623 0.64J 0.60J 0.80JCyclohexane 210,000 870,000 <3.3 <0.688 <0.688 <0.688 <0.688 <4.2 <3.6 <0.688 <0.688 <0.688 <3.8 <0.688 1.5J <3.6 <3.7

Dichlorodifluoromethane(Freon12) 3,300 15,000 2.7J 1.56 1.81 1.60 1.22 2.9J 3.0J 1.4 1.53 1.54 3.1J 1.46 2.8J 2.6J 2.8JEthanol NS NS <7.2 <9.42 <9.42 <9.42 <9.42 <9.3 <7.8 <9.42 <9.42 <9.42 7.8J <9.42 11 <7.9 4.5J

Ethyltoluene(4‐) NS NS <4.7 <0.983 <0.983 <0.983 <0.983 <6.0 <5.1 <0.983 <0.983 <0.983 <5.5 <0.983 <5.1 <5.2 <5.3Heptane 14,000 60,000 <3.9 <0.820 <0.820 <0.82 <5.0 <4.3 <0.82 0.82J 3.1J 1.1J 0.89JHexane 24,000 100,000 <3.4 <0.705 <0.705 <0.705 <0.705 <4.3 <3.7 <0.705 <0.705 0.775 <3.9 <0.705 4.1 <3.7 <3.8

Hexanone(2‐) 1,000 4,300 <16 <0.820 <0.820 <0.820 <0.82 <20 <17 <0.820 <0.820 <0.820 <18 <0.820 <17 <17 <18Isopropanol 7,000 29,000 <9.4 <1.23 <1.23 <1.23 <1.23 <12 <10 <1.23 <1.23 <1.23 <11 <1.23 <10 <10 <10

Methyl‐2‐pentanone(4‐)(MIBK) 100,000 430,000 <3.9 <2.05 <2.05 <2.05 <2.05 <5.0 <4.3 <2.05 <2.05 <2.05 <4.6 <2.05 <4.2 0.99J 2.3JPropene 100,000 430,000 <0.861 <0.861 <0.861 <0.861 <0.861 <0.861 <0.861 <0.861

Tetrahydrofuran 70,000 290,000 <2.8 <1.47 <1.47 <1.47 <1.47 <3.6 <3.1 <1.47 <1.47 <1.47 <3.3 <1.47 <3.0 <3.1 <3.2Trichlorofluoromethane(Freon11) NS NS 1.5J <1.12 1.17 <1.12 1.13 1.3J 1.5J 1.23 1.36 1.53 2.2J 2.11 <5.8 1.4J 1.2J

Trimethylpentane(2,2,4‐) NS NS <4.5 <0.934 <0.934 <0.934 <0.934 9.9 <4.8 <0.934 <0.934 <0.934 1.3J <0.934 11 2.0J 2.1JVinylAcetate 7,000 29,000 <3.52 <3.52 <3.52 <3.52 <3.52 <3.52 <3.52 <3.52

TotalOtherVOCs NS NS 10.87 12.76 9.30 5.88 7.43 39.87 39.03 2.63 2.89 3.85 37.62 11.92 78.14 35.79 59.49TotalVOCs NS NS 14.43 18.52 10.271 9.86 13.26 58.18 56.60 23.63 29.59 32.09 45.62 19.59 102.44 68.97 72.23

9/21/201712/20/2016 5/24/2017 5/24/2017 12/20/2016 5/24/2017 12/20/2016 12/20/2016 12/20/2016IndustrialSub‐slabSoilGas

Analyte

VTDECVIScreeningValues

ResidentialSub‐slabSoil

Gas

SG‐2 SG‐2

12/20/2016 5/24/2017 12/20/201610/17/20179/21/2017 2/20/2018

SG‐1Dup‐1 SG‐1 SG‐1Dup‐1 SG‐1AA‐1 AA‐1 AA‐1 AA‐1 SG‐1AA‐1 SG‐3 SG‐4 SG‐5




VOCsAVOCs

Benzene 4.3 35Ethylbenzene 37 160

Isopropyltoluene(4‐) NS NSNaphthalene 1.0 8.0

Propylbenzene(n‐) 33,000 150,000Styrene 33,000 150,000Toluene 170,000 730,000

Trimethylbenzene(1,2,4‐) 2,100 8,700Trimethylbenzene(1,3,5‐) 2,100 8,700

Xylene(m,p‐) 3,300 15,000Xylene(o‐) 3,300 15,000

TotalXylenes 3,300 15,000TotalAVOCs NS NS

CVOCsChloroform(Trichloromethane) 4.0 18

Chloromethane 3,100 13,000Dichlorobenzene(1,4‐) 8.7 37

MethyleneChloride(Dichloromethane) 3,300 40,000Tetrachloroethene(PCE) 21 170Trichloroethane(1,1,1‐) 170,000 730,000Trichloroethene(TCE) 6.7 23

TotalCVOCs NS NSOtherVOCs

Acetone 1,100,000 4,700,000Bromodichloromethane 2.5 11

Butadiene(1,3‐) 3.1 14Butanone(2‐)(MEK) 170,000 730,000CarbonDisulfide 24,000 100,000Cyclohexane 210,000 870,000

Dichlorodifluoromethane(Freon12) 3,300 15,000Ethanol NS NS

Ethyltoluene(4‐) NS NSHeptane 14,000 60,000Hexane 24,000 100,000

Hexanone(2‐) 1,000 4,300Isopropanol 7,000 29,000

Methyl‐2‐pentanone(4‐)(MIBK) 100,000 430,000Propene 100,000 430,000

Tetrahydrofuran 70,000 290,000Trichlorofluoromethane(Freon11) NS NS

Trimethylpentane(2,2,4‐) NS NSVinylAcetate 7,000 29,000

TotalOtherVOCs NS NSTotalVOCs NS NS

IndustrialSub‐slabSoilGas

Analyte



Gas

Concentrationsinµg/m³

Depth:6.5‐7.0' Depth:8.5‐9.0' Depth:8.5‐9.0' Depth:7.5‐8.0' Depth:8.5‐9.0' Depth:8.5‐9.0' Depth:8.5‐9.0' Depth:8.5‐9.0' Depth:8.5‐9.0' Depth:8.5‐9.0' Depth:8.5‐9.0' Depth:8.5‐9.0' Depth:4.5‐5.0' Depth:4.5‐5.0'

1.6J <0.639 <0.639 2.6J <0.639 <0.639 <0.639 <0.639 <0.639 <0.639 <0.639 <0.639 <0.639 3.45<4.6 <0.869 <0.869 4.2J <0.869 <0.869 <0.869 <0.869 <0.869 <0.869 <0.869 <0.869 <0.869 1.01

<1.10 <1.10 <1.10 <1.10 <1.10 <1.10 <1.10 <1.10 <1.10 <1.10 <1.10 1.14<0.262 <0.262 <1.05 <0.262 <1.05 <0.262 <1.05 <0.262 <0.262 <0.262 <0.262 11.5

<5.2 <0.983 <0.983 <5.2 <0.983 <0.983 <0.983 <0.983 <0.983 <0.983 <0.983 <0.983 <0.983 <0.983<4.5 <0.852 <0.852 <4.5 <0.852 <0.852 <0.852 <0.852 <0.852 <0.852 <0.852 <0.852 <0.852 1.651.9J <0.754 <0.754 31 <0.754 <0.754 1.41 <0.754 <0.754 <0.754 <0.754 <0.754 <0.754 9.31<5.2 <0.983 <0.983 <5.2 <0.983 <0.983 3.34 <0.983 <0.983 <0.983 <0.983 <0.983 <0.983 <0.983<5.2 <0.983 <0.983 <5.2 <0.983 <0.983 1.23 <0.983 <0.983 <0.983 <0.983 <0.983 <0.983 <0.983<4.6 <1.74 <1.74 11 <1.74 <1.74 3.66 <1.74 <1.74 <1.74 <1.74 <1.74 <1.74 2.95<4.6 <0.869 <0.869 4.8 <0.869 <0.869 2.32 <0.869 <0.869 <0.869 <0.869 <0.869 <0.869 <0.869ND ND ND 15.8 ND ND 5.98 ND ND ND ND ND ND 2.953.5 ND ND 53.6 ND ND 11.96 ND ND ND ND ND ND 31.01

<5.2 5.03 5.32 4.9J <0.977 <0.977 5.08 <0.977 4.81 <0.977 <0.977 <0.977 <0.977 11.3<22UJ <0.413 <0.413 <22UJ <0.413 <0.413 <0.413 <0.413 <0.413 <0.413 <0.413 <0.413 <0.413 <0.413<6.4 <1.20 <1.20 <6.3 <1.20 <1.20 <1.20 <1.20 <1.20 <1.20 <1.20 <1.20 <1.20 <1.202.6J 8.65 <1.74 2.3J <1.74 3.47 <1.74 2.04 <1.74 <1.74 <1.74 3.96 <1.74 2.37<7.2 <1.36 <1.36 <7.1 1.46 3.02 28.8 66.3 <1.36 1.69 2.37 1.60 2.91 <1.36<5.8 <1.09 <1.09 <5.7 <1.09 <1.09 1.22 2.65 <1.09 <1.09 <1.09 <1.09 <1.09 <1.09<5.7 <1.07 <1.07 <5.6 <1.07 <1.07 <1.07 <1.07 <1.07 <1.07 <1.07 <1.07 <1.07 <1.072.6 13.68 5.32 7.2 1.46 6.49 35.10 70.99 4.81 1.69 2.37 5.56 2.91 13.67

27 <2.38 <2.38 35 2.59 <2.38 <2.38 <2.38 2.54 <2.38 4.16 <2.38 2.52 119<7.1 <1.34 <1.34 <7.0 <0.134 <0.134 0.161 <0.134 <0.134 <0.134 <0.134 <0.134 <0.134 <1.34<2.3 <0.442 <0.442 <2.3 <0.044 <0.044 <0.044 <0.044 0.047 <0.044 <0.044 <0.044 <0.044 0.529<12 <1.47 <1.47 <12 <1.47 <1.47 <1.47 <1.47 <1.47 <1.47 <1.47 <1.47 <1.47 13.90.80J <0.623 <0.623 1.1J <0.623 <0.623 0.987 2.17 1.79 3.00 <0.623 <0.623 0.707 5.11<3.6 <0.688 <0.688 1.1J <0.688 <0.688 <0.688 0.764 <0.688 <0.688 <0.688 <0.688 <0.688 <0.6883.1J <0.989 <0.989 2.8J 1.43 1.10 1.05 <0.989 1.94 1.88 1.40 1.55 2.29 <0.9892.7J <9.42 <9.42 5.3J <9.42 <9.42 <9.42 <9.42 <9.42 <9.42 <9.42 <9.42 <9.42 234<5.2 <0.983 <0.983 0.93J <0.983 <0.983 <0.983 <0.983 <0.983 <0.983 <0.983 <0.983 <0.983 <0.9830.73J <0.820 <0.820 3.6J <0.820 <0.820 <0.820 <0.820 <0.820 <0.820 <0.8201.5J <0.705 <0.705 <3.7 <0.705 <0.705 <0.705 <0.705 <0.705 <0.705 <0.705 <0.705 <0.705 1.00<17 <0.820 <0.820 <17 <0.820 <0.820 <0.820 <0.820 <0.820 <0.82 <0.820 <0.820 <0.820 1.00<10 <1.23 <1.23 <10 <1.23 <1.23 <1.23 <1.23 <1.23 <1.23 <1.23 <1.23 <1.23 2.95<4.3 <2.05 <2.05 <4.3 <2.05 <2.05 <2.05 <2.05 <2.05 <2.05 <2.05 <2.05 <2.05 12.4

<0.861 <0.861 <0.861 1.27 <0.861 <0.861 1.93 <0.861 <0.861 <0.861 <0.861 6.2<3.1 <1.47 <1.47 2.2J <1.47 <1.47 <1.47 <1.47 <1.47 <1.47 <1.47 <1.47 <1.47 2.2<6.0 <1.12 <1.12 <5.9 1.54 1.33 1.43 1.36 1.64 1.68 1.42 1.59 4.10 <1.120.49J <0.934 <0.934 10 <0.934 <0.934 1.26 <0.934 <0.934 <0.934 <0.934 <0.934 <0.934 68.7

<3.52 <3.52 <3.52 <3.52 <3.52 <3.52 <3.52 <3.52 <3.52 <3.52 <3.52 5.5636.32 ND ND 62.03 5.56 3.70 4.89 4.29 9.89 6.56 6.98 3.14 9.62 472.5542.42 13.68 5.32 122.83 7.02 10.19 51.95 75.28 14.70 8.25 9.35 8.70 12.53 517.23

9/21/20179/21/201712/20/201612/20/2016

SG‐6 SG‐6 SG‐9 SG‐10 SG‐10 SG‐11 SG‐12SG‐6Dup‐1 SG‐7 SG‐8 SG‐8 SG‐9

10/17/2017

SG‐13 SG‐14

5/24/201710/17/201710/17/2017 9/21/20179/21/2017 9/21/2017 9/21/20175/24/20175/24/2017




VOCsAVOCs

Benzene 4.3 35Ethylbenzene 37 160

Isopropyltoluene(4‐) NS NSNaphthalene 1.0 8.0

Propylbenzene(n‐) 33,000 150,000Styrene 33,000 150,000Toluene 170,000 730,000

Trimethylbenzene(1,2,4‐) 2,100 8,700Trimethylbenzene(1,3,5‐) 2,100 8,700

Xylene(m,p‐) 3,300 15,000Xylene(o‐) 3,300 15,000

TotalXylenes 3,300 15,000TotalAVOCs NS NS

CVOCsChloroform(Trichloromethane) 4.0 18

Chloromethane 3,100 13,000Dichlorobenzene(1,4‐) 8.7 37

MethyleneChloride(Dichloromethane) 3,300 40,000Tetrachloroethene(PCE) 21 170Trichloroethane(1,1,1‐) 170,000 730,000Trichloroethene(TCE) 6.7 23

TotalCVOCs NS NSOtherVOCs

Acetone 1,100,000 4,700,000Bromodichloromethane 2.5 11

Butadiene(1,3‐) 3.1 14Butanone(2‐)(MEK) 170,000 730,000CarbonDisulfide 24,000 100,000Cyclohexane 210,000 870,000

Dichlorodifluoromethane(Freon12) 3,300 15,000Ethanol NS NS

Ethyltoluene(4‐) NS NSHeptane 14,000 60,000Hexane 24,000 100,000

Hexanone(2‐) 1,000 4,300Isopropanol 7,000 29,000

Methyl‐2‐pentanone(4‐)(MIBK) 100,000 430,000Propene 100,000 430,000

Tetrahydrofuran 70,000 290,000Trichlorofluoromethane(Freon11) NS NS

Trimethylpentane(2,2,4‐) NS NSVinylAcetate 7,000 29,000

TotalOtherVOCs NS NSTotalVOCs NS NS

IndustrialSub‐slabSoilGas

Analyte



Gas

Concentrationsinµg/m³7MerchantsRow

SG‐7M‐1 SG‐7M‐1Dup‐1 SG‐7M‐2Depth:8.5‐9.0' Depth:8.5‐9.0' Depth:8.5‐9.0'

<0.639 <0.639 0.8084.91 5.08 6.65<1.1 <1.1 <1.10.996 0.897 0.419<0.983 <0.983 1.11<0.852 <0.852 <0.8521.25 1.55 54.61.23 1.26 2.34<0.983 <0.983 <0.983<1.74 1.74 4.11<0.869 <0.869 1.83ND 1.74 5.948.39 10.53 71.87

5.37 5.18 1.150.442 <0.413 <0.413<1.2 <1.2 <1.2<1.74 5.38 2.25<1.36 <1.36 <1.36<1.09 <1.09 <1.09<1.07 <1.07 <1.075.81 10.56 3.40

24.9 21.2 23<1.34 <1.34 <1.340.471 0.515 <0.4426.19 4.95 3.13<0.623 <0.623 0.863<0.688 <0.688 <0.6881.55 1.58 1.78<9.42 <9.42 <9.42<0.983 <0.983 <0.983<0.82 <0.82 2.230.786 0.825 2.13<0.82 1.02 <0.826.46 6.32 <1.232.31 <2.05 <2.054.77 5.03 3.61<1.47 <1.47 <1.47<1.12 <1.12 <1.12<0.934 <0.934 2.08<3.52 <3.52 <3.5247.44 41.44 38.8261.64 62.53 114.09

2/20/2018 2/20/20182/20/2018

Notes:

1.SoilvaporsampleswerecollectedbySanbornHeadpersonnelatinteriorsub‐slablocationsSG‐1,SG‐2,SG‐4,andSG‐5andexteriorlocationsSG‐3,SG‐6,SG‐7,SG‐8,SG‐9,SG‐10,SG‐11,SG‐12,SG‐13,SG‐14,SG‐7M‐1,andSG‐7M‐2atthedepthsbelowsurfaceindicated.SamplescollectedinDecember2016were1‐literSumma®canistersamples,submittedtoEurofinsAirToxics,Inc.(EATI)ofFolsom,CaliforniaforanalysisofVolatileOrganicCompounds(VOCs)usingUSEPAMethodTO‐15.Samplescollectedafter2016were6‐literSumma®canistersamples,submittedtoAlphaAnalyticalofMansfield,MassachusettsforanalysisofVOCsusingUSEPAMethodsTO‐15andTO‐15SIM.

2."VTDECVIScreeningValues"wereobtainedfromAppendixA.2ofthe"InvestigationandRemediationofContaminatedPropertiesRule"("IRule"),effectiveJuly27,2017.http://dec.vermont.gov/sites/dec/files/wmp/Sites/07.11.2017.Adopted.Rule_.for_.SOS_.filing.pdf;downloadedonJuly19,2017.Consistentwith theIRule,ResidentialandIndustrialSub‐slabSoilGasvalueswerecalculatedbydividingtheUSEPARSLbythegenericsoilgas toindoorairattenuationfactor(0.03). TheVTDECVIScreeningValueswereupdatedusingtheUSEPA RSL indoor airvalues,datedNovember2017.

3."AVOCs"indicatesaromaticVOCs."CVOCs"indicateschlorinated VOCs.Total(e.g.,TotalAVOCs)indicatesthesumofthedetected

concentrationsoftherelevantanalytes.

4.Onlythoseanalytesdetectedinoneormoresamplesareshown.Refertotheanalytical laboratoryreportsforthefulllistofanalytes.

5."NS"indicatesnoscreeninglevelisprovidedforthisanalyte."<"indicatestheanalytewasnotdetectedabovetheindicated

laboratoryreportinglimit.Ablankcellindicatesthesamplewasnotanalyzedforthisanalyte."J"indicates estimatedvalues.SeeDataQualityAssessment

(AppendixEoftheFebruary2017PhaseIIESAReport)foradditionaldetails.

Bold indicatesthedetectedconcentrationexceedstheVTDECVaporIntrusion(VI)ResidentialSoilGasScreeningValue.

ItalicsindicatesthedetectedconcentrationexceedstheVTDECVaporIntrusion(VI)IndustrialSoilGasScreeningValue.


TABLE5SummaryofEnvironmentalContamination,EvaluationofInferredSourcesandPotentialReceptors

1,3,5CanadaStreetandMunicipalLotatMerchantsRowCorrectiveActionPlanSwanton,Vermont

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Media SoilAnalytes Benzo(a)pyrene(BaP)Exceedances1/Locations

Onelocation:‐ UST‐East/S2(northoftheMemorialBuilding)exceededtheresidentialBaPVermontResidentialToxicity

EquivalenceQuotient(TEQ)SoilScreeningValue(SSV)inthe7.5‐8.5feetbelowgroundsurface(ftbgs)interval.

SoilsamplesdidnotindicateexceedancesofUSEPA’sIndustrialSoilRegionalScreeningLevels(RSLs).InferredSource(s) InlightoftheabsenceofdetectableconcentrationsofVOCsandTPHsintheUSTsoilsamples,thepresenceoflow‐level

mid‐tohigh‐molecularweightPAHsintheUSTsoilsampleisinferredtoberelatedtothepresenceoffillsoilsassociatedwithsiteconstruction,andnotindicativeofapetroleumrelease.

TPHfingerprintingresultsdemonstratedgasoline‐relatedimpactsinsitesoilandgroundwater,withtheexceptionofSH‐5W(locateddowngradientoftheformerUST‐East)whichwascomposedofamixtureofgasolineandlubricatingoil,potentiallyindicatingalocalreleasefromthenearbyformerUST‐Eastco‐mingledwiththeexistingknowngasolinerelease.Areviewofhistoricalinformationforthesitedidnotindicategasolinestorageon‐site.TwoupgradientsitessouthofCanadaStreethavedocumentedgasolinereleases,includinginvestigationonportionsofthe1,3,5CanadaStreetandMunicipalLotproperties.

Basedongroundwaterflowdirectionrelativetothedocumentedgasolinereleases,andthegeneralabsenceofgasoline‐impactedsoilonthesubjectsite,theinferredsourceofgasoline‐relatedimpactsisunderstoodtobefromoff‐site,likelytheFormerE.J.BarretteFordsiteand/ortheFormerSwantonGulfsite.

PotentialReceptorEvaluation

CurrentSiteConfiguration

AcomparisonofsoildataatUST‐East/S2totheVTDECResidential,andIndustrialSSVswasusedforthisevaluation.Basedonthiscomparison,onlytheVTDECResidentialSSVswereexceededforbenzo(a)pyrene.

NoanalytesexceededtheVTDECIndustrialSSVs.

ThesoilsampleexceedingtheVTDECResidentialSSVsfromUST‐East/S2wascollectedfromadepthofapproximately7.5‐8.5ftbgs,andthereforeisnotanticipatedtopresentadirectcontactexposurerisktocurrentoccupants.

AnticipatedSiteRedevelopment

Basedontheplannedredevelopmentofthesiteasretailspace,theapplicablestandardsareunderstoodtobetheVTDECIndustrialSSVs.Weunderstandredevelopmentofthesiteislikelytoentailearthworktoinstallfrostwalls,etc.,andisnotanticipatedtoproceedtodepthswhereurbansoilcontaminationwasencounteredatUST‐East/S2.Ifthesoilremainsinplaceasplanned,theexceedanceoftheresidentialbenzo(a)pyreneSSVwillrequireaninstitutionalcontroltoprohibitresidentialuseofthesite,andpreparationofasoilmanagementplanforfutureexcavation.

Note:The9‐10ftbgssoilsampleatmonitoringwellSH‐2WindicatedexceedancesoftheresidentsoilRSLsforseveralpetroleum‐relatedanalytes(i.e.,ethylbenzene,naphthalene,totaltrimethylbenzenes,anddibenzo[a,h]anthracene).Thesoilimpactswerelimitedtopetroleum‐relatedanalyteswithinthegroundwatertablesmearzone(approximately9‐10ftbgs).Basedongroundwaterflowdirectionrelativetothedocumentedgasolinereleases,andthegeneralabsenceofgasoline‐impactedvadosezonesoilonthesubjectsite,theinferredsourceofgasoline‐relatedimpactsisunderstoodtobefromoff‐site,likelytheFormerE.J.BarretteFordsiteand/ortheFormerSwantonGulfsite.

1 "VermontSSVs"wereobtainedfromAppendixA.1ofthe"InvestigationandRemediationofContaminatedPropertiesRule"("IRule"),effectiveJuly27,2017.“Residential”and“Industrial”screeninglevelswereusedforcomparison.http://dec.vermont.gov/sites/dec/files/wmp/Sites/07.11.2017.Adopted.Rule_.for_.SOS_.filing.pdf;downloadedonJuly19,2017.TheUSEPARegionalScreeningLevels(RSLs)includedintheI‐RulewereupdatedtoreflecttheNovember2017values.



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Media GroundwaterAnalytes Petroleum‐relatedimpactstogroundwaterwereevidencedbythedetectionofAVOCs,TPH,andPAHsinmonitoringwellsacrossthesite,withtheexceptionoftwomonitoringwellslocatedin

thecentral/south‐centralportionofthesite(MW‐117andMW‐123).TheTPHfingerprintingroundwaterwaspredominantlygasoline,withtheexceptionofmonitoringwellSH‐5W,wheretheTPHfingerprintresembledamixtureofgasolineandalubricating/motoroil.

Exceedances2/Locations

ExceedancesofVTDECESwererecordedatsitemonitoringwells–refertoTable3andFigure4.

AnalyteswithVTGESexceedancesincluded:ethylbenzene,naphthalene,1,2,4‐trimethylbenzene,1,3,5‐trimethylbenzene.InferredSource(s) GasolineusesonthesitewerenotidentifiedaspartofthePhaseIESA,andthepossiblesourcesofgasoline‐relatedanalytesingroundwaterarethetwoupgradientsites(FormerE.J.Barrette

FordandFormerSwantonGulf)wheregasolinereleaseshavebeendocumented.Thepresenceofalubricatingoil/motoroil/lesserweatheredNo.2fueloilfingerprint(soil)andlubricating/motoroilfingerprint(groundwater)wasdetectedatSH‐5WinthePhaseIIESA.However,theobservationsandsamplingresultsfromremovalofUST‐EastwerenotconsistentwithareleasefromtheUST.ItispossiblethatthepresenceoftheNo.2fueloilfingerprintinsoilandlubricating/motoroilfingerprintingroundwateratSH‐5Wmayhavebeenfromalocalizedoverfillevent,aleakyoilline,oranolderundocumentedUSTat/nearthislocation.Soilresultsforthetwoon‐siteUSTsdidnotindicatedetectableconcentrationsofVOCsandTPH,thepresenceoflow‐levelPAHsintwooftheUSTsoilsamplesisinferredtoberelatedtothepresenceoffillsoilsassociatedwiththeUSTs,andthereforeisnotindicativeofapetroleumrelease.


CurrentSiteConfigurationandAnticipatedSiteRedevelopment

Humanhealth:Municipalwaterisavailableatthesiteandvicinity.Further,basedonareviewoftheVTAgencyofNaturalResources(ANR)NaturalResourceAtlas3andsiteobservations,therearenoprivatewells,publicwatersources,orsurfaceandgroundwatersourceprotectionareasidentifiedbetweenthesiteandtheMissisquoiRiver(thepresumeddischargelocationofsitegroundwater).Therefore,therearenoapparentcurrentoranticipatedfuturehumanreceptorsofgroundwateratthesite.

GroundwaterconcentrationsindicatedexceedancesoftheVTDECVIScreeningValuesforethylbenzene,naphthalene,1,2,4‐trimethylbenzene,andtotalxylenesforoneormorelocations.However,wheretheseanalytesweredetectedinsoilgassamplescollectedatthesite,theirconcentrationswerewellbelowtheirrespectiveVTDECVIScreeningValues.Asdiscussedbelowforsoilgas,thenaphthalenedetectionatSG‐14(locatedoffsiteadjacenttoMerchantsRow)isnotconsideredtoconstituteunacceptableriskrelatedtopotentialvaporintrusionattheMunicipalLotsite.Therefore,theredoesnotappeartobeunacceptableVIriskfromVOCsingroundwater.Ecological:Basedoninferredgroundwaterflowdirection,sitegroundwaterisassumedtodischargetotheMissisquoiRiver.PotentialsensitiveecologicalfeaturesintheareaappeartobelimitedtotheMissisquoiRiver,wheresitegroundwaterispresumedtodischarge4.Nostate‐orfederally‐listedendangeredspecieswereidentifiedproximatetothesite.TheMissisquoiRiverisclassifiedasaClassBwaterandacoldwaterfishhabitat,andisidentifiedasanimportantaquatichabitatandspeciesassemblage(i.e.,alocationwithconcentrationsofrarespecies,especiallydiverseareas,and/orimportantspeciesassemblages).

Althoughpotentialsensitivereceptorsmaybepresentin/neartheMissisquoiRiver,theecologicalriskisanticipatedtobelowgiventhefollowing:

Concentrationsofcontaminantsinsitegroundwaterarerelativelylow. GroundwaterdatacollectedaspartofinvestigationoftheFormerE.J.BarretteFordsiteindicatethatgroundwaterneartheMissisquoiRivertypicallyhaslowerconcentrationsthansamplinglocationsbetweentheMemorialBuildingandCanadaStreet.

ThedilutionofgroundwatercontaminantsdischargingtotheMissisquoiRiverisexpectedtobesignificant. Thepetroleum‐relatedanalytesdetectedingroundwateraspartofthis investigationaretypicallysubjecttodegradationinthesurfaceenvironment,andarenotanticipatedtopersistatsignificantconcentrations,norbesubjecttobioaccumulation.

Thispreliminaryassessmentwouldneedtobeevaluatedfurtherwithanecologicalriskassessment,asappropriate.

2 "VermontPrimaryGroundwater"PAL"and"ES"StandardsarePrimaryGroundwaterStandardsfromtheStateofVermontAgencyofNaturalResourcesDepartmentofEnvironmentalConservation"Chapter12oftheEnvironmentalProtectionRules:GroundwaterProtectionRuleandStrategy"(December16,2016),includingtheMarch4,2016InterimGroundwaterQualityStandards."ES"isEnforcementStandard;"PAL"isPreventiveActionLevel.

3 anrmaps.vermont.gov/websites/anra/4 biofinder.vt.govisamapanddatabaseidentifyingVermont'slandsandwaterssupportinghighpriorityecosystems,naturalcommunities,habitats,andspecies.



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Media SoilGasAnalytes Tetrachloroethene(PCE) Chloroform Naphthalene:Exceedances5/Locations

Residential:Twolocations:SG‐1andSG‐9

NoexceedancesofIndustrialVIScreeningLevel

Residential:Ninelocations:SG‐3,SG‐4,SG‐5,SG‐6,SG‐7,SG‐9,SG‐10,SG‐14,andSG‐7M‐1

Industrial:Onelocation:SG‐4

Residential&Industrial:Onelocation:SG‐14

InferredSource(s) ThepresenceofPCEinsoilgascouldpotentiallybetheresultofactivitiespreviouslyperformedintheMemorialBuildingbasement(e.g.,useofcleaningproducts).ThetransportmechanismfortheCVOCshasnotbeenidentified,butpossibleleaksinthedrainnetwork,ortransportthroughcracks/penetrationsinthefloorslabremainpossibilities.

SeveralchloroformdetectionswererecordedatlocationsthatarerelativelycloseanddowngradientfromCanadaStreet,whereapublicwaterlineispresent,aswellasatSG‐9wherethesewerpipeexitstheMemorialBuilding.Thedetectionsofchloroforminsoilgascouldbetheresultofchlorinatedwaterenteringthesubsurfaceandreactingwithresidualorganicmaterial,orthepresenceofchloroforminthedrinkingwater.

GiventhepresenceofpetroleumconstituentsinsoilgasatSG‐14(e.g.,AVOCs[including:benzene,toluene,ethylbenzene,xylene],ethanol,and2,2,4‐trimethylpentane),thenaphthaleneisinferredtoberelatedtoapetroleumrelease(mostlikelygasoline)notassociatedwiththeMunicipalLot.


CurrentSiteConfiguration

ExceedancesoftheVTDECResidentialVIScreeningValueweredetectedinsoilgasattwolocations(SG‐1beneaththeMemorialBuilding)andSG‐9(locatedatanexteriorlocationnearthenorthwestcorneroftheMemorialBuilding).NoexceedancesoftheVTDECIndustrialVIScreeningValueswerenoted.

NinelocationssampledbetweenDecember2016andFebruary2018indicatedchloroformconcentrationsexceedingtheVTDECResidentialVIScreeningValue.Onelocation(SG‐4;beneaththeProutyBuildingwhichisproposedfordemolition)exceededtheVTDECIndustrialVIScreeningValue.Weinferthatthepresenceofchloroforminsoilgascouldbetheresultofchlorinatedwaterenteringthesubsurfaceandreactingwithresidualorganicmaterial,orthepresenceofchloroforminthedrinkingwater,andisnotinferredtobeindicativeofanon‐siterelease.

SG‐14sampledinOctober2017indicatedanaphthaleneconcentrationexceedingtheVTDECResidentialandIndustrialVIScreeningValues.Thepresenceofnaphthaleneinsoilgasisinferredtoberelatedtoapetroleumrelease(mostlikelygasoline)notassociatedwiththeMunicipalLot.

AnticipatedSiteRedevelopment

TheobservedPCEsoilgasconcentrationswerebelowtheIndustrialVIScreeningValue,andpresumablythereforewouldnotconstituteanunacceptableriskrelatedtopotentialvaporintrusionfromPCEatthesiteundertheproposedredevelopmentscenario.Giventhenon‐detectPCEconcentrationsatsoilgaslocationswest/northwestoftheMemorialBuilding,therewasnorisktooff‐sitereceptorsfromPCEidentifiedattheKinneyPikeInsuranceor7MerchantsRowbuildings.

Basedonthefuturecommercial/retailredevelopmentscenariowhichisanticipatedtoincluderemovalofbuildingsalongCanadaStreet,chloroformisnotconsideredtoconstituteunacceptableriskrelatedtopotentialvaporintrusionatthesite.GiventheinferredchloroformsourceisnotlocatedontheMunicipalLot/MerchantsRowproperties,theevaluationofpotentialrisktooff‐sitereceptorsfromchloroforminsoilgasisoutsidethescopeofthisinvestigation

ThepresenceofnaphthaleneinsoilgasatSG‐14(locatedoffsiteadjacenttoMerchantsRow)isinferredtoberelatedtoapetroleumrelease(mostlikelygasoline)notassociatedwiththeMunicipalLot.ThenaphthalenedetectionatSG‐14isnotconsideredtoconstituteunacceptableriskrelatedtopotentialvaporintrusionattheMunicipalLotsite.TheresultsofthisAdditionalSoilGasPhaseIIESAshouldbesharedwithVTDECandreviewedinthecontextofmanagementofthenearbyWasteManagementDivision(WMD)sites–refertorecommendations.

P:\4000s\4091.00\SourceFiles\CAP\Tables\Tbl_X.docx

5 "VTDECVIScreeningValues"wereobtainedfromAppendixA.2ofthe"InvestigationandRemediationofContaminatedPropertiesRule"("IRule"),effectiveJuly27,2017.http://dec.vermont.gov/sites/dec/files/wmp/Sites/07.11.2017.Adopted.Rule_.for_.SOS_.filing.pdf;downloadedonJuly19,2017.

TABLE6EvaluationofRemedialAlternatives


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Soil

EvaluationCriteria Alternative1a:Noaction

Alternative1b:On‐sitesoilreuse/NoticewithintheCOCthatrequiresnotificationtoVTDECifanyfuturesoildisturbancewilloccurinareaswherecontaminationhasbeenidentified Alternative1c:TargetedSoilExcavationwithOff‐SiteSoilDisposal

Compliancewithlegalrequirements

IsnotanticipatedtomeetallFederal,State,orlocalpermittingrequirementsduetoidentifiedcontaminationindeepsitesoilson‐site.

IsanticipatedtomeetFederal,State,orlocalpermittingrequirementsaspartoftypicalconstructionactivities.

IsanticipatedtomeetFederal,State,orlocalpermittingrequirementsaspartoftypicalconstructionactivities.

Overallprotectionofhumanhealthandtheenvironment

Isnotanticipatedtobeprotectiveofhumanhealthandtheenvironmentbecausepotentialexposuretocontaminationthroughcontactwithcontaminatedsoilsatdepthwouldnotberestricted.

Isanticipatedtobeprotectiveofhumanhealthandtheenvironmentbecausetheplannedexcavationisnotanticipatedtoencountercontaminatedsoil.TheCOCisanticipatedtoincludeaninstitutionalcontrolthatwillbeprotectiveofhumanhealth.

Isanticipatedtobeprotectiveofhumanhealthandtheenvironmentbecauseitinvolvestheremovalofcontaminatedsoilandeliminatespotentialexposurepathways.

Long‐termeffectivenessandpermanence

Isnoteffectiveinpreventingthelong‐termexposureofreceptorstocontaminationattheSitebecausepotentialexposuretocontaminationthroughcontactwithcontaminatedsoilsatdepthwouldnotberestricted.

Isanticipatedtohavelong‐termeffectivenessbecausefuturesoildisturbanceinareasofidentifiedcontaminationwillrequireVTDECnotification.

Isanticipatedtohavelong‐termeffectivenessbecauseitwillentailremovalandoff‐sitedisposalofcontaminatedsoil.

Reducingtoxicity,mobility,orvolumethroughtreatment

Willnotreducetoxicity,mobilityorvolumethroughtreatment.


Isanticipatedtoreducetoxicity,mobilityandvolumebecauseitwillentailremovalandoff‐sitedisposalofcontaminatedsoil.

Short‐termeffectiveness

Isnoteffectiveinpreventingtheshort‐termexposureofreceptorstocontaminationattheSitebecausepotentialexposuretocontaminationthroughcontactwithcontaminatedsoilsatdepthwouldnotberestricted.

Isanticipatedtohaveshort‐termeffectivenessbecausefuturesoildisturbanceinareasofidentifiedcontaminationwillrequireVTDECnotification.

Isanticipatedtohaveshort‐termeffectivenessbecauseitwillentailremovalandoff‐sitedisposalofcontaminatedsoil.

Implementability Iseasytoimplementsincenoactionwillbeperformed. Iseasytoimplementbecauseon‐sitesoilreuserequiresnospecialmethodsbeusedbythecontractor,andtheinstitutionalcontrolsundertheCOCarestraightforward.

Isanticipatedtoberelativelyeasytoimplementfromaconstructionstandpointbecauseitwillentailarelativelysmallvolumeofsoilexcavation/backfill.

Cost Therewillbenoremediation‐relatedcostsunderthisalternative.

ThecosttosupportreceiptoftheCOCisconsideredminimalbecauseitentailsonlysmallcapitalcosts;O&Mcostsarenotnecessaryforthisalternative.

Thisalternativehasthehighestoverallcostduetotheexcavationandoff‐sitedisposalcontaminatedsoilandtheimportationofcleanfillmaterialneededforbackfillingtheexcavationarea.

Environmentalimpactandsustainability

ComplieswithEPA’sGreenRemediationStrategy. IscompliantwithEPA’sGreenRemediationStrategy,becauseitavoidsthehighenergyandcarbonfootprintinvolvedwithsoildisposal(seebelow).Also,theproposedreuseofthesoilfitsinwithEPA’sgoaltoreduce,reuse,andrecyclematerialsandwastes.

Off‐sitesoildisposalisthemostnon‐compliantwithEPA’sGreenRemediationStrategy,becauseitrequirestheneedtotrucksoilsapproximately60mileseasttoCoventry,VermontwherethenearestMunicipalSolidWasteLandfillislocated.Thistruckinginvolveshighenergyuseandhasahighcarbonfootprint.Also,thedisposalofmildlycontaminatedsoilinasolidwastelandfillisnotaneffectiveuseoflandfillspaceanddoesnotmeetsEPA’sgoalstoreduce,reuse,andrecyclewastes.

Communityacceptance

Isnotanticipatedtosignificantlydisruptthecommunity;thereforecommunityacceptanceisanticipated.


Mayresultinminordisruptiontothecommunityrelatedtosoilexcavation/trucktraffic.Assuch,preparationofacommunityrelationsplanisrecommendedtogaincommunityacceptance.

Notes:Theremedialalternativeshavebeenevaluatedconsistentwithcriterialistedin§35‐503(d)oftheInvestigationandRemediationofContaminatedPropertiesRule(I‐Rule),effectiveJuly27,2017.RefertothetextandAppendixGforassumptionsandcostestimatesforthesealternatives.



SMSSite#2016‐4658

Page2of4

GroundwaterEvaluationCriteria Alternative2a:Noaction Alternative2b:DeedRestrictiontoprohibitgroundwaterextractionCompliancewithlegalrequirements

IsnotanticipatedtomeetallFederal,State,orlocalpermittingrequirementsduetoidentifiedcontaminationinon‐sitegroundwater.

IsanticipatedtomeetFederal,State,orlocalpermittingrequirementsbecausepotentialexposuretocontaminationthroughtheuseofgroundwaterwouldberestricted.


Isnotprotectiveofhumanhealthandtheenvironmentbecausepotentialexposuretocontaminationthroughtheuseofgroundwaterwouldnotberestricted.

Isanticipatedtobeprotectiveofhumanhealthandtheenvironmentbecausepotentialexposuretocontaminationthroughtheuseofgroundwaterwouldberestricted.


Isnoteffectiveinpreventingthelong‐termexposureofpotentialreceptorstocontamination.

Isanticipatedtobeeffectiveinpreventingthelong‐termexposureofpotentialreceptorstocontamination.



Willnotreducetoxicity,mobilityorvolumethroughtreatmentbecausecontaminatedgroundwaterwillnotberemoved/treated.

Short‐termeffectiveness Isnoteffectiveinpreventingtheshort‐termexposureofpotentialreceptorstocontamination.

Isanticipatedtobeeffectiveinpreventingtheshort‐termexposureofpotentialreceptorstocontamination.

Implementability Iseasytoimplementsincenoactionwillbeperformed. ADeedRestrictionisrelativelyeasytoimplement.Further,giventhatpublicwaterisavailableatthesite,theprohibitionongroundwaterextractionisnotanonerouslimitationtopropertyuse.


ThecosttoimplementtheDeedRestrictionisconsideredminimalbecauseitentailsonlysmallcapitalcosts;O&Mcostsarenotnecessaryforthisalternative.


ComplieswithEPA’sGreenRemediationStrategy. ComplieswithEPA’sGreenRemediationStrategybecauseitdoesnotentailalargecarbonfootprinttoimplement.

Communityacceptance Isnotanticipatedtodisruptthecommunity;thereforecommunityacceptanceisanticipated.

Isnotanticipatedtodisruptthecommunity;thereforecommunityacceptanceisanticipated.




SMSSite#2016‐4658

Page3of4

SoilGas

EvaluationCriteria

Alternative3a:Noaction

Alternative3b:DeedRestrictionorzoningchangewouldberequiredtoprohibitresidentialuseoftheMemorialBuilding.

Alternative3c:MemorialBuildingBasementFillingandSealing

Compliancewithlegalrequirements

IsnotanticipatedtomeetFederal,State,orlocalpermittingrequirementsduetoidentifiedcontaminationinon‐sitesoilgasaboveresidentialscreeninglevels.

IsanticipatedtomeetFederal,State,orlocalpermittingrequirementsbecausepotentialresidentialexposuretocontaminationthroughtheVIpathwaywouldberestricted.

IsanticipatedtomeetFederal,State,orlocalpermittingrequirementsbecausepotentialexposuretocontaminationthroughtheVIpathwaywouldberestricted.


Isnotanticipatedtobeprotectiveofhumanhealthandtheenvironmentbecausepotentialresidentialexposuretocontaminationthroughvaporintrusionwouldnotberestricted.

Isanticipatedtobeprotectiveofhumanhealthandtheenvironmentbecausepotentialresidentialexposuretocontaminationthroughvaporintrusionwouldberestricted.

Isanticipatedtobeprotectiveofhumanhealthandtheenvironmentbecauseitmitigatesthelong‐termexposureofpotentialreceptorstocontaminationthroughthevaporintrusionpathway


Isnoteffectiveinpreventinglong‐termVIexposuretopotentialresidentialreceptors.

Isanticipatedtobeeffectiveinpreventinglong‐termVIexposuretopotentialresidentialreceptors.

Isanticipatedtobeeffectiveinpreventingthelong‐termexposureofpotentialreceptorstocontaminationthroughthevaporintrusionpathway.




Willnotreducetoxicity,mobilityorvolumethroughtreatmentbecausecontaminatedsoilgaswillnotberemoved/treated.

Short‐termeffectiveness Isnoteffectiveinpreventingshort‐termVIexposuretopotentialresidentialreceptors.

Isanticipatedtobeeffectiveinpreventingshort‐termVIexposuretopotentialresidentialreceptors.

Isanticipatedtobeeffectiveinpreventingtheshort‐termexposureofpotentialreceptorstoVIcontamination.

Implementability Iseasytoimplementsincenoactionwillbeperformed.

ADeedRestriction/zoningchangeisrelativelyeasytoimplement.

Isanticipatedtoberelativelyeasytoimplementbecausebasementfilling/vaporbarrierinstallationcanbeperformedaspartofbuildingrenovationactivitiesplannedbythesiteowner.


ThecosttoimplementtheDeedRestriction/zoningchangetoprohibitresidentialuseoftheMemorialBuildingisconsideredminimal.

Willincludeonlycapitalcosts;O&Mcostsarenotnecessaryforthisalternative.Costsforthisalternativeareestimatedtobeapproximately$134,000,butareconsistentwithtypicalsiteredevelopmentcoststosupportplannedsitereuseinadditiontoprovidingmitigationofVIpathways.


ComplieswithEPA’sGreenRemediationStrategy. ComplieswithEPA’sGreenRemediationStrategy. GenerallymeetsthegreenandsustainableinitiativesinEPA’sGreenRemediationStrategybecauseitentailsretrofitofanexistingbuilding(ratherthannewconstruction)andreliesonapassivedesignthatwillnotrequireon‐goingO&M.

Communityacceptance Isnotanticipatedtosignificantlydisruptthecommunity;thereforecommunityacceptanceisanticipated.






SMSSite#2016‐4658

Page4of4

HazardousBuildingMaterialsEvaluationCriteria Alternative4a:Noaction Alternative4b:HBMAbatementCompliancewithlegalrequirements

IsnotanticipatedtomeetallFederal,State,orlocalpermittingrequirementsduetoidentifiedpresenceofHBMs.

Isanticipatedtomeetpermittingrequirements.


IsnotanticipatedtobeprotectiveofhumanhealthandtheenvironmentbecausepotentialoccupantexposuretocontaminationthroughHBMswouldnotberestricted/eliminated.

IsanticipatedtobeprotectiveofhumanhealthandtheenvironmentbecauseitinvolvestheremovalofHBMsandeliminatespotentialexposurepathways.


IsnoteffectiveinpreventingtheexposureofreceptorstoHBMsattheSitegiventheredevelopmentplansproposedfortheproperty.

Isanticipatedtohavelong‐termeffectivenessbecauseitentailstheremovalofHBMsandeliminatespotentialexposurepathways.



Isanticipatedtoreducetoxicity,mobilityandvolumebecauseitwillentailremovalandoff‐sitedisposalofHBMs.

Short‐termeffectiveness IsnoteffectiveincontrollingtheexposureofreceptorstoHBMsattheSitegiventheredevelopmentplansproposedfortheproperty.

Isanticipatedtohaveshort‐termeffectivenessbecauseitentailstheremovalofHBMsandeliminatespotentialexposurepathways.

Implementability Iseasytoimplementsincenoactionwillbeperformed. Isanticipatedtoberelativelyeasytoimplementbecauseitentailsstandardabatement/demolition/disposal/testingmethodsthatcanbeperformedaspartoftypicalsiteredevelopmentactivities.


Willincludeonlycapitalcosts;O&Mcostsarenotnecessaryforthisalternative.HBMabatementcostsareexpectedtobetypicalfortheproposedsiteredevelopment.


ComplieswithEPA’sGreenRemediationStrategy. WillnotmeetthegreenandsustainableinitiativesinEPA’sGreenRemediationStrategybecauseitwillrequiretruckingHBMsoff‐siteanddisposinginalandfill.However,becauseleavingHBMsinplaceisnotprotectiveofhumanhealth,off‐sitedisposalisconsideredtheonlyfeasible/practicalalternative.GreenBMPsimplementedaspartoftransport/disposalcouldhelplowercarbonfootprint.

Communityacceptance Isnotanticipatedtosignificantlydisruptthecommunity;thereforecommunityacceptanceisanticipated.



P:\4000s\4091.00\SourceFiles\CAP\Tables\Tbl_6.docx

FIGURES

Sources: Esri, HERE, DeLorme, Intermap, increment P Corp., GEBCO,USGS, FAO, NPS, NRCAN, GeoBase, IGN, Kadaster NL, Ordnance Survey,Esri Japan, METI, Esri China (Hong Kong), swisstopo, MapmyIndia, ©OpenStreetMap contributors, and the GIS User Community

© 2018 SANBORN, HEAD & ASSOCIATES, INC.

Locus Plan

Figure 1

Corrective Action Plan

Swanton, Vermont

Drawn By:Designed By:Reviewed By:

Project No:Date:

E. WrightC. NortonT. White4091.00April 2018

500 0 500 1,000250Feet-_̂

Esri, HERE, DeLorme,MapmyIndia, ©

Path: P:\4000s\4091.00\Graphics Files\GIS\Figures\CorrectiveAction_Locus.mxd Last Edited By: ewright

Site

Miss

isquo

i Rive

r

SH-3W

SH-4W

SH-2W

SH-5W

MW-105

MW-102

MW-101

MW-111

MW-114

MW-11

SG-8

SG-9

SG-10

AA-1

SG-2

SB-2

SB-1

SG-3

SG-6

SG-7 SG-4

SG-5

SG-11 SG-12

SG-13

SED-1

SG-1

SG-14

Memorial Building

WarehouseBuilding

Former E.JBarrette Ford

The PartsStore

Bob's One Stop(Formerly Swanton Gulf)

Merchants RowRetail Strip

Laundromat(former Greer's

Cleaners)

RoyInsuranceBuilding

7 Merchants RowApartment Building

SwantonCofC

MissisquoiRiver

Canada Street

Merchants Row

Marble Mill Park

SG-7M-1

SG-7M-2

Vacant Lot

VFW

ProutyBuilding

TheatreBuilding

PeoplesUnited Bank

SS-3

SS-1

SS-2

MW-1

MW-10

MW-103

MW-104

MW-106

MW-107

MW-108

MW-109

MW-110

MW-115MW-116

MW-117

MW-118

MW-120

MW-121

MW-122

MW-123

MW-124

SH-6W

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This figure shows sample locations in thevicinity of the Municipal Lot relative tosubsurface utilities beneath Merchants Row.The subsurface utility information is basedon a record drawing obtained from SwantonVillage Department of Public Works.

Site Vicinity Plan


Swanton, Vermont

Figure Narrative

Figure 2

15'30' 0 30' 60'Feet

Project No:Reviewed By:Designed By:

Drawn By:T. WhiteE. Wright

4091.00C. Crocetti

Date: April 2018

Monitoring wellMonitoring well not locatedpresumed destroyedSoil gas sampling locationAmbient air sample locationSubslab soil sample locationDrain sediment sampling locationShallow soil sample location

Legend

1. Aerial photograph downloaded fromGoogle Earth Pro. Image dated May 13,2015.2. Subsurface utilities beneath MerchantsRow are based on a record drawing entitled"Swanton Village, Vermont CombinedSewer Separation, Sheet 17 of 78"(prepared by Dubois and King, dated March1994), obtained from Swanton VillageDepartment of Public Works via NRPC.3. Monitoring wells and exterior soil vaporsampling locations installed by SanbornHead were surveyed by Vermont Surveyand Engineering. Other sampling locationsshould be considered approximate. Refer toSanborn Head's Phase II ESA Reports foradditional information.

Notes

SAN NBOR HEAD

SH-2W

AA-1

SB-1

SG-1

MW-101

SED-1

SS-1

SH-3W

SH-4W

SH-2W

SH-5W

MW-105

MW-102

MW-101

MW-111

MW-114

MW-11

SG-8

SG-9

SG-10

AA-1

SG-2

SB-2

SB-1

SG-3

SG-6

SG-7 SG-4

SG-5

SG-11 SG-12

SG-13

SED-1

SG-1

SG-14

Memorial Building

WarehouseBuilding


The PartsStore




Cleaners)



SwantonCofC

MissisquoiRiver

Canada Street

Merchants Row

Marble Mill Park

SG-7M-1

SG-7M-2

Vacant Lot

VFW

ProutyBuilding

TheatreBuilding

PeoplesUnited Bank

SS-3

SS-1

SS-2

135

134

133

132

131

130

125

120

115

110

105

129.2

130.0

129.5

131.0

131.7

131.8

131.8 131.7 131.7131.5

132.4

133.0133.1

MW-1

MW-10

MW-103

MW-104

MW-106

MW-107

MW-108

MW-109

MW-110

MW-115MW-116

MW-117

MW-118

MW-120

MW-121

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SH-6W

133.5

134.2134.2

134.3

134.1

133.9

135.4Canada Street1

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This figure depicts groundwater elevationcontours based on groundwater levels measuredby Sanborn Head personnel in wells on May24-25, 2017.

Groundwater ElevationContour PlanCorrective Action Plan

Swanton, Vermont

Figure Narrative

Figure 3

15'30' 0 30' 60'Feet



4091.00C. Crocetti

Date: April 2018

Legend

1. Variable contour intervals were used todepict the steep gradient northward towardMarble Mill Park relative to the MunicipalLot/1-3-5 Canada Street.2. The groundwater elevation contours weredeveloped using generally-acceptedhydrogeologic practices, and are intended todepict inferred trends in groundwater levelsconsistent with the available information. Actualconditions may vary from those shown and otherinterpretations are possible.3. Variations in groundwater elevations areexpected to occur due to changes in precipitation,temperature, and other factors not evident at thetime water level measurements were obtained.4. Refer to previous figures for additional notesand legend.

Notes

SAN NBOR HEAD

Groundwater elevation recorded onMay 24-25, 2017Groundwater elevation contour basedon May 24-25, 2017 water levels(dashed where less constrained)135

135.4

SH-3W

SH-4W

SH-2W

SH-5W

MW-105

MW-102

MW-101

MW-111

MW-114

MW-11

SG-8

SG-9

SG-10

AA-1

SG-2

SB-2

SB-1

SG-3

SG-6

SG-7 SG-4

SG-5

SG-11 SG-12

SG-13

SED-1

SG-1

SG-14

Memorial Building

WarehouseBuilding


The PartsStore




Cleaners)



SwantonCofC

MissisquoiRiver

Canada Street

Merchants Row

Marble Mill Park

SG-7M-1

SG-7M-2

Vacant Lot

VFW

ProutyBuilding

TheatreBuilding

PeoplesUnited Bank

SS-3

SS-1

SS-2

MW-1

MW-10

MW-103

MW-104

MW-106

MW-107

MW-108

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This figure provides a summary of Phase IIESA information. The soil sample resultswere compared to standards/screeninglevels. Locations where samples indicatedan exceedance of one or more screeninglevels are annotated. Refer to table 2 andtext for additional information.

Soil ContaminantDistribution Plan


Swanton, Vermont

Figure Narrative

Figure 4

15'30' 0 30' 60'Feet



4091.00C. Crocetti

Date: April 2018

Indicates exceedances in soilLegend

1. Refer to previous figures for additionalnotes and legend.

Notes

SAN NBOR HEAD

UST-East/S2 7.5-8.5 ft bgs: BaP TEQ Res. SSV exceedance in soil sample beneath former UST (removed May 2017). TPHs not detected. PAHs inferred to be related to presence of "urban" fill soils, and are not indicative of a petroleum release.

SH-2W 9-10 ft bgs: Aromatic VOCs, naphthalene, and BaP TEQ exceeded Res. SSVs. Sample was collected from the groundwater table smear zone, and is not considered representative of vadose soil conditions. The contaminant signature is consistent with impacts from an off-site gasoline source, likely the Former E.J. Barrette Ford site and/or the Former Swanton Gulf site, and possibly also urban fill soils.

SH-3W

SH-4W

SH-2W

SH-5W

MW-105

MW-102

MW-101

MW-111

MW-114

MW-11

SG-8

SG-9

SG-10

AA-1

SG-2

SB-2

SB-1

SG-3

SG-6

SG-7 SG-4

SG-5

SG-11 SG-12

SG-13

SED-1

SG-1

SG-14

Memorial Building

WarehouseBuilding


The PartsStore




Cleaners)



SwantonCofC

MissisquoiRiver

Canada Street

Merchants Row

Marble Mill Park

SG-7M-1

SG-7M-2

Vacant Lot

VFW

ProutyBuilding

TheatreBuilding

PeoplesUnited Bank

SS-3

SS-1

SS-2

MW-1

MW-10

MW-103

MW-104

MW-106

MW-107

MW-108

MW-109

MW-110

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MW-118

MW-120

MW-121

MW-122

MW-123

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This figure provides a summary of the groundwatersample results from the Supplemental Phase II ESA,shown relative to the standards. Refer to Table 3 andtext for additional information.

Groundwater ContaminantDistribution Plan


Swanton, Vermont

Figure Narrative

Figure 5

15'30' 0 30' 60'Feet



4091.00C. Crocetti

Date: April 2018

Bold values indicate the detected concentrationexceeds the Vermont Preventive Action Level (PAL)

Italic values indicate the detected concentrationexceeds the Vermont Enforcement Standard (ES)

"ND" indicates not detected above laboratoryreporting limit

"J" Indicates estimated values. See Data QualityAssessment Appendix E of the February 2017Phase II ESA Report) for additional details

Legend

1. In cases where a duplicate sample wascollected, both results are indicated. In cases wheretwo analytical methods were used (i.e., fornaphthalene), the 8260C results are shown on thetop line, and the 8270D results are shown in bracketson the second line. Refer to Table 3 for additionalinformation.

2. "M" The percent recovery in the MS/D wasoutside acceptance criteria. See Data QualityAssessment (Appendix E of the February 2017Phase II ESA Report) for additional details.

3. Refer to previous figures for additional notesand legend.

Notes

SAN NBOR HEAD

1,000540

1,770

340

MW-104

970230

1,210

240J[120 ]

MW-108

<2<2

ND

<5

MW-117

<2<2

ND

<5/<0.5

MW-123

590M/600360M/360

1,200/1,210

220J/240J[180M /180]

SH-2W

1,100440

1,100

190J[160 ]

SH-3W

840170

1,160

140J[95 ]

SH-4W

2<2

403

30J[12]

SH-5W

6/6<2/<2

ND/ND

40 /50[14/9]

SH-6W

EthylbenzeneToluene

TotalTrimethylbenzene

Naphthalene

Analyte

SH-3W

SH-4W

SH-2W

SH-5W

MW-105

MW-102

MW-101

MW-111

MW-114

MW-11

SG-8

SG-9

SG-10

AA-1

SG-2

SB-2

SB-1

SG-3

SG-6

SG-7 SG-4

SG-5

SG-11 SG-12

SG-13

SED-1

SG-1

SG-14

Memorial Building

WarehouseBuilding


The PartsStore




Cleaners)



SwantonCofC

MissisquoiRiver

Canada Street

Merchants Row

10J (15J)21 (26.7)24.7

28.866.3

1.463.02

<7.2<1.36 (<1.36)

<7.1 <7.1

<7.2

<7.0

3.4J5.89

<1.361.69

<6.5<1.36<1.36<1.36

2.37 1.60

2.91

<1.36

Marble Mill Park

SG-7M-1

SG-7M-2

<1.36 (<1.36)

<1.36

Vacant Lot

VFW

ProutyBuilding

TheatreBuilding

PeoplesUnited Bank

SS-3

SS-1

SS-2

MW-1

MW-10

MW-103

MW-104

MW-106

MW-107

MW-108

MW-109

MW-110

MW-115MW-116

MW-117

MW-118

MW-120

MW-121

MW-122

MW-123

MW-124

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This figure provides a summary of soil gassample results, shown relative to theVTDEC screening levels. PCEconcentrations from December 2016, May2017, September 2017, October 2017, andFebruary 2018 are indicated. Refer to Table4 and text for additional information.

Soil Gas ContaminantDistribution Plan


Swanton, Vermont

Figure Narrative

Figure 6

15'30' 0 30' 60'Feet



4091.00C. Crocetti

Date: April 2018

Tetrachloroethene (PCE)concentration in μg/m3

Bold indicates the detected PCEconcentration exceeds theVTDEC Vapor Intrusion (VI)Shallow Soil Gas ScreeningValueIndicates estimated values. SeeData Quality Assessment(Appendix E of the February 2017Phase II ESA Report) foradditional detailsIndicates duplicate sample

Legend

1. Aerial photograph downloaded fromGoogle Earth Pro. Image dated May 13,2015.2. Maximum soil gas VOC concentrations(in μg/m3) are indicated in call-out boxesrelative to VTDEC screening levels.3. Refer to previous figures for additionalnotes and legend.

Notes

SAN NBOR HEAD

1.46

26.7

J

( )

<1.36

SG-13 PCE Max: 2.91

SG-11 PCE Max: 2.37

SG-12 PCE Max: 1.6

SG-10 Chloroform max: 4.81 Exceeds Residential S.L.

AA PCE not detected

SG-9 PCE Max: 66.3 Exceeds Residential S.L.

SG-8 PCE Max: 3.02

SG-2 PCE Max: 5.89

SG-1 PCE Max: 26.7 Exceeds Residential S.L.

SG-14 Naphthalene max: 11.5 Exceeds Residential and Industrial S.L. Chloroform max: 11.3 Exceeds Residential S.L.PCE not detected

SG-3 Chloroform max: 4.6J Exceeds Residential S.L.PCE not detected

SG-4 Chloroform max: 27 Exceeds Residential and Industrial S.L.PCE not detected

SG-6 Chloroform max: 5.32 Exceeds Residential S.L.PCE not detected



Chloroform max: 5.08 Exceeds Residential S.L.

PCE Residential Screening Level Exceedance

Chloroform or Naphthalene Screening Level Exceedance

Maximum VOC concentrations (in ug/m3) are indicated in call-out boxes

SG-7M-1 Chloroform max: 5.37 Exceeds Residential S.L.PCE not detected

SG-7M-2 PCE not detected

APPENDIXA

SITEREDEVELOPMENTPLAN

Approximate location of UST-East/S2 soil sample collected from 7.5-8.5 ft bgs. This location is the only area on the site where soil contamination in exceedance of the Vermont Industrial Soil Screening Values was identified above the water table. Soil disturbance associated with site preparation is not anticipated to encounter the 7.5-8.5 ft interval. This area will be covered by a proposed building.

SH-2W soil sample 9-10 ft bgs indicated aromatic VOCs, naphthalene, and BaP TEQ exceeded Res. SSVs. Sample was collected from the groundwater table smear zone, and is not considered representative of vadose soil conditions. The contaminant signature is consistent with impacts from an off-site gasoline source, likely the Former E.J. Barrette Ford site and/or the Former Swanton Gulf site, and possibly also urban fill soils. Location will be beneath new site driveway.

APPENDIXB

PUBLICNOTICEWITHPARCELMAP/ABUTTERS

APPENDIXB.1

PUBLICNOTICE

**DRAFT**

CORRECTIVE ACTION PLAN AT 1-3-5 CANADA STREET AND THE MUNICIPAL LOT AT MERCHANTS ROW SWANTON, VT (#2016-4658) An Evaluation of Corrective Action Alternatives (ECAA)/Corrective Action Plan (CAP) dated April XX, 2018 was prepared by Sanborn, Head & Associates, Inc. on behalf of the Northwest Regional Planning Commission (NRPC) for the site located at 1-3-5 Canada Street and the Municipal Lot at Merchants Row in Swanton, Vermont. The CAP was prepared to prevent unacceptable risk of exposure to site users to: direct contact or ingestion of contaminated soil, ingestion of contaminated groundwater, inhalation of volatile organic compounds (VOCs) through the vapor intrusion pathway, and direct contact with Hazardous Building Materials (HBMs). Contamination was detected at the site during environmental site assessment activities conducted in 2016 through 2018. The site investigation found soils contaminated with benzo(a)pyrene, petroleum-related VOCs in groundwater, chlorinated VOCs in soil gas, and HBMs (asbestos containing material and lead-based paint) in site structures. The site consists of three parcels totaling approximately 1.4 acres with site buildings that are proposed to be renovated or demolished as part of site redevelopment. The property is enrolled in the Brownfields Reuse and Environmental Liability Limitations Act (BRELLA) program. The CAP details the proposed remediation, which includes: 1. Implementation of institutional controls on the site property in the form of a Certificate

of Completion (COC) under the State of Vermont Brownfields Reuse and Environmental Liability Limitation Act (BRELLA). Limitations on property proposed to be included in the COC include:

a. Notice within the COC that requires notification to DEC if any future soil disturbance will occur in areas where contamination has been identified.

b. A Deed Restriction to prohibit groundwater extraction.

2. Filling and sealing the Memorial Building basement to mitigate potential VI impacts.

3. Abatement of HBMs.

The Secretary of the Agency of Natural Resources is considering approving the Corrective Action Plan that describes the above mentioned remedial measures for the 1-3-5 Canada Street and the Municipal Lot at Merchants Row site. The proposed Corrective Action Plan for the site can be viewed at the Swanton Village office located at 120 First Street, Swanton, or at the Waste Management & Prevention Division (WMPD) offices at 1 National Life Drive in Montpelier, Vermont. Electronic copies of the Corrective Action Plan, or other site reports and relevant documents may be made available upon request. Alternatively, these documents may be viewed on the Waste Management Interactive Database (WMID) at this web address:

**DRAFT**

https://anrweb.vt.gov/DEC/ERT/Hazsites.aspx, by typing in either the Site Number, which is 2016-4658 or the Site Name, which is “Swanton Municipal Lot”. Please direct any comments or questions to: Kimberly Caldwell, Environmental Analyst Vermont Department of Environmental Conservation 802-461-5857 The public comment period for the Corrective Action Plan will run from April XX, 2018 through May XX, 2018.

P:\4000s\4091.00\Source Files\CAP\App-B_Public Notice-Parcel_Map\DRAFT_Public_Notice.docx

http://anrweb.vt.gov/DEC/ERT/Hazsites.aspx,

APPENDIXB.2

PARCELMAP/ABUTTERS

April 24, 2018

®www.cai-tech.com

Abutters MapSwanton, VT

0 150 300 450

Village BoundaryPWaterProperty LinePublic RoadRailroadCommonNotPar

Property HookWaterLinesParcelText_LeadersParcelText_ArrowheadsRight of WaysWater-poly

Data shown on this map is provided for planning and informational purposes only. The municipality and CAI Technologies are not responsible for any use for other purposes or misuse or misrepresentation of this map.

1 inch = 150 Feet

GA0036

Parcel not listed in SwantonGIS database

Parcel Number: CAMA Number: Property Address:

CN0002CN0002 2 CANADA ST

Mailing Address: TIMBERLAKE ASSOC 32 SAN REMO DR SO BURLINGTON, VT 05403



Mailing Address: DOMEY GEOFFREY JEANINE 11 FARRAR ST SWANTON, VT 05488



Mailing Address: BARRETTE E J & SONS INC PO BOX 130 SWANTON, VT 05488



Mailing Address: PEOPLES UNITED BANK N.A. RES CONTRACT MANAGER BC05-451850 MAIN STREET BRIDGEPORT, CT 06604


GA0036GA0036 36 GRAND AVE

Mailing Address: VILLAGE PARK 36 GRAND AVE SWANTON, VT 05488


ME0001ME0001 1 MERCHANTS ROW

Mailing Address: MARBLE MILL PARK ,



Mailing Address: RSE & B PROPERTIES LLC PO BOX 37 SOUTH HERO, VT 05486

Abutters:


CN0001CN00011 CANADA ST

Mailing Address: MAQUAM HOLDINGS - CANADA STREET LLC 218 MAQUAM SHORE RD SWANTON, VT 05488


LC0003LC00033 LABEL LANE

Mailing Address: SWANTON VILLAGE PO BOX 279 SWANTON, VT 05488


LC0003ME002525 MERCHANTS ROW

Mailing Address: CHAMBER OF COMMERCE PO BOX 237 SWANTON, VT 05488

Subject Properties:

Abutters List Report - Swanton, VT

4/24/2018

www.cai-tech.comData shown on this report is provided for planning and informational purposes only. The municipality and CAI Technologies

are not responsible for any use for other purposes or misuse or misrepresentation of this report. Page 1 of 2

80 foot Abutters List ReportSwanton, VTApril 24, 2018



Mailing Address: MCGORRY WILLIAM 4302 BOLTON VALLEY RD BOLTON VALLEY, VT 05477



Mailing Address: HORTON DAVID M REVOCABLE TRUST 22 BROADWAY ST SWANTON, VT 05488



Mailing Address: DOWNTOWN SWANTON LLC % KEVIN LOTHIANPO BOX 2 FRANKLIN, VT 05457



Mailing Address: PAPA TIMS LLC PO BOX 123 FAIRFAX, VT 05454



Mailing Address: MASONIC 76 LODGE F&AM 56 MERCHANTS ROW SWANTON, VT 05488



Mailing Address: UNITED DRUG STORES INC % SWANTON REXALL44 MERCHANTS ROW SWANTON, VT 05488

Abutters List Report - Swanton, VT

4/24/2018

www.cai-tech.comData shown on this report is provided for planning and informational purposes only. The municipality and CAI Technologies

are not responsible for any use for other purposes or misuse or misrepresentation of this report. Page 2 of 2

80 foot Abutters List ReportSwanton, VTApril 24, 2018

APPENDIXC

FEMAFLOODMAP

APPENDIXD

RPF’SHBMREPORTS

APPENDIXD.1

JANUARY4,2017HBMREPORT

January 4, 2017 Patrick Troy P.G. Sanborn, Head & Associates, Inc. 20 Foundry Street Concord, NH 03301 Re: Swanton Vermont

Building Survey Findings RPF File No. 167604 Dear Patrick, On December 7, 2016, RPF Environmental, Inc. (RPF) conducted a survey at the 1-5 Canada Street property and the Memorial Hall Building located at the Municipal Lot in Swanton, Vermont. The survey was performed throughout each building as designated by you or your site representative for accessible hazardous building material as indicated herein. Below is a summary of findings, discussion of the results and preliminary recommendations for proper management of the identified hazardous building material. Attached to this report are the survey data tables, laboratory results, survey methodologies and limitations. This report is not intended to be used as an abatement specification or work plan. To proceed with abatement work, the following important steps are necessary:

1. A work plan or project design documents must be prepared prior to abatement by a certified abatement project designer. As part of the design, additional site testing and analysis is required as discussed in this report.

2. The abatement specification or work plan should then be used to solicit bids from qualified abatement contractors. Only properly licensed contractors should be used for asbestos abatement and disposal.

3. A qualified industrial hygiene/testing consultant should conduct sufficient testing and

inspections of the work, independent of the abatement contractor. The consultant should also prepare final abatement reports for the work.

Summary of Findings

The 1-3-5 Canada Street properties is a former retail space consisting of approximately 12,000 square feet of building space. The second story of the 1 Canada Street building was formerly used for residential rental apartments.

The Memorial Hall building located at the municipal lot is a two story structure consisting of approximately 18,500 square feet and has an attached metal Warehouse Building which is approximately 6,500 ft2.

Sanborn Head & Associates, Inc. Swanton, VT Building Survey Findings Page 2

The scope of the survey included accessible asbestos-containing building material in accordance with the initial asbestos inspection requirements prior to renovation or demolition work as stated in the State regulations and applicable federal regulations. In addition, the survey included screening for lead paint (LP), polychlorinated biphenyls (PCB) light ballasts, mercury switches, and fluorescent light bulbs.

Asbestos Several types of suspect asbestos-containing building material (ACBM) were observed by RPF, including friable and nonfriable suspect material. Based on the testing performed by RPF asbestos was detected in the following materials:

Interior Window Caulk Gypsum Board with joint

compound Door Caulk Window Caulk 9” Floor Tile 2x4 Ceiling Tiles Transite Panels Pipe Fitting Insulation

Debris Flooring adhesive Door Glaze Building Seam Caulk Sink Basin Undercoat Floor Tile and Mastic Pipe Insulation Pipe Wrap

Except for the building seam caulk, door and window caulking, siding paper and limited roof testing on 1 Canada Street, exterior portions of the building were inventoried only. Sampling was not performed of exterior suspect ACBM in order not to damage the integrity of the materials at this time. As such, the roofing materials, sealants and compounds are assumed to be ACBM for the purposes of this inspection. When feasible and prior to demolition or disturbance, the roofing materials should be tested including representative core samples and analysis of the different suspect materials. Lead Paint Disposal Issues

Screening of paint for lead content was completed for potential waste disposal purposes and LP was confirmed to be present on various exterior building components. PCB, Mercury and other Potential Hazardous Materials

Based on the RPF visual observations, fluorescent light bulbs are present in the building and it is assumed that some of the older ballasts contain PCBs. PCBs were not detected in the caulking samples or paint samples included in the screening except for one sample of paint which was identified as having low levels of PCB. Mercury containing switches or thermostats were observed during this survey in the Memorial Building and Apartments 1 and 2. Various potential hazardous materials were observed throughout the facility including copier inks, paints, solvents, refrigerants and other miscellaneous items.


Depending on the extent of renovation and final construction plans, proper abatement and/or management of the materials will be required in accordance with applicable State and federal regulations. Renovation and demolition plans should be reviewed by a certified industrial hygienist and a licensed project designer for possible asbestos impact issues. Based on the impact assessment and planned usage, technical specifications should be prepared for abatement, as applicable. A management plan should also be prepared to address any asbestos or other hazardous material scheduled to remain after construction. Discussion of Findings Asbestos-Containing Building Material Asbestos is the name for a group of naturally occurring minerals that separate into strong, very fine fibers. The adverse health effects associated with asbestos exposure have been extensively studied for many years. Results of these studies and epidemiological investigations have demonstrated that inhalation of asbestos fibers may lead to increased risk of developing one or more diseases. In all cases, extreme care must be used not to disturb asbestos-containing materials or to create fiber release episodes. In the accessible locations surveyed, RPF identified ninety-five (95) homogeneous groups of accessible suspect asbestos-containing building material. Suspect materials were identified based on current industry standards, EPA, and other guideline listings of potential suspect ACBM. The following is a summary list of the suspect ACBM identified and sampled during this survey: Various types of formica with adhesive Various Sink basin undercoat Gypsum board with joint compound Various Caulking Airocell pipe insulation Pipe wrap insulation Flu Cement

Transite Panels Textured Surfacing 2x4 Ceiling Tiles Various 12” Floor tiles with adhesive Flooring with adhesive Carpet adhesive Various 1x1 Ceiling Tiles Ceramic Tile Grout Various Types Linoleum

Homosote Board Dairy Board 9” Floor tile with adhesive Plaster Window Glaze Window Caulk Building Seam Caulk Asphalt Shingles

Siding Paper A total of one hundred and ninety-six (196) samples were extracted from the different groups of suspect material in accordance with EPA sampling protocols. In addition, RPF collected ten (10) duplicate samples for quality control purposes. Of the samples collected by RPF, asbestos was detected in fifty (50) groups of suspect ACBM. Table 1 of Appendix A includes a list of ACBM and accessible asbestos identified in the building, EPA category listings, and asbestos content. A listing of the different homogenous groups of suspect material identified, samples collected, and analytical results is included in Appendix A.


The ACBM identified during this survey consists of friable and nonfriable material. The nonfriable ACBM was observed to be in good to fair condition and, left undisturbed and properly managed, is unlikely to cause any major fiber release episodes. The friable ACBM pipe insulation and pipe wrap in the Municipal lot building was observed to be damaged and in 3 Canada Street pipe fitting insulation debris were observed in the basement near the crawlspace. Care should be used to prevent further damage to the materials in each of these areas and to ensure that dust is not disturbed and made airborne. Access to these areas should be restricted until proper cleaning and repairs to the ACBM can be accomplished and air quality sampling is accomplished. As you can see in the analytical results, some of the composite samples of wallboard and joint compound material were found to have trace amounts (<1%) asbestos present. Current definitions for ACBM include materials found to have greater than 1% asbestos content. Layered analysis of this composite material was performed and asbestos was not detected in the wallboard layer and 3% asbestos was detected in the joint compound. Therefore, the joint compound is classified as ACBM. It is recommended that the composite gypsum board and joint compound samples found to have trace amounts of asbestos be submitted to undergo further analysis using point count methods in an effort to determine if the concentration of asbestosis actually less than or greater than 1%. In addition, the caulking on the south windows at 1 Canada Street were found to contain trace amounts of tremolite asbestos. It is recommended that further transmission electron miscopy (TEM) analysis be conducted to determine if the material is greater than 1% asbestos. As reviewed with you some suspect material is assumed to be ACBM as testing of the material was not included in the RPF scope of work or because sampling was not feasible at the time of the survey. All assumed ACBM should be handled as ACBM unless full testing is performed and the material is found to be non-detect for asbestos. The structure was in current use at the time of the survey and full destructive or exploratory survey methods were not feasible. Please reference the attached methodology and limitations. Lead Paint Screening Based on the type and age of building construction, it is reasonable to assume that various painted surfaces contain some lead. It is not uncommon in buildings such as this and that have had various renovation and upgrades to have both lead containing paint and non-lead containing paint. For the purposes of this survey, RPF collected representative samples for quality control screening for potential waste issues. RPF extracted ten (10) composite suspect paint samples from various interior and exterior building components including the Teen Center kitchen floor, old foundation wall, entry ceiling, exterior windows, 1 Canada Street store exterior siding and interior floor, 3 Canada Street basement stairwell and exterior window sill. The results for the paint chip testing completed during this survey are included in Table 3 of Appendix A. Lead was detected in five of the six samples collected, and ranged from 0.012 to 1.4 percent by weight (%/wt).


Based on this limited testing, it should be assumed that other painted similar surfaces at the site may also contain lead and further testing is recommended in the event that a detailed surface by surface inventory is needed or to confirm any specific surface not included in this screening. Current State of Vermont lead poisoning regulations consider any paint that contains greater than 0.5 percent by weight (0.5 %wt.) to be lead-based paint. However, the intent of this survey was for construction waste purposes in nonresidential settings. In addition, U.S. Occupational Safety and Health Administration (OSHA) construction rules do not specify any "safe" or acceptable levels of lead within paint for the purposes of occupational exposures. Therefore, any surfaces with lead present should be managed in accordance with current rules and guidelines, including but not limited to OSHA worker safety rules and State and EPA waste handling and disposal regulations. Construction work involving paint found to contain lead must be completed in accordance with OSHA regulations, not limited to the lead standard, 29 CFR 1926.62. Contractors completing work in areas found to contain lead, or where it is reasonable to assume lead may be present, should be notified of the presence (and potential presence) of lead and proper work protocols should be used. Proper waste testing with TCLP extraction for lead and potentially other toxic materials should also be completed prior to disposal of any waste generated in accordance with current EPA requirements. Often times it is recommended that pre-demolition TCLP testing be completed such that waste can be segregated as required during demolition activity. TCLP testing should be based on anticipation waste stream results or further LP screening. Construction/demolition waste that is found to contain lead greater or equal to 5.0 milligrams per liter (mg/L) by TCLP analysis must be handled and treated as hazardous waste. PCB Light Ballasts, Fluorescent Bulbs, Mercury Switches PCB or assumed PCB ballasts were observed by RPF throughout the building. For this survey, RPF inventoried representative fluorescent lamps throughout the building. Visual spot checks of accessible fixture ballasts were conducted throughout the survey areas. The ballasts inspected were checked for a “No PCBs” label. Unmarked ballasts and ballasts without date stamps are assumed to be PCB containing. The ballasts in the Municipal Building in what appeared to be several of the older lighting units could not be checked during the survey due to accessibility and it was not feasible to de-energize the systems during the survey. The ballasts should be assumed to contain PCB. The following table is a summary of the ballasts, fluorescent light tubes and other potential hazardous materials observed and approximate quantities.


Location Ballasts Fluorescent Bulbs

Mercury Switches

Other Potential Hazardous Materials

1 Canada St. 48 24 -- --- 3 Canada St. 31 124 -- Solvents, oil, paints 5 Canada St. 10 20 -- --- Apt. 1 & 2 -- -- 9 Refrigerators Memorial Blg 65 80 3 AC unit, Refrigerator, various

paints and electrical components Warehouse building

40 80 ---

With regard to light ballasts, approximately half were manufactured prior to 1979 and nearly all pre-1979 ballasts contain PCBs. Ballasts manufactured after July 1, 1978 and that do not contain PCBs are required to be clearly marked “No PCBs”. Please note that is possible that post 1979 ballasts may contain some PCBs in the capacitor oils and more information should be requested if needed for applicable State and federal agencies. PCBs may also be present in common household appliances with small capacitors and as dielectric fluids other electric equipment such as transformers, switches and voltage regulators. Documentation of current conditions and in-depth hazard assessments is beyond the scope-of-work for this initial survey. PCB and non-PCB ballasts should be segregated and packaged for waste disposal in accordance with State and federal requirements. There is a substantial cost difference for disposal of PCB ballasts versus non-PCB ballasts. It is also recommended that prior to proceeding with site work, it be requested that the Client or Building Owner provide documentation of PCB ballasts removed and replaced in the building, if available. PCB are known to have been used improperly in the manufacturing of various building caulk and paint materials and are highly regulated by the US EPA. RPF performed limited testing of paint and caulking materials for PCB’s. PCBs have been shown to cause chronic toxic effects and are a human carcinogen. PCBs are toxic according to the U.S. EPA and are a regulated material. The two primary federal laws that affect the handling of PCBs are the Toxic Substance Control Act and the Superfund Law (CERCLA). Other regulations include various State requirements, Department of Transportation, U.S. OSHA, and the Resource Conservation and Recovery Act. The regulations establish various requirements for the removal, handling, storage and disposal of PCBs. PCB in Caulking Nine (9) composite samples of building caulking were collected and submitted for analysis to determine PCB content and one duplicate sample for a total of ten (10). These samples were comprised of discrete caulking materials collected from various locations including; exterior store side door, store building seam, Teen Center Auditorium door, 1-5 Canada Street store windows, Teen Center Auditorium windows, interior window caulk at 1 Canada Street and caulk on the interior ceiling at 1 Canada Street. One duplicate sample was also collected of the exterior


auditorium windows. The samples were analyzed by Eastern Analytical, Inc. using EPA Method 8082. All results of the testing were less than the detection limit. PCB-containing caulk is considered PCB bulk product waste if the concentration of PCBs in the caulk is greater than or equal to (>) 50 ppm pursuant to 40 CFR § 761.3. PCB bulk product waste includes waste derived from manufactured products containing PCBs in a non-liquid state where the concentration at the time of designation for disposal is >50 ppm PCBs. The results of the PCB analysis are included in Table 4 of Appendix A. Conclusions Based on the survey findings, the building was found to contain ACBM, LP and other hazardous building material. Damaged ACBM should be repaired and/or removed and appropriate surface decontamination performed by qualified personnel. In accordance with current regulatory requirements, ACBM that may be impacted or disturbed (such that asbestos fiber release occurs) by renovation, demolition or other such activity must be removed by qualified, licensed firms. Although regulations for removal of nonfriable ACBM are somewhat less stringent than the requirements for friable ACBM, it should be noted that nonfriable ACBM that is subjected to grinding, abrasion, and other forces, could be rendered friable. In this event, the nonfriable ACBM would be re-categorized friable ACBM. ACBM that will not be impacted by renovation or demolition activity may be left in place if managed properly and if the materials are maintained in good condition. ACBM to remain in the building should be included in an asbestos management plan and operations and maintenance (O&M) program detailing the measures to be used to safely occupy the building until the ACBM is fully removed. An accredited Management Planner should prepare the O&M Program in accordance with the guidelines set forth in 40 CFR Part 763 (AHERA). Work impacting LP, fluorescent light bulbs, mercury (and potential PCB ballasts) must be performed in accordance with current State and federal standards, including but not limited safe work practices, engineering controls, proper waste packaging, and proper disposal. Work involving LP may require notification of tenants, if rented or leased space, prior to start of work. Sufficiently in advance of the start of renovation and/or remediation work, abatement project design should be completed. As part the initial design steps any planned renovation and demolition activity should be reviewed for potential impact on ACBM. Asbestos removal is highly regulated at the State and federal level, and in some cases, at the local level also. Notification to VT Department of Health is required 10-days prior to the start of interior abatement work and demolition. Only qualified, trained, and licensed firms, as applicable, should be engaged to complete asbestos removal or other abatement activity. Asbestos abatement work must be designed (abatement specifications or work plan prepared) by licensed personnel.


All employees and contractors that may access or otherwise disturb areas with suspect ACBM present should be notified of the presence of ACBM and possible hidden ACBM, and the need to use caution when proceeding with work. Appropriate notifications, labeling and other hazard communications should be completed to all employees, contractors and others in accordance with US OSHA regulations and other applicable requirements (including asbestos labeling in accordance with 29 CFR Part 1926). The scope of RPF services for this survey did not include labeling of ACBM or hazard communications to other employees, building occupants, contractors, or subcontractors. Documentation of current ACBM conditions and in-depth hazard assessment is beyond the scope-of-work for this initial survey. With the exception of the specific testing and analysis detailed herein, no other samples of materials, oil, water, ground water, air, or other suspect hazardous materials were collected in the course of this inspection that supports or denies these conclusions. No additional services beyond those explicitly stated herein were performed and none should be inferred or implied. The summary and conclusions are based on reasonably ascertainable information as described in this report. RPF Environmental, Inc. makes no guarantees, warranties, or references regarding this property or the condition of the property after the period of this report. If you have any questions at this time, or if you would like to discuss the remediation process, please call our office. Sincerely, RPF ENVIRONMENTAL, INC. Kara Forsythe Sr. EH&S Consultant Licensed Inspector AI517212 Enclosures: Appendix A: Data and Analytical Tables Appendix B: Example Pictures Appendix C: Summary of Methodology and Limitations 167604 Swanton VT 120716 Hazmat Rpt

APPENDIX A

TABLE 1

1-5 Canada Street & Municipal Building Lot Swanton, VT

SUMMARY OF ACBM & ASBESTOS IDENTIFIED

Building Material

Location Approximate Quantity

EPA Category Asbestos Results

1 Canada Street Interior Window Caulking

South store front windows 6 windows @36 lf/unit

Category II Nonfriable

Trace Tremolite

Gypsum board with joint compound

Interior walls Category II Nonfriable

Trace Chrysotile

Door Caulk Exterior side door 25 linear feet Category II Nonfriable

2% Chrysotile

Window Caulk Exterior store front windows 6 windows @36 lf/unit


3% Chrysotile

3 Canada Street 9” Floor Tile Entrance to stairwell to

basement (however, additional materials are likely below newer floor coverings)

50 sq. ft. Category I Nonfriable

5% Chrysotile

2x4 Ceiling Tiles Throughout suite 2,500 square feet

Friable 5% Amosite

Gypsum board with joint compound

Throughout suite 1,800 square feet


Trace Chrysotile

Transite Panels Basement, boiler room above boiler

75 square feet Category II Nonfriable

20% Chrysotile

Pipe Fitting Insulation Debris

Basement boiler room 15 fittings, less than 6 square feet

Friable RACM 40% Chrysotile

5 Canada Street Flooring adhesive Assumed to be throughout

space under laminate flooring 1,050 square feet


5% Chrysotile

2nd floor: Canada Street Apartment 1 Door Glaze Apartment vestibule entrance

door 6 linear feet Category II

Nonfriable 3% Chrysotile

Building Seam Caulk Exterior seam joint on vestibule stairwell

20 linear feet Category II Nonfriable

2% Chrysotile

2nd floor: Canada Street Apartment 2 Sink basin undercoat Kitchen 1 sink unit Category II

Nonfriable 6% Chrysotile

BMTM Services Floor tile and mastic Bathroom off warehouse 50 square feet Category II

Nonfriable 4%-5% Chrysotile

Teen Center Airocell Pipe Insulation Basement main room in wall <1 linear feet Friable RACM 40%

Chrysotile Pipe Wrap Basement ladies room and

sprinkler room 16 linear feet Friable RACM 20%

Chrysotile Pipe Insulation Basement sprinjkler room 10 linear feet Friable RACM 15% Amosite

TABLE 1

1-5 Canada Street & Municipal Building Lot Swanton, VT

SUMMARY OF ACBM & ASBESTOS IDENTIFIED

Building Material



Transite Panel Entrance stairwell ceilings and stairs on east and west side of entrance


30% Chrysotile

Exterior Roofing, sealants, flashings

Exterior roofing 1-5 Canada Street and Memorial Hall Building

Unknown Unknown Assumed ACM

Notes:

· Table 1 does not include a listing of all ACBM and suspect ACBM present at the site, only the materials found to be ACBM during the limited testing of this limited survey. Full testing and inspections are required to further identify the types, locations and quantities of ACBM present at this site.

· Please note that Category 1 and Category 2 nonfriable ACM are recategorized as friable and/or RACM under certain conditions. Current State asbestos regulations are more strict and comprehensive than the EPA NESHAPs requirements.

· All quantities are approximate only and should be confirmed during abatement project design and abatement bidding. · It is likely that some concealed or inaccessible ACBM is present. Care should be used when renovating/demolishing

inaccessible building space. Further explorative survey work may be necessary during design and/or in conjunction with demolition.

TABLE 2

SANBORN HEAD & ASSOCIATES INC. 1-3-5 Canada Street, Swanton, VT

Teen Center Polarized Light Microscopy – EPA 600/R-93/116 Method

Samples Collected: December 7, 2016

Notes: · Trace means less than 1%. SFP Means analysis was terminated because asbestos was detected on a previous homogenous

sample during the survey work. Please reference the "HG" group number. · Please reference the full report for discussions and additional information and limitations pertaining to these results.

Page 1 of 2

Sample ID Description Asbestos Content

Asbestos Components

Fibrous Components

Non Fibrous Components

120716-HG 1 Formica with adhesive, grey, teen center, kitchen None Detected 40% Cellulose 60% Other

120715 HG2 Gypsum board ceiling tile, grey, teen center, kitchen bar area None Detected

5% Fiber Glass 10% Cellulose 85% Other

120716-HG 2b Gypsum board ceiling tile, grey, teen center, kitchen bar area None Detected


120716-HG 3 Sink basin mastic, white, teen center, kitchen None Detected 10% Cellulose 90% Other

120716-HG 4 Airocell, grey, main room, wall Positive 40% Chrysotile -- 60% Other

120716-HG 5 Pipe wrap, grey, basement, teen center, ladies room Positive 20% Chrysotile -- 80% Other

120716-HG 5b Pipe wrap, grey, basement, teen center, ladies room *SFP -- --

120716-HG 5c Pipe wrap, grey, basement, teen center, electrical room *SFP -- --

120716-HG 6 Pipe insulation, grey, basement, teen center, sprinkler room Positive 15% Amosite -- 85% Other

120716-HG 6b Pipe insulation, grey, basement, teen center, sprinkler room *SFP -- --

120716-HG, 6c Pipe insulation, grey, basement, teen center, sprinkler room *SFP -- --

120716-HG 7 Caulking, white, basement, teen center, men's bathroom None Detected -- 100% Other

120716-HG 7b Caulking, white, basement, teen center, men's bathroom None Detected -- 100% Other

120716-HG 8 Peg board, brown, basement, teen center, storage room None Detected 98% Cellulose 2% Other

120716-HG 8b Peg board, brown, basement, teen center, music room None Detected 98% Cellulose 2% Other

120716-HG 9 Flu cement, white, basement, teen center, boiler room None Detected -- 100% Other

120716-HG 9b Flu cement, white, basement, teen center, boiler room None Detected -- 100% Other

120716-HG 9c Flu cement, white, basement, teen center, boiler room None Detected -- 100% Other

TABLE 2 (continued)


Teen Center Polarized Light Microscopy – EPA 600/R-93/116 Method




Page 2 of 2


Asbestos Components

Fibrous Components


120716-HG 10 Transite panel, grey, entrance stairwell to teen center Positive 30% Chrysotile -- 70% Other

120716-HG 10b Transite panel, grey, entrance stairwell to teen center *SFP -- --

120716-HG 10c Transite panel, grey, entrance stairwell to teen center *SFP -- --

167604

TABLE 2 (continued)


BMTM Services Polarized Light Microscopy – EPA 600/R-93/116 Method




Page 1 of 2


Asbestos Components

Fibrous Components


120716-HG 100 Textured surfacing, white, 1st floor, BMTM services, employee entrance vestibule None Detected -- 100% Other

120716-HG 100b Textured surfacing, white, 1st floor, BMTM services, employee entrance vestibule None Detected -- 100% Other

120716-HG 100c Textured surfacing, white, 1st floor, BMTM services, employee entrance vestibule None Detected -- 100% Other

120716-HG 101 Gypsum board with joint compound, grey, BMTM services, bathroom None Detected 10% Cellulose 90% Other

120716-HG 101b Gypsum board with joint compound, grey, BMTM services, bathroom None Detected 10% Cellulose 90% Other

120716-HG 101c Gypsum board with joint compound, grey, BMTM services, shipping area None Detected 10% Cellulose 90% Other

120716-HG 101d Gypsum board with joint compound, grey, BMTM services, closet None Detected 10% Cellulose 90% Other

120716-HG 101e Gypsum board with joint compound, grey, BMTM services, Kitchen/office None Detected 10% Cellulose 90% Other

120716-HG 102 2x4 Ceiling tiles, grey, multi indent, older, BMTM services, open warehouse None Detected

45% Cellulose 45% Mineral Wool 10% Other

120716-HG 102b 2x4 Ceiling tiles, grey, multi indent, older, BMTM services, open warehouse None Detected


120716-HG 102c 2x4 Ceiling tiles, grey, multi indent, older, BMTM services, open warehouse None Detected


120716-HG 103-A

12" floor tile, tan, 1st floor, BMTM services, bathroom None Detected -- 100% Other

120716-HG 103-B

Mastic, yellow, 1st floor, BMTM services, bathroom None Detected -- 100% Other

120716-HG 103b-A

12" floor tile, tan, 1st floor, BMTM services, bathroom None Detected -- 100% Other

120716-HG 103b-B

Mastic, yellow, 1st floor, BMTM services, bathroom None Detected -- 100% Other

120716-HG 104 1x1 Ceiling tiles, 1st floor, BMTM services, bathroom off warehouse None Detected 90% Cellulose 10% Other

TABLE 2 (continued)


BMTM Services Polarized Light Microscopy – EPA 600/R-93/116 Method


Notes: · Trace means less than 1%. SFP Means analysis was terminated because asbestos was detected on a previous homogenous sample

during the survey work. Please reference the "HG" group number. · Please reference the full report for discussions and additional information and limitations pertaining to these results.

Page 2 of 2


Asbestos Components

Fibrous Components


120716-HG 104b 1x1 Ceiling tiles, 1st floor, BMTM services, bathroom off warehouse None Detected 90% Cellulose 10% Other

120716-HG 105-A

12" Floor tile, white, BMTM services, bathroom off warehouse None Detected -- 100% Other

120716-HG 105-B

Mastic, yellow, BMTM services, bathroom off warehouse None Detected -- 100% Other

120716-HG 105b-A

12" Floor tile, white, BMTM services, bathroom off warehouse None Detected -- 100% Other

120716-HG 105b-B


120716-HG 106-A

12" Floor tile, purple, BMTM services, bathroom off warehouse None Detected -- 100% Other

120716-HG 106-B


120716-HG 106b-A

12" Floor tile, purple, BMTM services, bathroom off warehouse None Detected -- 100% Other

120716-HG 106b-B


120716-HG 107-A

Flooring, pink, BMTM services, bathroom off warehouse under HG 105/106 Positive

4% Chrysotile -- 96% Other

120716-HG 107-B

Mastic, BMTM services, bathroom off warehouse under HG 105/106 Positive

5% Chrysotile -- 95% Other

120716-HG 107b-A

Flooring, pink, BMTM services, bathroom off warehouse under HG 105/106 *SFP -- --

120716-HG 107b-B

Mastic, BMTM services, bathroom off warehouse under HG 105/106 *SFP -- --

120716-HG 108-A

12" Floor tile, blue, BMTM services, base of stairs in warehouse None Detected -- 100% Other

120716-HG 108-B

Mastic, BMTM services, base of stairs in warehouse None Detected -- 100% Other

120716-HG 108b-A

12" Floor tile, blue, BMTM services, base of stairs in warehouse None Detected -- 100% Other

120716-HG 108b-B

Mastic, BMTM services, base of stairs in warehouse None Detected -- 100% Other

167604

TABLE 2 (continued)

SANBORN HEAD & ASSOCIATES INC. 5 Canada Street, Swanton, VT

Polarized Light Microscopy – EPA 600/R-93/116 Method




Page 1 of 1


Asbestos Components

Fibrous Components


120716-HG 200 Gypsum board with joint compound, grey, 5 Canada Street, rest room, wall None Detected 15% Cellulose 85% Other

120716-HG 200b Gypsum board with joint compound grey, 5 Canada Street, main area entrance, wall None Detected 15% Cellulose 85% Other

120716-HG 200c Gypsum board with joint compound, grey, 5 Canada Street, entrance, wall None Detected 15% Cellulose 85% Other

120716-HG 201 Gypsum board ceiling tiles, grey, 5 Canada Street, Main area None Detected


120716-HG 201b Gypsum board ceiling tiles, grey, 5 Canada Street, Main area None Detected


120716-HG 201c Gypsum Board ceiling tiles, grey, 5 Canada Street Main area None Detected


120716-HG 202 Ceramic tile grout, grey, 5 Canada Street, Main area None Detected -- 100% Other

120716-HG 202b Ceramic tile grout, grey, 5 Canada Street, Main area None Detected -- 100% Other

120716-HG 203 Flooring adhesive, yellow, 5 Canada Street, back hallway Positive 5% Chrysotile -- 95% Other

120716-HG 203b Flooring adhesive, yellow, 5 Canada Street, back hallway *SFP -- --

167604

TABLE 2 (continued)





sample during the survey work. Please reference the "HG" group number. · Please reference the full report for discussions and additional information and limitations pertaining to these results. · 3% Chrysotile found in Joint Compound Layer of sample 120716-HG306b

Page 1 of 2


Asbestos Components

Fibrous Components


120716-HG 300 Linoleum, tan, green, bathroom None Detected 20% Cellulose 80% Other 120716-HG 300b Linoleum, tan, green, bathroom None Detected 20% Cellulose 80% Other 120716-HG 301 1x1 ceiling tiles, tan, main area None Detected 85% Cellulose 15% Other 120716-HG 301b 1x1 ceiling tiles, tan, main area None Detected 85% Cellulose 15% Other 120716-HG 302 1x1 ceiling tiles, tan, main area None Detected 85% Cellulose 15% Other 120716-HG 302b 1x1 ceiling tiles, tan, main area None Detected 85% Cellulose 15% Other 120716-HG 303-A Flooring, white, main area north end None Detected -- 100% Other 120716-HG 303-B Mastic, yellow, main area north end None Detected -- 100% Other 120716-HG 303b-A Flooring, white, main area north end None Detected -- 100% Other 120716-HG 303b-B Mastic, yellow, main area north end None Detected -- 100% Other 120716-HG 304-A Mastic, yellow, south end None Detected -- 100% Other 120716-HG 304-B Flooring, south end None Detected -- 100% Other 120716-HG 304-C Mastic, mixed, south end None Detected 2% Cellulose 98% Other 120716-HG 304b-A Mastic, yellow, south end None Detected -- 100% Other 120716-HG 304b-B Flooring, grey, south end None Detected -- 100% Other 120716-HG 304b-C Mastic, mixed, south end None Detected -- 100% Other

120716-HG 305 Caulk, grey, south windows Positive Trace Tremolite -- 100% Other

120716-HG 305b Caulk, grey, south windows Positive Trace Tremolite -- 100% Other

120716-HG 306 Gypsum wallboard with joint compound, north wall None Detected 15% Cellulose

30% Other 55% Gypsum

TABLE 2 (continued)






Page 2 of 2


Asbestos Components

Fibrous Components


120716-HG 306b Gypsum wallboard with joint compound, east wall Positive

Trace Chrysotile 15% Cellulose


120716-HG 306c Gypsum wallboard with joint compound, west wall None Detected 15% Cellulose


120716-HG 307 Floor tile with mastic, bathroom, under HG 300 None Detected -- 100% Other

120716-HG 307b Floor tile with mastic, bathroom, under HG 300 None Detected -- 100% Other

120716-HG 308 Homosote board, brown, north east window counter room None Detected 90% Cellulose 10% Other

120716-HG 308b Homosote board, brown, north east window counter room None Detected 90% Cellulose 10% Other

120716-HG 309 Flooring mastic, black, north east hall outside bathroom None Detected -- 100% Other

120716-HG 309b Flooring mastic, black, north east hall outside bathroom None Detected -- 100% Other

120716-HG 310 Caulking, white, ceiling, north east room across from bathroom None Detected -- 100% Other

120716-HG 310b Caulking, white, ceiling, north east room across from bathroom None Detected -- 100% Other

167604

TABLE 2 (continued)





sample during the survey work. Please reference the "HG" group number. · Please reference the full report for discussions and additional information and limitations pertaining to these results. · 2% Chrysotile found in Joint Compound Layer of sample 120716-HG406, 120716-HG406b and 120716HG406c

Page 1 of 2


Asbestos Components

Fibrous Components


120716 HG 400-A

9" Floor tile, grey, 3 Canada St at entrance to basement Positive 5% Chrysotile -- 95% Other

120716 HG 400-B Mastic, black, 3 Canada St at entrance to basement None Detected -- 100% Other

120716 HG 400b-A

9" Floor tile, grey, 3 Canada St at entrance to basement *SFP -- --

120716 HG 400b-B

Mastic, black, 3 Canada St at entrance to basement None Detected -- 100% Other

120716 HG 401-A

12" Floor tile, grey/tan, 3 Canada St at carpet storage room None Detected -- 100% Other

120716 HG 401-B Mastic, 3 Canada St at carpet storage room None Detected -- 100% Other 120716 HG 401b-A

12" Floor tile, grey/tan, 3 Canada St at carpet storage room None Detected -- 100% Other

120716 HG 401b-B Mastic, 3 Canada St at carpet storage room None Detected -- 100% Other

120716 HG 402 Pegboard, brown, 3 Canada St carpet storage wall None Detected 98% Cellulose 2% Other

120716 HG 403 Dairy board, white, 3 Canada St carpet storage None Detected 30% Fiber Glass 70% Other 120716 HG 403b Dairy board, white, 3 Canada St carpet storage None Detected 30% Fiber Glass 70% Other

120716 HG 404 Blown-in insulation, 3 Canada St, above 2x4 ceiling tiles, carpet storage None Detected 98% Cellulose 2% Other

120716 HG 404b Blown-in insulation, 3 Canada St, above 2x4 ceiling tiles, carpet storage None Detected 98% Cellulose 2% Other

120716 HG 404c Blown-in insulation, 3 Canada St, above 2x4 ceiling tiles, carpet storage None Detected 98% Cellulose 2% Other

120716 HG 405 2x4 ceiling tiles, grey, multi indent, 3 Canada St, carpet storage room Positive 5% Amosite

20% Cellulose 40% Fiber Glass

15% Other 20% Perlite

120716 HG 405b 2x4 ceiling tiles, grey, multi indent, 3 Canada St, carpet storage room *SFP -- --

120716 HG 406 Gypsum board with joint compound*, grey, 3 Canada St, basement stairwell, wall Positive

Trace Chrysotile 10% Cellulose 90% Other

120716 HG 406b Gypsum board with joint compound*, grey, 3 Canada St, carpet storage, wall Positive


TABLE 2 (continued)






Page 2 of 2


Asbestos Components

Fibrous Components


120716 HG 406c Gypsum board with joint compound*, grey, 3 Canada St, 2nd floor, office Positive


120716 HG 407 Plaster, grey, 3 Canada St, basement, NE wall by stairwell None Detected 5% Cellulose 95% Other

120716 HG 407b Plaster, grey, 3 Canada St, basement, NE wall by stairwell None Detected 5% Cellulose 95% Other

120716 HG 407c-A-Texture

Plaster, grey, 3 Canada St, basement, NE wall by stairwell None Detected -- 100% Other

120716 HG 407c-B-Plaster

Plaster, grey, 3 Canada St, basement, NE wall by stairwell None Detected 5% Cellulose 95% Other

120716 HG 408 Boiler insulation, grey, 3 Canada St, basement, boiler room None Detected

10% Mineral Wool 90% Other

120716 HG 408b Boiler insulation, grey, 3 Canada St, basement, boiler room None Detected


120716 HG 408c Boiler insulation, grey, 3 Canada St, basement, boiler room None Detected


120716 HG 409 Transite panels, grey, 3 Canada St, basement, boiler room above boiler Positive 20% Chrysotile -- 80% Other

120716 HG 409b Transite panels, grey, 3 Canada St, basement, boiler room above boiler *SFP -- --

120716, HG 410 Fitting Insulation debris, grey, 3 Canada St, basement Positive 40% Chrysotile -- 60% Other

120716 HG 410b Fitting Insulation debris, grey, 3 Canada St, basement *SFP -- --

120716 HG 411-A

Linoleum, pebble pattern, 3 Canada St, 1st floor, bathroom None Detected

15% Synthetic Fibers 85% Other

120716 HG 411- B Mastic, 3 Canada St, 1st floor, bathroom None Detected -- 100% Other 120716 HG 411b-A

Linoleum, pebble pattern, 3 Canada St, 1st floor, bathroom None Detected


120716 HG 411b-B Mastic, 3 Canada St, 1st floor, bathroom None Detected -- 100% Other 167604

TABLE 2 (continued)


2nd Floor Apartment 1 Polarized Light Microscopy – EPA 600/R-93/116 Method




Page 1 of 2


Fibrous Components


120716 HG 500-A Linoleum, tan with flower, 2nd floor, kitchen None Detected 30% Cellulose 70% Other 120716 HG 500- B Mastic, 2nd floor, kitchen None Detected 100% Other 120716 HG 500b-A Linoleum, tan with flower, 2nd floor, kitchen None Detected 30% Cellulose 70% Other 120716 HG 500b-B Mastic, 2nd floor, kitchen None Detected 100% Other 120716 HG 501 Linoleum, tan with flower, 2nd floor, bath None Detected 30% Cellulose 70% Other 120716 HG 501b-A Linoleum, tan with flower, 2nd floor, bath None Detected 30% Cellulose 70% Other 120716 HG 501b-B Mastic, 2nd floor, bath None Detected 100% Other

120716 HG 502 Textured surfacing, white, 2nd floor, apartment 1, bathroom, walls None Detected 3% Cellulose

20% Perlite 77% Other

120716 HG 502b Textured surfacing, white, 2nd floor, apartment 1, bathroom, walls None Detected 3% Cellulose


120716 HG 502c Textured surfacing, white, 2nd floor, apartment 1, bathroom, walls None Detected 3% Cellulose 97% Other

120716 HG 503 1x1 ceiling tiles, tan, 2nd floor apartment 1, bathroom None Detected 95% Cellulose 5% Other 120716 HG 503b 1x1 ceiling tiles, tan, 2nd floor, apartment 1, kitchen None Detected 95% Cellulose 5% Other

120716 HG 504 Gypsum board with joint compound, 2nd floor, apartment 1, bedroom 2 None Detected 10% Cellulose 90% Other

120716 HG 504b Gypsum board with joint compound, 2nd floor, apartment 1, bedroom 1 None Detected 10% Cellulose 90% Other

120716 HG 504c Gypsum board with joint compound, 2nd floor, apartment 1, living room None Detected 10% Cellulose 90% Other

120716 HG 505 Homosote board, brown, 2nd floor, apartment, kitchen None Detected 95% Cellulose 5% Other 120716 HG 505b Homosote board, brown, 2nd floor, apartment, kitchen None Detected 95% Cellulose 5% Other

120716 HG 506 Plaster, grey, kitchen closet, 2nd floor, apartment 1 wall None Detected 30% Perlite 70% Other

TABLE 2 (continued)






Page 2 of 2


Fibrous Components


120716 HG 506b Gypsum board, grey, kitchen closet, 2nd floor, apartment 1 wall None Detected 15% Cellulose 85% Other

120716 HG 506c-A-Grey layer Plaster, grey, kitchen closet, 2nd floor, apartment 1 wall None Detected


120716 HG 506c-B-White layer Plaster, grey, kitchen closet, 2nd floor, apartment 1 wall None Detected 5% Hair


120716 HG 507 Sink basin undercoat, white, 2nd floor, apartment 1 kitchen None Detected 100% Other

120716 HG 507b Sink basin undercoat, white, 2nd floor, apartment 1 kitchen None Detected 100% Other

120716 HG 508 Carpet mastic, yellow, 2nd floor, apartment 1, bedroom 1 None Detected 100% Other 120716 HG 508b Carpet mastic, yellow, 2nd floor, apartment 1, bedroom 3 None Detected 100% Other

167604

TABLE 2 (continued)






Page 1 of 1


Asbestos Components

Fibrous Components


120716 HG 600 1x1 ceiling tiles, tan, 2nd floor, apartment 2, kitchen None Detected 90% Cellulose 10% Other

120716 HG 600b 1x1 ceiling tiles, tan, 2nd floor, apartment 2, kitchen None Detected 90% Cellulose 10% Other

120716 HG 601 Carpet mastic, yellow, 2nd floor, apartment 2, living room None Detected -- 100% Other

120716 HG 601b Carpet mastic, yellow, 2nd floor, apartment 2, living room None Detected -- 100% Other

120716 HG 602 Linoleum, tan and brown, 2nd floor, apartment 2, kitchen None Detected 30% Cellulose 70% Other

120716 HG 602b Linoleum, tan and brown, 2nd floor, apartment 2, kitchen None Detected 30% Cellulose 70% Other

120716 HG 603 Linoleum, tan and brown, 2nd floor, apartment 2, bathroom None Detected 30% Cellulose 70% Other

120716 HG 603b Linoleum, tan and brown, 2nd floor, apartment 2, bathroom None Detected 30% Cellulose 70% Other

120716 HG 604 Paneling adhesive, tan, 2nd floor, apartment 2, kitchen None Detected -- 100% Other

120716 HG 604b Paneling adhesive, tan, 2nd floor, apartment 2, kitchen None Detected -- 100% Other

120716 HG 605 Sink basin undercoat, black, 2nd floor, kitchen Positive 6% Chrysotile -- 94% Other 120716 HG 605b Sink basin undercoat, black, 2nd floor, kitchen *SFP -- --

120716 HG 606 Gypsum board with joint compound, grey, 2nd floor, apartment 2, kitchen None Detected 10% Cellulose 90% Other

120716 HG 606b Gypsum board with joint compound, grey, 2nd floor, apartment 2, bathroom None Detected 10% Cellulose 90% Other

167604

TABLE 2 (continued)

SANBORN HEAD & ASSOCIATES INC. Exterior





Page 1 of 1


Asbestos Components

Fibrous Components


120716 HG 700 Door glaze, tan, apartment stairwell, vestibule Positive 3% Chrysotile -- 97% Other 120716 HG 700b Door glaze, tan, apartment stairwell, vestibule *SFP -- -- 120716 HG 701 Door caulk, tan, exterior side door Positive 2% Chrysotile -- 98% Other 120716 HG 701b Door caulk, tan, exterior side door *SFP -- --

120716 HG 702 Siding paper, black, exterior 1-5 Canada Street residential structure None Detected 70% Cellulose 30% Other

120716 HG 702b Siding paper, black, exterior 1-5 Canada Street residential structure None Detected 70% Cellulose 30% Other

120716 HG 703 Siding paper, brown, exterior 1-5 Canada Street residential structure None Detected 95% Cellulose 5% Other

120716 HG 703b Siding paper, brown, exterior 1-5 Canada Street residential structure None Detected 95% Cellulose 5% Other

120716 HG 704 Window caulk, white, 1 Canada Street, storefront windows Positive 3% Chrysotile -- 97% Other

120716 HG 704b Window caulk, white, 1 Canada Street, storefront windows *SFP -- --

120716 HG 705 Building seam caulk, tan, exterior stairwell, vestibule Positive 2% Chrysotile -- 98% Other

120716 HG 705b Building seam caulk, tan, exterior stairwell, vestibule *SFP -- --

120716 HG 706 Asphalt shingles, black, 1 Canada Street, exterior roof None Detected 5% Fiber Glass 95% Other

120716 HG 706b Asphalt shingles, black, 1 Canada Street, west side, exterior lower roof None Detected 5% Fiber Glass 95% Other

120716 HG 707 Door caulk, white, Exterior Teen Center, auditorium door None Detected -- 100% Other

120716 HG 707b Door caulk, white, Exterior Teen Center, auditorium door None Detected -- 100% Other

120716 HG 708 Window caulk, grey, Exterior teen center, auditorium windows None Detected -- 100% Other

120716 HG 708b Window caulk, grey, Exterior teen center, auditorium windows None Detected -- 100% Other

167604

TABLE 2 (continued)

SANBORN HEAD & ASSOCIATES INC. Duplicate Samples

Swanton, VT Polarized Light Microscopy – EPA 600/R-93/116 Method




Page 1 of 1


Asbestos Components

Fibrous Components


120716 HG 800

Window caulk, white, Teen Center, men’s bathroom (duplicate 120716 HG 7) None Detected -- 100% Other

120716 HG 801

1x1 Ceiling tiles, tan, BMTM Services, bathroom off warehouse (120716 HG 104) None Detected 85% Cellulose 15% Other

120716 HG 802 Gypsum board, 1 Canada Street, north wall (duplicate 120716 HG 306) None Detected 30% Cellulose


120716 HG 803

Peg board, brown, 3 Canada Street, carpet storage wall (duplicate 120716 HG 402) None Detected 85% Cellulose 15% Other

120716 HG 804 - A

Linoleum, tan and brown, 2nd floor apartment 2 bathroom (duplicate 120716 HG 602) None Detected 20% Cellulose 80% Other

120716 HG 804 - B Linoleum, tan and brown, 2nd floor, apartment 2 bathroom None Detected -- 100% Other

120716 HG 805 - A

Floor tile, grey, 3 Canada Street, entrance to basement (duplicate 120716 HG 400) Positive 4% Chrysotile -- 96% Other

120716 HG 805 – B Mastic

Flooring mastic, black, 3 Canada Street, entrance to basement (duplicate 120716 HG 400) None Detected -- 100% Other

120716 HG 806

Window caulk, grey, exterior Teen Center, auditorium windows (duplicate 120716 HG 708) None Detected -- 100% Other

120716 HG 807

Siding paper, black, exterior 1-5 Canada Street, residential structure (duplicate 120716 HG 702) None Detected 60% Cellulose 40% Other

120716 HG 808

Door Glaze, tan, 1-5 Canada Street apartment stairwell vestibule (duplicate 120716 HG 700) Positive 3% Chrysotile -- 97% Other

120716 HG 809

Building Seam Caulk, tan, 1-5 Canada Street residential apartment vestibule stairwell (duplicate 120716 HG 705) Positive 4% Chrysotile -- 96% Other

167604

Note: OSHA does not currently establish an acceptable concentration of lead in paint. The purposes of this test is for construction/demolition waste only and does not include LBP inspection or risk assessment.

TABLE 3


SUMMARY OF BULK SAMPLE RESULTS Lead Analysis in Paint by Flame AAS (SW 846 3050B and 7420)

Sample Collected: December 7, 2016

Sample ID Description Lead Result

120716-LP1 Paint, tan, Teen Center, kitchen, floor <0.007%

120716-LP3 Paint, green, Teen Center, old foundation wall 0.061%

120716-LP4 Paint, light brown, ceiling at entry, Teen Center 0.14%

120716-LP5 Paint, yellow /grey, Teen Center kitchen 0.012%

120716-LP6 Paint, white/grey, BMTM service <0.005%

120716-LP7 Paint, red/white, Store, exterior 1-5 Canada Street <0.007%

120716-LP8 Paint, white/black/pink, floor, 1 Canada Street 1.1%

120716-LP9 Paint, brown, 3 Canada Street, stairwell to basement 1.4%

120716-LP10 Paint, yellow, 3 Canada Street, stairwell to basement 0.051%

120716-LP2 Paint, white, 2nd Floor, window sill, 3 Canada Street <0.006%

167604

TABLE 4


Preliminary Analytical Results

For Polychlorinated Biphenyls (PCBs)


Sample ID

Description PCB-1016 (mg/kg)

PCB-1221 (mg/kg)

PCB-1232 (mg/kg)

PCB-1242 (mg/kg)

PCB-1248 (mg/kg)

PCB-1254 (mg/kg)

PCB-1260 (mg/kg)

PCB-1262 (mg/kg)

PCB-1268 (mg/kg)

120716-01 Exterior Store, side door <0.3 <0.3 <0.3 <0.3 <0.3 <0.3 <0.3 <0.3 <0.3 120716-02 Exterior Store, Blg seam <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 120716-03 Teen Center, Auditorium door <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 120716-04 Teen Center, store windows <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2

120716-05 Teen Center, auditorium window, exterior <0.3 <0.3 <0.3 <0.3 <0.3 <0.3 <0.3 <0.3 <0.3

120716-06 Interior, caulk, store #1 front <0.3 <0.3 <0.3 <0.3 <0.3 <0.3 <0.3 <0.3 <0.3 120716-07 Interior, caulk, ceiling, unit #1 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2

120716-08 Teen Center, auditorium

window, exterior (Duplicate #5)

<0.3 <0.3 <0.3 <0.3 <0.3 <0.3 <0.3 <0.3 <0.3

167604 120716 PCB tbl Notes: · Results are presented as milligrams per kilogram (mg/kg) · Samples were analyzed per EPA Method 8082A

APPENDIX B

EXAMPLE PICTURES

Site Address: Sanborn Head & Associates Swanton, VT

www.airpf.com 888-SAFE AIR File No. 167604

1. Exterior view of the Teen Center 2. Example of the airocell pipe insulation in the Teen Center wall

3. Example of the ballast in the Teen Center, no PCB free label 4. Pipe wrap and pipe insulation

5. ACBM transite panels in the stairwell of teen center 6. Teen Center cans of paints and solvents.

EXAMPLE PICTURES



7. Warehouse at BMTM Services 8. Transite panels above the boiler in the basement of 3 Canada

9. 3 Canada St Debris of pipe fittings 10. 5 Canada Street, assumed ACBM flooring underneath laminate

11. 5 Canada Street interior window caulk, trace tremolite 12. 5 Canada LP on the floor inside the former store

EXAMPLE PICTURES



13. Building seam caulk in the vestibule stairwell to the apartment 14. 3 Canada Street ACBM 9” Flooring at basement

15. Apartment Vestibule ACBM Door Glaze 16. Exterior view of 1-5 Canada Street

17. 1-5 Canada Street, snow covered roofing locations material is assumed to be ACBM 18. 3 Canada Street ACBM ceiling tiles present. Possible older

flooring underneath newer flooring as well.

APPENDIX C

Summary of Methodology: Asbestos-Containing Building Materials Survey EPA accredited inspector(s) surveyed accessible space in the building or site areas included within the RPF Scope of Work (SOW) to identify suspect asbestos-containing building material (ACBM). Suspect ACBM was inventoried and categorized into homogeneous groups of materials. To the extent indicated in the report, samples were then extracted from the different groups of homogeneous materials in accordance with applicable State and federal rules and regulations. For surveys in which the SOW included full inspections of the affect space, sampling methodologies were based on the requirements set forth in 40 CFR Part 763 (EPA) and 29 CFR Part 1926.1101 (OSHA). For preliminary or limited surveys, findings apply to only the affected material or space as indicated in the RPF SOW and Report and additional inspection and testing will be required to satisfy regulatory obligations associated with renovation, demolition, maintenance and other occupational safety and health requirements. Collected samples were individually placed into sealed containers, labeled, and submitted with proper chain of custody forms to the RPF NVLAP-accredited vendor laboratory. Sample containers and tools were cleaned after each sample was collected. Samples were analyzed for asbestos content using polarized light microscopy (PLM). Although PLM is the method currently recognized in State and federal regulations for asbestos identification in bulk samples, PLM may not be sensitive enough to detect all of the asbestos fibers in certain types of materials, such as floor tile and other nonfriable ACBM. In the event that more definitive results are requested in cases of with negative or trace results of asbestos are detected, RPF recommends that confirmation testing be completed using transmission electron microscopy. For each homogeneous group of suspect material, a “stop at first positive” (SFP) method may have been employed during the analysis. The SFP method is based on current EPA sampling protocols and means that if one sample within a homogeneous group of suspect material is found to contain >1% asbestos, then further analysis of that specific homogenous group samples is terminated and the entire homogeneous group of material is considered to be ACBM regardless of the other sample results. This is based on the potential for inconsistent mix of asbestos in the product yielding varying findings across the different individual samples collected from the same homogeneous group. Unless otherwise noted in the report, sample groups found to have 1% to <10% asbestos content are assumed to be ACBM; to rebut this assumption further analysis with point count methods are required. Inaccessible and hidden areas, including but not limited to wall/floor/ceiling cavity space, space with obstructed access (such as fiberglass insulation above suspended ceilings), sub floors, interiors of mechanical and process equipment, and similar spaces were not included in the inspection and care should be used when accessing these areas in the future. Unless otherwise noted in the RPF Report, destructive survey techniques were not employed during this survey. In the event that additional suspect materials are encountered that are not addressed in this report, the materials should be properly tested by an accredited inspector. For example, during renovation and demolition it is likely that additional suspect material will be encountered and such suspect materials should be assumed to be hazardous until proper inspection and testing occurs. RPF followed applicable industry standards; however, various assumptions and limitations of the methods can result in missed materials or misidentification of materials due several factors including but not limited to: inaccessible space due to physical or safety constraints, space that is difficult to reach to fully inspection, assumptions regarding the determination of homogenous groups of suspect material, assumptions regarding attempts to conduct representative sampling, and potential for varying mixtures and layers of material sampled not being representative of all areas of similar material. Also reference the Limitations document attached to the report.

Summary of Methodology: Lead in Paint Survey Screening for lead in paint (LP) was performed using bulk sampling of paint or using an X-Ray Fluorescence (XRF) meter for in situ measurements of various painted surfaces. For bulk sampling, samples for determinations were collected by scraping lead paint chips from the substrate. The surveyor attempted to sample layers of paint down to the substrate surface at each sample location. Samples were placed into proper sample containers, the containers were then sealed, labeled and shipped with chain of custody to the RPF AIHA accredited vendor laboratory. The samples were analyzed for total lead content using SW 846 3050B - NIOSH Method 7420. For XRF screening, the device was used and calibrated in accordance with the equipment and industry guidelines applicable for the specific testing performed. Unless specific TCLP waste characterizations were included in the RPF Scope of Work (SOW), further analysis of waste streams for toxicity characteristics including, but not necessarily limited to lead, may be required prior to disposal of the waste stream. Other toxics may also be present including other heavy metals and PCBs and it may also be necessary to conduct waste characterization for these materials. Sampling was limited to the specific components as listed in the RPF Report and testing and survey was not completed on every different surface in every room or area in the building. In addition unless otherwise noted in the RPF Report, surface dust, air and soil testing were not conducted during this survey. In order to conduct thorough hazard assessments for lead exposures, representative surface dust testing and air monitoring throughout the building, LBP testing of all surfaces in the building, and representative soil testing in the exterior areas should be completed. This type of testing and analysis was beyond the SOW for the initial survey The intent of this survey is for lead in construction purposes, not for lead abatement, lead inspections, or lead hazard assessments in residential situations. Specific survey and inspection protocols are required for residential lead-based paint inspections that were not included in the RPF SOW. RPF followed applicable industry standards for construction related identification in nonresidential settings; however, RPF does not warrant or certify that all lead or other hazardous materials in or on the building has been identified and included in this report. Various assumptions and limitations of the methods can result in missed materials or misidentification of materials due several factors including but not limited to: inaccessible space due to physical or safety constraints, space that is difficult to reach to inspect of sample, assumptions regarding the determination of homogenous or like types of paint, assumptions regarding attempts to conduct representative sampling, and potential for varying mixtures and layers of material sampled not being representative of all areas of similar appearing material. Also reference the Limitations document attached to the report.

Summary of Methodology: Polychlorinated Biphenyls, Mercury and Refrigerants Various, accessible fluorescent light fixtures were inspected to determine if the ballasts contain a “No PCBs” label. Ballasts that do not have the “No PCBs” label are assumed to contain PCB. Only limited fixtures were checked based on accessibility and safety concerns. Further inspection will be required during the course of construction, maintenance, renovation and demolition. Various equipment and machinery within the building may also contain PCB oils. Specific findings relating to such equipment and machinery were not included in the RPF SOW. It is common to find fluorescent light bulbs, thermostats and switches are present in buildings. RPF performed a visual inspection of specific areas included in the RPF SOW in an attempt to identify such materials. Findings are limited to the specific accessible space accessed by RPF. Various compressor and refrigerant equipment may be present and is should be assumed that such equipment contains Freon or other chlorofluorocarbons unless otherwise tested or documented. Although general comment may be provided in the RPF Report, the specific identification of all potential Freon and CFCs is not included in the RPF SOW. The findings may or may not be fully representative of all of the entire building. Confirmation testing and analysis of PCB, refrigerants and mercury was not included in the RPF SOW. RPF followed applicable industry standards; however, RPF does not warrant or certify that all hazardous material in or on the building has been identified and included in this report. Various assumptions and limitations of the methods can result in missed materials or misidentification of materials due several factors including but not limited to: inaccessible space due to physical or safety constraints, space that is difficult to reach to fully inspection, electrical safety considerations, and assumptions relating to areas or material being representative of other locations which in fact may not be representative. Also reference the Limitations document attached to the report.

LIMITATIONS

1. The observations and conclusions presented in the Report were based solely upon the services described herein, and not on scientific tasks or procedures beyond the RPF Environmental, Inc. Scope of Work (SOW) as discussed in the proposal and/or agreement. The conclusions and recommendations are based on visual observations and testing, limited as indicated in the Report, and were arrived at in accordance with generally accepted standards of industrial hygiene practice and asbestos professionals. The nature of this survey or monitoring service was limited as indicated herein and in the report or letter of findings. Further testing, survey, and analysis is required to provide more definitive results and findings.

2. For site survey work, observations were made of the designated accessible areas of the site as indicated in

the Report. While it was the intent of RPF to conduct a survey to the degree indicated, it is important to note that not all suspect ACBM material in the designated areas were specifically assessed and visibility was limited, as indicated, due to the presence of furnishings, equipment, solid walls and solid or suspended ceilings throughout the facility and/or other site conditions. Asbestos or hazardous material may have been used and may be present in areas where detection and assessment is difficult until renovation and/or demolition proceeds. Access and observations relating to electrical and mechanical systems within the building were restricted or not feasible to prevent damage to the systems and minimize safety hazards to the survey team.

3. Although assumptions may have been stated regarding the potential presence of inaccessible or concealed

asbestos and other hazardous material, full inspection findings for all asbestos and other hazardous material requires the use of full destructive survey methods to identify possible inaccessible suspect material and this level of survey was not included in the SOW for this project. For preliminary survey work, sampling and analysis as applicable was limited and a full survey throughout the site was not performed. Only the specific areas and /or materials indicated in the report were included in the SOW. This inspection did not include a full hazard assessment survey, full testing or bulk material, or testing to determine current dust concentrations of asbestos in and around the building. Inspection results should not be used for compliance with current EPA and State asbestos in renovation/demolition requirements unless specifically stated as intended for this use in the RPF report and considering the limitations as stated therein and within this limitations document.

4. Where access to portions of the surveyed area was unavailable or limited, RPF renders no opinion of the condition and assessment of these areas. The survey results only apply to areas specifically accessed by RPF during the survey. Interiors of mechanical equipment and other building or process equipment may also have asbestos and other hazardous material present and were not included in this inspection. For renovation and demolition work, further inspection by qualified personnel will be required during the course of construction activity to identify suspect material not previously documented at the site or in this survey report. Bordering properties were not investigated and comprehensive file review and research was not performed.

5. For lead in paint, observations were made of the designated accessible areas of the site as indicated in the Report. Limited testing may have been performed to the extent indicated in the text of the report. In order to conduct thorough hazard assessments for lead exposures, representative surface dust testing, air monitoring and other related testing throughout the building, should be completed. This type of in depth testing and analysis was beyond the scope of services for the initial inspection. For lead surveys with XRF readings, it is recommended that surfaces found to have LBP or trace amount of lead detected with readings of less than 4 mg/cm2 be confirmed using laboratory analysis if more definitive results are required. Substrate corrections involving destructive sampling or damage to existing surfaces (to minimize XRF read-through) were not completed. In some instances, destructive testing may be required for more accurate results. In addition, depending on the specific thickness of the paint films on different areas of a building component, differing amounts of wear, and other factors, XRF readings can vary slightly, even on the same building component. Unless otherwise specifically stated in the scope of services and final report, lead testing performed is not intended to comply with other state and federal regulations pertaining to childhood lead poisoning regulations.

RPF Service Limitations (cont.)

6. Air testing is to be considered a “snap shot” of conditions present on the day of the survey with the understanding that conditions may differ at other times or dates or operational conditions for the facility. Results are also limited based on the specific analytical methods utilized. For phase contrast microscopy (PCM) total airborne fiber testing, more sensitive asbestos-specific analysis using transmission electron microscopy (TEM) can be performed upon request.

7. For asbestos bulk and dust testing, although polarize light microscopy (PLM) is the method currently

recognized in State and federal regulations for asbestos identification in bulk samples, some industry studies have found that PLM may not be sensitive enough to detect all of the asbestos fibers in certain nonfriable material, vermiculate type insulation, soils, surface dust, and other materials requiring more sensitive analysis to identify possible asbestos fibers. In the event that more definitive results are requested, RPF recommends that confirmation testing be completed using TEM methods or other analytical methods as may be applicable to the material. Detection of possible asbestos fibers may be made more difficult by the presence of other non-asbestos fibrous components such as cellulose, fiber glass, etc., by binder/matrix materials which may mask or obscure fibrous components, and/or by exposure to conditions capable of altering or transforming asbestos. PLM can show significant bias leading to false negatives and false positives for certain types of materials. PLM is limited by the visibility of the asbestos fibers. In some samples the fibers may be reduced to a diameter so small or masked by coatings to such an extent that they cannot be reliably observed or identified using PLM.

8. For hazardous building material inspection or survey work, RPF followed applicable industry standards; however, RPF does not warrant or certify that all asbestos or other hazardous materials in or on the building has been identified and included in this report. Various assumptions and limitations of the methods can result in missed materials or misidentification of materials due to several factors including but not limited to: inaccessible space due to physical or safety constraints, space that is difficult to reach to fully inspect, assumptions regarding the determination of homogenous groups of suspect material, assumptions regarding attempts to conduct representative sampling, and potential for varying mixtures and layers of material sampled not being representative of all areas of similar material.

9. Full assessments often requires multiple rounds of sampling over a period of time for air, bulk material, surface dust and water. Such comprehensive testing was beyond the scope of RPF services. In addition clearance testing for abatement, as applicable, was based on the visual observations and limited ambient area air testing as indicated in the report and in accordance with applicable state and federal regulations. The potential exists that microscopic surface dust remains with contaminant present even in the event that the clearance testing meets the state and federal requirements. Likewise for building surveys, visual observations are not sufficient alone to detect possible contaminant in settled dust. Unless otherwise specifically indicated in the report, surface dust testing was not included in the scope of the RPF services.

10. For abatement or remediation monitoring services: RPF is not responsible for observations and test for

specific periods of work that RPF did not perform full shift monitoring of construction, abatement or remediation activity. In the event that problems occurred or concerns arouse regarding contamination, safety or health hazards during periods RPF was not onsite, RPF is not responsible to provide documentation or assurances regarding conditions, safety, air testing results and other compliance issues. RPF may have provided recommendations to the Client, as needed, pertaining to the Client’s Contractor compliance with the technical specifications, schedules, and other project related issues as agreed and based on results of RPF monitoring work. However, actual enforcement, or waiving of, contract provisions and requirements as well as regulatory liabilities shall be the responsibility of Client and Client’s Contractor(s). Off-site abatement activities, such as waste transportation and disposal, were not monitored or inspected by RPF.

11. For services limited to clearance testing following abatement or remediation work by other parties: The testing was limited to clearance testing only and as indicated in the report and a site assessment for possible environmental health and safety hazards was not performed as part of the scope of this testing. Client, or Client’s abatement contractor as applicable, was responsible for performing visual inspections


of the work area to determine completeness of work prior to air clearance testing by RPF.

12. For site work, including but not limited to air clearance testing services, in which RPF did not provide full site safety and health oversight, abatement design, full shift monitoring of all site activity, RPF expresses no warranties, guarantees or certifications of the abatement work conducted by the Client or other employers at the job site(s), conditions during the work, or regulatory compliance, with the exception of the specific airborne concentrations as indicated by the air clearance test performed by RPF during the conditions present for the clearance testing. Unless otherwise specifically noted in the RPF Report, visual inspections and air clearance testing results apply only to the specific work area and conditions present during the testing. RPF did not perform visual inspections of surfaces not accessible in the work area due to the presence of containment barriers or other obstructions. In these instances, some contamination may be present following RPF clearance testing and such contamination may be exposed during and after removal of the containment barriers or other obstructions following RPF testing services. Client or Client’s Contractor is responsible for using appropriate care and inspection to identify potential hazards and to remediate such hazards as necessary to ensure compliance and a safe environment.

13. The survey was limited to the material and/or areas as specifically designated in the report and a site assessment for other possible environmental health and safety hazards or subsurface pollution was not performed as part of the scope of this site inspection. Typically, hazardous building materials such as asbestos, lead paint, PCBs, mercury, refrigerants, hydraulic fluids and other hazardous product and materials may be present in buildings. The survey performed by RPF only addresses the specific items as indicated in the Report.

14. For mold and moisture survey services, RPF services did not include design or remediation of moisture intrusion. Some level of mold will remain at the site regardless of RPF testing and Contractor or Client cleaning efforts. RPF testing associated with mold remediation and assessments is limited and may or may not be representative of other surfaces and locations at the site. Mold growth will occur if moisture intrusion deficiencies have not been fully remedied and if the site or work areas are not maintained in a sufficiently dry state. Porous surfaces in mold contaminated areas which are not removed and disposed of will likely result in future spore release, allergen sources, or mold contamination.

15. Existing reports, drawings, and analytical results provided by the Client to RPF, as applicable, were not verified and, as such, RPF has relied upon the data provided as indicated, and has not conducted an independent evaluation of the reliability of these data.

16. Where sample analyses were conducted by an outside laboratory, RPF has relied upon the data provided, and has not conducted an independent evaluation of the reliability of this data.

17. All hazard communication and notification requirements, as required by U.S. OSHA regulation 29 CFR

Part 1926, 29 CFR Part 1910, and other applicable rules and regulations, by and between the Client, general contractors, subcontractors, building occupants, employees and other affected persons were the responsibility of the Client and are not part of the RPF SOW.

18. The applicability of the observations and recommendations presented in this report to other portions of the site was not determined. Many accidents, injuries and exposures and environmental conditions are a result of individual employee/employer actions and behaviors, which will vary from day to day, and with operations being conducted. Changes to the site and work conditions that occur subsequent to the RPF inspection may result in conditions which differ from those present during the survey and presented in the findings of the report.

APPENDIXD.2

MARCH23,2018HBMREPORT

March 23, 2018 Tim White, P.G. Project Manager Sanborn, Head & Associates, Inc. 20 Foundry Street Concord, NH 03301 Re: 1-3-5 Canada Street

Building Survey Findings RPF File No. 188445 Dear Mr. White: On February 27, 2018, RPF Environmental, Inc. (RPF) conducted a survey at the commercial property located at 1-3-5 Canada Street in Swanton, Vermont. The survey included the roof of the commercial structure located at 1-3-5 Canada Street for accessible asbestos containing building material, overall sampling of the commercial structure at 1-3-5 Canada Street for lead waste characterization, and a complete survey of the Chamber of Commerce Building for accessible hazardous building material, as indicated herein. Below is a summary of findings, discussion of the results, and preliminary recommendations for proper management of the identified hazardous building material. Attached to this report are the survey data tables, laboratory results, survey methodologies and limitations. This report is not intended to be used as an abatement specification or work plan. To proceed with abatement work, the following important steps are necessary:

1. A work plan or project design documents must be prepared prior to abatement by a certified abatement project designer.

2. The abatement specification or work plan should then be used to solicit bids from qualified abatement contractors. Only properly licensed contractors should be used for asbestos abatement and disposal.

3. A qualified industrial hygiene/testing consultant should conduct sufficient testing and

inspections of the work, independent of the abatement contractor. The consultant should also prepare final abatement reports for the work.

Summary of Findings The commercial structure at 1-3-5 Canada Street is an approximately 9,500 square foot commercial building comprised of 3 separate buildings, combined into what is effectively one structure. The scope of this survey included the inspection of the various roofing present on this structure for any suspect asbestos containing building materials (ACBM), as well as the collection of representative composite samples of the overall building components present for waste characterization purposes due to the presence of lead containing paint on the structures.

Sanborn Head & Associates, Inc. Swanton, Vermont Building Survey Findings Page 2

Also included in this scope of work is a survey of the single story, 625 square foot Chamber of Commerce building located at 34 Merchants Row in Swanton, Vermont for accessible hazardous building materials. The scope of the survey included accessible asbestos-containing building material in accordance with the initial asbestos inspection requirements prior to renovation or demolition work, as stated in the state regulations and applicable federal regulations. 1-3-5 Canada Street

Asbestos Existing survey and testing information provided by Client to RPF during this project includes a building survey findings report prepared by RPF Environmental dated January 4, 2017. Based on the review of the existing survey records, the following materials associated with the 1-3-5 Canada Street commercial structure are identified as ACBM: 1 Canada Street (includes Apt. 1 & 2) Interior Window Caulk Gypsum Board Joint Compound Door Caulk Window Caulk Door Glaze Building Seam Caulk Sink Basin Undercoat

3 Canada Street 9” Floor Tile 2x4 Ceiling Tiles Gypsum Board Joint Compound Transite Panels Pipe Fitting Insulation 5 Canada Street Flooring Adhesive

In addition to the above, several types of additional suspect ACBM roofing were observed by RPF during this inspection, including friable and nonfriable suspect material. Based on the testing performed by RPF, asbestos was detected in the following materials: • Black/Silver Flashing • Black Flashing • Grey Caulking • Black Roofing • Transite Debris

Lead Waste Characterization Based on the presence of lead containing paint on the structure detected during the initial hazardous building survey conducted in 2016, additional sampling was conducted during this round of testing for lead content by Toxicity Characteristic Leaching Procedure (TCLP) for disposal waste characterization purposes. Based on these results, lead was detected in one composite sample of building material collected from 1 Canada Street at a concentration above the US EPA Maximum Concentration for Contaminants for the


Toxicity Characteristic of 5.0 milligrams per liter (mg/L). The remaining sample from 1 Canada Street, both samples from 3 Canada Street, and the single sample from 5 Canada Street were all below the US EPA Maximum Concentration.

Chamber of Commerce Building

Asbestos

Several types of suspect ACBM were observed by RPF during the inspection of the Chamber of Commerce Building, including friable and nonfriable suspect material. Based on the testing performed by RPF, asbestos was detected in the yellow vinyl sheet flooring present in the bathroom and utility room underneath a brown non-asbestos sheet flooring layer. Lead Containing Paint RPF conducted limited spot testing of representative paint within the Chamber of Commerce building. Based on the results of this testing, no detectable lead was found in any of the paint chip samples collected. The intent of the lead testing was for potential lead hazardous waste disposal screening purposes only. Other Hazardous Materials No other potentially hazardous materials were observed during the inspection of the Chamber of Commerce building. The building is heated by electric baseboard heat, so no fuel sources are present. One single window-mounted air conditioner was observed in a utility closet which would need to be properly handled and disposed.

Depending on the extent of renovation and final construction plans, proper abatement and/or management of the materials will be required in accordance with applicable state and federal regulations. Renovation and demolition plans should be reviewed by a certified industrial hygienist and licensed project designer for possible asbestos impact issues. Based on the impact assessment and planned usage, technical specifications should be prepared for abatement, as applicable. A management plan should also be prepared to address any asbestos or other hazardous material scheduled to remain after construction. Discussion of Findings Asbestos is the name for a group of naturally occurring minerals that separate into strong, very fine fibers. The adverse health effects associated with asbestos exposure have been extensively studied for many years. Results of these studies and epidemiological investigations have demonstrated that inhalation of asbestos fibers may lead to increased risk of developing one or more diseases. In all cases, extreme care must be used not to disturb asbestos-containing materials or to create fiber release episodes.


1-3-5 Canada Street

Asbestos-Containing Building Material During this survey, RPF identified nineteen (19) homogeneous groups of accessible suspect ACBM associated with the roofing present on the 1-3-5 Canada Street structure. Suspect materials were identified based on current industry standards, EPA, and other guideline listings of potential suspect ACBM. The following is a summary list of the suspect ACBM identified and sampled during this survey: • Asphalt Shingles (various colors) • Black Roofing Paper • Brown Roofing Debris • Roof Flashing Caulk • Tan Roofing Paper • Black/Silver Flashing • Black Flashing Compound

• White Caulk • Grey Caulk • White Roofing Material • Black Modified Bitumen Roofing • Black Flashing Caulk • Transite Panel Debris

A total of thirty-six (36) samples were extracted from the different groups of suspect material in accordance with EPA sampling protocols. Of the samples collected by RPF, asbestos was detected in six (6) groups of suspect ACBM. Table 1 of Appendix A includes a list of ACBM identified associated with the roof of 1-3-5 Canada Street, EPA category listings, and asbestos content. A listing of the different homogenous groups of suspect material identified, samples collected, and analytical results is included in Table 2 of Appendix A. The ACBM identified during this survey consists of nonfriable material which was observed to be in good to fair condition and, left undisturbed and properly managed, is unlikely to cause any major fiber release episodes. During this roofing survey, a representative of the building owner was onsite to perform patching of the roof sample locations as necessary. The flat portions of the roof, specifically in enclosed alley portion between 1 and 3 Canada Street and the roof over 5 Canada Street were a white, synthetic roofing product that typically requires a specialized roof patching procedure. The owner representative applied patching to these locations consisting of a Grace ice and water shield product. As was recommended at the time, a more secure patch should be installed at each of the sample locations in the white synthetic roofing materials in order to prevent any roof leaks, particularly since these areas of the building are over areas that are currently occupied . Suspect materials encountered at the site subsequent to this survey, which are not included on the enclosed listings of suspect material sampled, should be assumed to be ACBM until


proper testing proves otherwise. Please notify RPF in this event to arrange for proper testing and assessments. Please reference the attached methodology and limitations. Lead Waste Characterization As lead containing paint (LP) was previously identified on various surfaces of the 1-3-5 Canada Street structure during the original hazardous building material survey, this round of testing included collection of a representative number of composite waste characterization samples from the building materials present for lead content. Lead is a toxic metal that was used for many years in paint and other products found in and around buildings and homes. Exposure to lead may cause a range of health effects, from behavioral problems and learning disabilities, to seizures and death. Children six years old and under are most at risk; however, adults are also susceptible to the effects of lead over exposure. For the purposes of this survey, RPF collected five (5) composite samples from the 1-3-5 Canada Street structure, each comprised of representative collections of accessible building materials throughout the building as follows: Sample Number General Description of Sample Makeup

022718-C1 Exterior wood siding, asphalt shingle roofing, slate roofing, window sills.

022718-C2 Gypsum wallboard, ceiling tiles, carpet, wood material from 1st floor, wood material from basement, fiberglass insulation, mortar.

022718-C3 Brick, asphalt shingle roofing, caulking, slate roofing, window sills.

022718-C4 Gypsum board, carpeting, fiberglass insulation, mortar, brick, ceiling tiles.

022718-C5 Laminate flooring, wood materials, ceiling tiles, carpet, ceramic tile

These samples are intended to be representative of the final waste stream materials to be disposed of during the demolition of the building. Each of the five composite samples were submitted for analysis for lead content by Toxicity Characteristic Leaching Procedure (TCLP). The intent of the lead testing was for potential lead hazardous waste disposal screening purposes only. Construction/demolition waste that is found to contain lead greater or equal to 5.0 milligrams per liter (mg/L) by TCLP analysis must be handled and treated as hazardous waste. The results of this analysis indicated that the lead content of the samples collected from 1 Canada Street ranged from 0.19 to 5.6 milligrams per liter (mg/L) by TCLP. The results of sampling from 3 Canada Street were both below reported as less than 0.05 mg/L, and the result from 5 Canada Street was reported as 0.092 mg/L. These results are included in Appendix B. Construction/demolition waste that is found to contain lead


greater or equal to 5.0 milligrams per liter (mg/L) by TCLP analysis must be handled and treated as hazardous waste. As one of the five samples was found to contain greater than 5.0 mg/L lead by TCLP, RPF recommends that additional characterization sampling be conducted by the demolition contractor prior to or during demolition of the structure. In order to more accurately characterize and delineate potentially lead contaminated surfaces, onsite measurement could be conducted using an x-ray fluorescence meter or other direct reading technology to direct the sampling effort and assist in segregating lead contaminated from non-lead contaminated wastes.


Asbestos-Containing Building Material In the accessible locations of the Chamber of Commerce building surveyed, RPF identified nine (9) homogeneous groups of accessible suspect asbestos-containing building material. Suspect materials were identified based on current industry standards, EPA, and other guideline listings of potential suspect ACBM. The following is a summary list of the suspect ACBM identified and sampled during this survey: • Gypsum Board Joint Compound • Carpet Adhesive • Brown Vinyl Sheet Flooring and

Mastic • Yellow Vinyl Sheet Flooring and

Mastic

• Laminate Countertop with Adhesive

• Asphalt Shingle Roofing • Ice & Water Shield

A total of seventeen (17) samples were extracted from the different groups of suspect material in accordance with EPA sampling protocols. Of the samples collected by RPF, asbestos was detected in one (1) groups of suspect ACBM. Table 1 of Appendix A includes a list of ACBM identified in the building, EPA category listings, and asbestos content. A listing of the different homogenous groups of suspect material identified, samples collected, and analytical results is included in Table 3 of Appendix A. The ACBM vinyl sheet flooring and mastic identified during this survey consists nonfriable material which observed to be in good to fair condition and, left undisturbed and properly managed, is unlikely to cause any major fiber release episodes.


Lead Paint Screening Based on the type and age of building construction, it is reasonable to assume that various painted surfaces contain some lead. It is not uncommon in buildings such as this and that have had various renovation and upgrades to have both lead containing paint and non-lead containing paint. Lead is a toxic metal that was used for many years in paint and other products found in and around buildings and homes. Exposure to lead may cause a range of health effects, from behavioral problems and learning disabilities, to seizures and death. Children six years old and under are most at risk; however, adults are also susceptible to the effects of lead over exposure. For the purposes of this survey, RPF extracted five (5) representative suspect paints samples from components within the Chamber of Commerce building. The results for the paint chip testing completed during this survey are included in Appendix B. As you can see, lead was found above the minimum detection limit for each sample collected. Current State of Vermont Lead Poisoning regulations consider any paint that contains greater than 0.5 percent by weight to be lead-based paint. However, the intent of this survey was for construction purposes only and preliminary demolition waste stream implications, not for compliance with Vermont Lead Poisoning regulations, HUD, or any regulatory abatement order. Any surfaces with lead present should be managed in accordance with current rules and guidelines, including but not limited to OSHA worker safety rules and state and EPA waste handling and disposal regulations. U.S. Occupational Safety and Health Administration (OSHA) construction rules do not specify any "safe" or acceptable levels of lead within paint for the purposes of occupational exposures. Therefore, construction work involving paint found to contain lead must be completed in accordance with OSHA regulations, not limited to the lead standard, 29 CFR 1926.62. Contractors completing work in areas found to contain lead, or where it is reasonable to assume lead may be present, should be notified of the presence (and potential presence) of lead and proper work protocols should be used. Please also note that construction and renovation work involving lead paint in housing and child-occupied facilities built before 1978 is also regulated under the EPA Renovation, Repair, and Painting (RRP) rule. Any contractors conducting such work must be properly certified and must use lead safe work methods pursuant to the EPA RRP rule. In addition, pursuant to Title X requirements landlords and sellers are required to disclose the results of lead inspections to tenants and purchasers, and to provide the warning notice and pamphlets in accordance with Title X and State requirements. PCB Light Ballasts, Fluorescent Lamp Inventory and other Hazardous Materials During the survey of the Chamber of Commerce Building, RPF did not observe any light fixtures with potentially PCB containing ballasts, any fluorescent light bulbs, or other building components that are likely to contain mercury or other hazardous materials. A


single air conditioner unit was observed in the utility closet which could contain chlorofluorocarbons (CFCs) or other ozone depleting chemicals which would need to be properly handled and disposed of as part of the building demolition.

Conclusions Based on the survey findings, the roof of the 1-3-5 Canada Street structure was found to contain various types of ACBM. In addition, one of the five waste characterization samples were found to contain lead greater than the 5 mg/L threshold for lead hazardous waste. The Chamber of Commerce building was found to contain ACBM in the form of vinyl sheet flooring. In accordance with current regulatory requirements, ACBM that may be impacted or disturbed (such that asbestos fiber release occurs) by renovation, demolition or other such activity must be removed by qualified, licensed firms. Although regulations for removal of nonfriable ACBM are somewhat less stringent than the requirements for friable ACBM, it should be noted that nonfriable ACBM that is subjected to grinding, abrasion, and other forces, could be rendered friable. In this event, the nonfriable ACBM would be re-categorized friable ACBM. ACBM that will not be impacted by renovation or demolition activity may be left in place if managed properly and if the materials are maintained in good condition. ACBM to remain in the building should be included in an asbestos management plan and operations and maintenance (O&M) program detailing the measures to be used to safely occupy the building until the ACBM is fully removed. An accredited Management Planner should prepare the O&M Program in accordance with the guidelines set forth in 40 CFR Part 763 (AHERA). Work impacting LP must be performed in accordance with current State and federal standards, including but not limited safe work practices, engineering controls, proper waste packaging, and proper disposal. Work involving LP may require notification of tenants, if rented or leased space, prior to start of work. Sufficiently in advance of the start of renovation and/or remediation work, abatement project design should be completed. As part the initial design steps any planned renovation and demolition activity should be reviewed for potential impact on ACBM. Asbestos removal is highly regulated at the state and federal level, and in some cases, at the local level also. Notification to NH Air Resources is required 10-days prior to the start of interior abatement work and demolition. Only qualified, trained, and licensed firms, as applicable, should be engaged to complete asbestos removal or other abatement activity. Asbestos abatement work must be designed (abatement specifications or work plan prepared) by accredited licensed personnel. All employees and contractors that may access or otherwise disturb areas with suspect ACBM present should be notified of the presence of ACBM and possible hidden ACBM, and the need to use caution when proceeding with work. Appropriate notifications, labeling and other hazard communications should be completed to all employees, contractors and others in accordance with US OSHA regulations and other applicable requirements (including asbestos labeling in accordance with 29 CFR Part 1926). The scope of RPF services for this survey did not include


labeling of ACBM or hazard communications to other employees, building occupants, contractors, or subcontractors. Documentation of current ACBM conditions and in-depth hazard assessment is beyond the scope-of-work for this initial survey. With the exception of the specific testing and analysis detailed herein, no other samples of materials, oil, water, ground water, air, or other suspect hazardous materials were collected in the course of this inspection that supports or denies these conclusions. No additional services beyond those explicitly stated herein were performed and none should be inferred or implied. The summary and conclusions are based on reasonably ascertainable information as described in this report. RPF Environmental, Inc. makes no guarantees, warranties, or references regarding this property or the condition of the property after the period of this report. If you have any questions at this time, or if you would like to discuss the remediation process, please call our office. Sincerely, RPF ENVIRONMENTAL, INC. Allan D. Mercier, CMC Field Operations Manager Licensed Inspector AI937386 Enclosures: Appendix A: Data and Analytical Tables Appendix B: Laboratory Results Appendix C: Site Sketch Appendix D: Survey Photographs Appendix E: Summary of Methodology and Limitations 188445 Swanton VT 022718 Report

APPENDIX A

TABLE 1

SANBORN, HEAD & ASSOCIATES, INC.

1-3-5 Canada Street & Chamber of Commerce Building Swanton, Vermont

SUMMARY OF ACBM IDENTIFIED

Building Material



1-3-5 Canada Street, Swanton, Vermont

Black/Silver Flashing 3 Canada Street, east slope, along lower edge of roof at ice shield, 3 ft high and the length of roof

180 square feet Category I Nonfriable

6% Chrysotile

Black Flashing 1 and 3 Canada Street, patches throughout slate roofing


5% Chrysotile

Grey Caulk 3 Canada Street, northeast corner at roofline, repairs to brick walls

6 linear feet Category I Nonfriable

4% Chrysotile

Modified Bitumen Roofing

Roof over alley between 1 and 3 Canada Street and extending along front overhang of entire structure, under white synthetic roofing

1,500 square feet Category I Nonfriable

3% Chrysotile

Transite Debris Roof over alley between 1 and 3 Canada Street


18% Chrysotile


Roof over 5 Canada under white synthetic roofing

1,200 square feet Category I Nonfriable

8% Chrysotile


Yellow Vinyl Sheet Flooring and Adhesive

Bathroom and Utility Closet underneath non-ACBM brown vinyl sheet flooring


15% Chrysotile

Notes:

• Table 1 does not include a listing of all ACBM and suspect ACBM present at the site, only the materials found to be ACBM during the limited testing of this roofing survey. Please refer to the original survey report prepared by RPF Environmental dated January 4, 2017 which identifies the types, locations and quantities of other ACBM present at this site

• Please note that Category 1 and Category 2 nonfriable ACM are recategorized as friable and/or RACM under certain conditions. Current State asbestos regulations are more strict and comprehensive than the EPA NESHAPs requirements.

• All quantities are approximate only and should be confirmed during abatement project design and abatement bidding. • It is possible that some concealed or inaccessible ACBM is present. Care should be used when renovating/demolishing

inaccessible building space. Further explorative survey work may be necessary during design and/or in conjunction with demolition.

TABLE 2

SANBORN, HEAD & ASSOCIATES, INC. 1-3-5 Canada Street, Swanton, Vermont

Roofing Survey Results


Samples Collected: February 27, 2018

Notes: • SFP Means analysis was terminated because asbestos was detected on a previous homogenous sample during the survey work.

Please reference the "HG" group number. • Please reference the full report for discussions and additional information and limitations pertaining to these results.

Page 1 of 3


Asbestos Components

Fibrous Components


022718HG1a Asphalt shingle, black/red, 3 Canada Street, west slope None Detected 10% Fiber Glass 90% Other

022718HG1b Asphalt shingle, black/red, 3 Canada Street, west slope None Detected 10% Fiber Glass 90% Other

022718HG2a Paper, black, 3 Canada Street west slope, under shingles None Detected 70% Cellulose 30% Other

022718HG2b Paper, black, 3 Canada Street west slope, under shingles None Detected 70% Cellulose 30% Other

022718HG3a Asphalt shingle, black, 3 Canada Street north buildout None Detected 10% Fiber Glass 90% Other

022718HG3b Asphalt shingle, black, 3 Canada Street north buildout None Detected 10% Fiber Glass 90% Other

022718HG4a Paper, black, 3 Canada Street, north buildout, under shingles None Detected 70% Cellulose 30% Other

022718HG4b Paper, black, 3 Canada Street, north buildout, under shingles None Detected 70% Cellulose 30% Other

022718HG5a

Asphalt shingle, black/tan, 1 Canada, west porch, upper roof, top layer None Detected 10% Fiber Glass 90% Other

022718HG5b

Asphalt shingle, black/tan, 1 Canada, west porch, lower roof, top layer None Detected 10% Fiber Glass 90% Other

022718HG6a

Asphalt shingle, black, 1 Canada, west porch, upper roof, bottom layer None Detected 10% Fiber Glass 90% Other

022718HG6b

Asphalt shingle, black, 1 Canada, west porch, upper roof, bottom layer None Detected 10% Fiber Glass 90% Other

022718HG7a Brown debris, 1 Canada, upper roof under slate None Detected 60% Cellulose 40% Other

022718HG7b Brown debris, 1 Canada, upper roof under slate None Detected 60% Cellulose 40% Other

TABLE 2 (continued)


1-3-5 Canada Street, Swanton, Vermont Roofing Survey Results





Page 2 of 3


Asbestos Components

Fibrous Components


022718HG8a Roof Flashing, black/grey, 1 Canada, west porch, upper edge None Detected 20% Cellulose 80% Other

022718HG8b Roof Flashing, black/grey, 1 Canada, west porch, upper edge None Detected 20% Cellulose 80% Other

022718HG9a Paper, tan, 3 Canada Street, east slope, under slate None Detected 90% Cellulose 10% Other

022718HG9b Paper, tan, 3 Canada Street, east slope, under slate None Detected 90% Cellulose 10% Other

022718HG10a Flashing, black/silver, 3 Canada Street, east slope, lower ice shield Positive 6% Chrysotile -- 94% Other

022718HG10b Flashing, black/silver, 3 Canada Street, east slope, lower ice shield *SFP -- --

022718HG11a Flashing, black, 3 Canada Street, east slope, spots in field Positive 5% Chrysotile -- 95% Other

022718HG11b Flashing, black, 1 Canada, east slope, spots in field *SFP -- --

022718HG12 Caulk, white, 3 Canada Street, northeast corner None Detected -- 100% Other

022718HG13 Caulk, grey, 3 Canada Street, northeast corner at roofline Positive 4% Chrysotile -- 96% Other

022718HG14a

Roofing, white, Roof over alley between 1 and 3 Canada, north edge None Detected


022718HG14b Roofing, white, Roof over alley between 1 and 3 Canada, south side None Detected


022718HG15a

Modified bitumen roofing, black, Roof over alley between 1 and 3 Canada, north edge, under white Positive 3% Chrysotile 27% Cellulose 70% Other

022718HG15b

Modified bitumen roofing, black, Roof over alley between 1 and 3 Canada, south side, under white *SFP -- --

TABLE 2 (continued)


1-3-5 Canada Street, Swanton, Vermont Roofing Survey Results





Page 3 of 3


Asbestos Components

Fibrous Components


022718HG16a

Flashing/caulk, black, Roof over alley between 1 and 3 Canada, at abutment edges, north side None Detected -- 100% Other

022718HG16b

Flashing/caulk, black, Roof over alley between 1 and 3 Canada, at abutment edges, south side None Detected -- 100% Other

022718HG16c

Flashing/caulk, black, Roof over alley between 1 and 3 Canada, at abutment edges, at metal buildout None Detected -- 100% Other

022718HG17 Transite debris, grey, Roof over alley between 1 and 3 Canada Positive 18% Chrysotile -- 82% Other

022718HG18a Roofing, white, 5 Canada, north edge None Detected


022718HG18b Roofing, white, 5 Canada, approximate center None Detected


022718HG19a Modified bitumen roofing, black, 5 Canada, north edge, under white Positive 8% Chrysotile 42% Cellulose 50% Other

022718HG19b

Modified bitumen roofing, black, 5 Canada, approximate center, under white *SFP -- --

188445

TABLE 3

SANBORN, HEAD & ASSOCIATES, INC. Chamber of Commerce Building

34 Merchants Road, Swanton, VT





Page 1 of 1


Asbestos Components

Fibrous Components


022718HG1a Gypsum board joint compound, white, bathroom wall

None Detected 10% Cellulose 90% Other

022718HG1b Gypsum board joint compound, white, Main room wall


022718HG1c Gypsum board joint compound, white, Main room ceiling


022718HG2a Carpet adhesive, yellow, main room None Detected -- 100% Other

022718HG2b Carpet adhesive, yellow, main room None Detected -- 100% Other

022718HG3a-A Vinyl sheet flooring, brown, bathroom, top layer


022718HG3a-B Mastic, beige, bathroom, top layer None Detected -- 100% Other

022718HG3b-A Vinyl sheet flooring, brown, utility room, top layer


022718HG3b-B Mastic, beige, utility room, top layer None Detected -- 100% Other

022718HG4a Vinyl sheet flooring and mastic, yellow, bathroom, bottom layer (unable to

separate mastic layer)

Positive 15% Chrysotile 15% Cellulose 70% Other

022718HG4b Vinyl sheet flooring and mastic, yellow, utility room, bottom layer (unable to

separate mastic layer)

*SPF -- --

022718HG5a-A Laminate, tan, main room None Detected -- 100% Other

022718HG5a-B Mastic, yellow, main room None Detected -- 100% Other

022718HG6a Asphalt shingle, black, southeast corner roof

None Detected 10% Fiber Glass

90% Other

022718HG6b Asphalt shingle, black, southwest corner roof


90% Other

022718HG7a Ice and water shield, black, southeast corner roof, bottom layer


022718HG7b Ice and water shield, black, southwest corner roof, bottom layer


70% Other

Note: Lead based paint as defined by current state of NH lead poisoning prevention regulations, is any paint that contains > 0.5 %Weight (WT) of lead. OSHA does not currently establish a percent lead for lead paint.

TABLE 4


Chamber of Commerce Building Swanton, Vermont

SUMMARY OF BULK LEAD SURFACE SAMPLE RESULTS Lead Analysis in Paint by Flame AAS (SW 846 3050B and 7420)

Sample Collected: February 27, 2018

Sample ID Description Lead Result

022718LPS1 Paint, white, bathroom wall <0.0042%

022718LPS Paint, white, utility room wall <0.0054%

022718LPS Paint, white, bathroom ceiling <0.0063%

022718LPS Paint, white, exterior siding, south <0.0059%

022718LPS Paint, white, exterior siding north <0.0075% 188445

APPENDIX B

Bulk Asbestos AnalysisBy Polarized Light Microscopy

EPA Method: 600/R-93/116 and 600/M4-82-020

188445 SHA-Swanton VT RoofProject:

Sample ID

Lab Sample ID

Description

Lab Notes AsbestosFibrous

ComponentsNon-FibrousComponents

Attributes

Treatment

Allan MercierAttn:Customer: RPF Environmental Inc.320 1st NH TurnpikeNorthwood, NH 03261

Analysis ID: 11805188_PLM

Date Reported: 3/5/2018

Date Received: 3/1/2018

Lab Order ID: 11805188

None Detected022718HG1a

Asphalt shingle, black/red,Theater building, west slope

Black, RedNon FibrousHeterogeneous

Dissolved11805188PLM_1

Fiber Glass Other 10% 90%

None Detected022718HG1b

Asphalt shingle, black/red,Theater building, west slope

Black, RedNon FibrousHeterogeneous




Paper, black, Theater buildingwest slope, under shingles

BlackFibrousHeterogeneous

Teased, Dissolved11805188PLM_3

Cellulose Other 70% 30%


Paper, black, Theater buildingwest slope, under shingles





Asphalt shingle, black,Theater buildilng northbuildout

BlackNon FibrousHeterogeneous




Asphalt shingle, black,Theater buildilng northbuildout





Paper, black, Theater building,north buildout, under shingles





Paper, black, Theater building,north buildout, under shingles




Disclaimer: Due to the nature of the EPA 600 method, asbestos may not be detected in samples containing low levels of asbestos. We strongly recommend that analysis of floor tiles, vermiculite, and/orheterogeneous soil samples be conducted by TEM for confirmation of “None Detected” by PLM. This report relates only to the samples tested and may not be reproduced, except in full, without the writtenapproval of SAI. This report may not be used by the client to claim product endorsement by NVLAP or any other agency of the U.S. government. Analytical uncertainty available upon request. ScientificAnalytical Institute participates in the NVLAP Proficiency Testing program. Unless otherwise noted blank sample correction was not performed. Estimated MDL is 0.1%.

Page 1 of 5

Approved SignatoryAnalyst

Scientific Analytical Institute, Inc. 4604 Dundas Dr. Greensboro, NC 27407 (336) 292-3888

Byron Stroble (36)

P-F-002 r15 1/16/2021


EPA Method: 600/R-93/116 and 600/M4-82-020


Sample ID

Lab Sample ID

Description



Attributes

Treatment







Asphalt shingle, black/tan, 1Canada, west porch, upper

Black, TanNon FibrousHeterogeneous




Asphalt shingle, black/tan, 1Canada, west porch, lower

Black, TanNon FibrousHeterogeneous




Asphalt shingle, black, 1Canada, west porch, upper,bottom layer





Asphalt shingle, black, 1Canada, west porch, upper,bottom layer





Brown debris, 1 Canada,upper roof under slate

BrownFibrousHeterogeneous

Teased11805188PLM_13



Brown debris, 1 Canada,upper roof under slate

BrownFibrousHeterogeneous




Roof Flashing, black/grey, 1Canada, west porch, upperedge

Tan, BlackNon FibrousHeterogeneous




Roof Flashing, black/grey, 1Canada, west porch, upperedge

Gray, BlackNon FibrousHeterogeneous




Page 2 of 5



Byron Stroble (36)

P-F-002 r15 1/16/2021


EPA Method: 600/R-93/116 and 600/M4-82-020


Sample ID

Lab Sample ID

Description



Attributes

Treatment







Paper, tan, Theater building,east slope, under slate

Brown, GrayFibrousHeterogeneous




Paper, tan, Theater building,east slope, under slate

Brown, GrayFibrousHeterogeneous



6% Chrysotile

022718HG10a

Flashing, black/silver, Theaterbuidling, east slope, lower iceshield

Black, SilverNon FibrousHeterogeneous


Other 94%

Not Analyzed022718HG10b

Flashing, black/silver, Theaterbuidling, east slope, lower iceshield

11805188PLM_20

5% Chrysotile

022718HG11a

Flashing, black, Theaterbuilding, east slope, spots infield



Other 95%


Flashing, black, 1 Canada, eastslope, spots in field

11805188PLM_22

None Detected022718HG12

Caulk, white, Theaterbuilding, northeast corner

WhiteNon FibrousHomogeneous

Ashed11805188PLM_23

Other 100%

4% Chrysotile

022718HG13

Caulk, grey, Theater building,northeast corner (similar toHG11)

Gray, BlackNon FibrousHeterogeneous


Other 96%


Page 3 of 5



Byron Stroble (36)

P-F-002 r15 1/16/2021


EPA Method: 600/R-93/116 and 600/M4-82-020


Sample ID

Lab Sample ID

Description



Attributes

Treatment







Roofing, white, Alley roof,north edge


Ashed11805188PLM_25

Synthetic Fibers Other 10% 90%


Roofing, white, Alley roof,south side


Ashed11805188PLM_26


3% Chrysotile

022718HG15a

Roofing, black, Alley roof,north edge, under white





Roofing, black, Alley roof,south side, under white

11805188PLM_28


Flashing/caulk, black, Alleyroof, at abuttment edges, northside

Gray, BlackNon FibrousHomogeneous

Ashed11805188PLM_29

Other 100%


Flashing/caulk, black, Alleyroof, at abuttment edges, southside


Ashed11805188PLM_30

Other 100%

None Detected022718HG16c

Flashing/caulk, black, Alleyroof, at abuttment edges, atmetal buildout


Ashed11805188PLM_31

Other 100%

18% Chrysotile

022718HG17

Transite debris, grey, AlleyRoof

GrayNon FibrousHeterogeneous


Other 82%


Page 4 of 5



Byron Stroble (36)

P-F-002 r15 1/16/2021


EPA Method: 600/R-93/116 and 600/M4-82-020


Sample ID

Lab Sample ID

Description



Attributes

Treatment







Roofing, white, 5 Canada,north edge


Ashed11805188PLM_33



Roofing, white, 5 Canada,approximate center


Ashed11805188PLM_34


8% Chrysotile

022718HG19a

Roofing, black, 5 Canada,north edge, under white





Roofing, black, 5 Canada,approximate center, underwhite

11805188PLM_36


Page 5 of 5



Byron Stroble (36)

P-F-002 r15 1/16/2021


EPA Method: 600/R-93/116 and 600/M4-82-020

188445 SHA-Swanton VT ChamberProject:

Sample ID

Lab Sample ID

Description



Attributes

Treatment



Date Amended: 3/5/2018





Gypsum board jointcompound, white, bathroomwall

gypsum board: none detect;joint compnd: none detect

Brown, WhiteNon FibrousHeterogeneous

Teased11805185PLM_1



Gypsum board jointcompound, white, Main roomwall



Teased11805185PLM_2


None Detected022718HG1c

Gypsum board jointcompound, white, Main roomceiling



Teased11805185PLM_3



Carpet adhesive, yellow, mainroom

YellowNon FibrousHeterogeneous


Other 100%


Carpet adhesive, yellow, mainroom



Other 100%

None Detected022718HG3a- A

Vinyl sheet flooring, brown,bathroom, top layer

vinyl

BrownNon FibrousHeterogeneous

Teased11805185PLM_6


None Detected022718HG3a- B

Vinyl sheet flooring, brown,bathroom, top layer

mastic

BeigeNon FibrousHeterogeneous


Other 100%

None Detected022718HG3b- A

Vinyl sheet flooring, brown,utility room, top layer

vinyl


Teased11805185PLM_7



Page 1 of 3



Byron Stroble (17)

P-F-002 r15 1/16/2021


EPA Method: 600/R-93/116 and 600/M4-82-020


Sample ID

Lab Sample ID

Description



Attributes

Treatment







None Detected022718HG3b- B

Vinyl sheet flooring, brown,utility room, top layer

mastic

BeigeNon FibrousHeterogeneous


Other 100%

15% Chrysotile

022718HG4aVinyl sheet flooring, yellow,bathroom, bottom layer

unable to separate mastic

GrayNon FibrousHeterogeneous

Teased11805185PLM_8



Vinyl sheet flooring, yellow,utility room, bottom layer

11805185PLM_9

None Detected022718HG5a- A

Laminate with adhesive, tan,main room

laminate


Ashed11805185PLM_10

Other 100%

None Detected022718HG5a- B

Laminate with adhesive, tan,main room

mastic



Other 100%


Asphalt shingle, black,southeast corner roof





Asphalt shingle, black,southwest corner roof





Ice and water shield, black,southeast corner roof, bottomlayer





Page 2 of 3



Byron Stroble (17)

P-F-002 r15 1/16/2021


EPA Method: 600/R-93/116 and 600/M4-82-020


Sample ID

Lab Sample ID

Description



Attributes

Treatment








Ice and water shield, black,southwest corner roof, bottomlayer


Dissolved, Teased11805185PLM_14



Page 3 of 3



Byron Stroble (17)

P-F-002 r15 1/16/2021

RPF Environmental Inc.320 1st NH TurnpikeNorthwood, NH 03261

Customer:

Analysis ID: 11806073_PBPAttn: Allan Mercier

Date Reported: 3/14/2018Date Received: 3/12/2018

Project: 188445 SHA Swanton VT-Chamber


Lab Notes

Description

Lab Sample ID

Sample ID

by Flame Atomic Absorption SpectroscopyEPA SW-846 3050B/6010C/7000B

Concentration

(ppm)(g)

Mass Concentration

(% by weight)

11806073PBP_1

Paint, white, bathroom wall022718LPS1< 420.0962 < 0.0042%

11806073PBP_2

Paint, white, utility room wall022718LPS< 540.0738 < 0.0054%

11806073PBP_3

Paint, white, bathroom ceiling022718LPS< 630.0634 < 0.0063%

11806073PBP_4

paint, white, exterior siding, south022718LPS< 590.0678 < 0.0059%

11806073PBP_5

Paint, white exterior siding north022718LPS< 750.0534 < 0.0075%

Unless otherwise noted blank sample correction was not performed on analytical results. Scientific Analytical Institute participates in the AIHA ELPAT program. ELPAT Laboratory ID: 173190. This reportrelates only to the samples tested and may not be reproduced, except in full, without the written approval of SAI. Analytical uncertainty available upon request. The quality control samples run with thesamples in this report have passed all EPA required specifications unless otherwise noted. RL: (Report Limit for an undiluted 50ml sample is 4µg Total Pb).

Daniel Olson (5)

Scientific Analytical Institute, Inc. 4604 Dundas Dr. Greensboro, NC 27407 (336) 292-3888Analyst Laboratory Director

Page 1 of 1pbRpt_4.0.01_pbp001

L-F-021 r17 2/14/2020

188445 SHA-Swanton VTProject ID:43615Job ID:

022718-C1TCLP Extract

Sample ID:Matrix:

Parameter ResultAnalysis

Date Time

Sample #:

Reporting Limit Reference

2/27/18 0:00Sampled:

43615-001

AnalystInstr Dil'n

FactorUnits

>>> This report format is for TCLP Extracts only <<<

TCLP Limit

3/7/18TCLP:PrepDate Batch

Arsenic 3/8/18< 0.050 0.050 SW1311 SW3005A6020A1 21:06mg/L AGN5 3/8/18 10444Barium 3/9/18< 0.10 0.10 SW1311 SW3005A6020A1 15:57mg/L AGN100 3/8/18 10444Cadmium 3/9/18< 0.010 0.010 SW1311 SW3005A6020A1 15:57mg/L AGN1 3/8/18 10444Chromium 3/8/18< 0.10 0.10 SW1311 SW3005A6020A1 21:06mg/L AGN5 3/8/18 10444Lead 3/12/185.6 0.050 SW1311 SW3005A6020A1 19:28mg/L AGN5 3/8/18 10444Mercury 3/9/18< 0.0020 0.0020 SW1311 SW7470A1 15:48mg/L AJD0.2 3/9/18 10445Selenium 3/8/18< 0.10 0.10 SW1311 SW3005A6020A1 21:06mg/L AGN1 3/8/18 10444Silver 3/8/18< 0.050 0.050 SW1311 SW3005A6020A1 21:06mg/L AGN5 3/8/18 10444


Sample ID:Matrix:


Date Time

Sample #:


2/27/18 0:00Sampled:

43615-002

AnalystInstr Dil'n

FactorUnits


TCLP Limit


Arsenic 3/8/18< 0.050 0.050 SW1311 SW3005A6020A1 21:32mg/L AGN5 3/8/18 10444Barium 3/9/180.11 0.10 SW1311 SW3005A6020A1 16:04mg/L AGN100 3/8/18 10444Cadmium 3/9/18< 0.010 0.010 SW1311 SW3005A6020A1 16:04mg/L AGN1 3/8/18 10444Chromium 3/8/18< 0.10 0.10 SW1311 SW3005A6020A1 21:32mg/L AGN5 3/8/18 10444Lead 3/8/180.19 0.050 SW1311 SW3005A6020A1 21:32mg/L AGN5 3/8/18 10444Mercury 3/9/18< 0.0020 0.0020 SW1311 SW7470A1 15:50mg/L AJD0.2 3/9/18 10445Selenium 3/8/18< 0.10 0.10 SW1311 SW3005A6020A1 21:32mg/L AGN1 3/8/18 10444Silver 3/8/18< 0.050 0.050 SW1311 SW3005A6020A1 21:32mg/L AGN5 3/8/18 10444


Sample ID:Matrix:


Date Time

Sample #:


2/27/18 0:00Sampled:

43615-003

AnalystInstr Dil'n

FactorUnits


TCLP Limit


Arsenic 3/8/18< 0.050 0.050 SW1311 SW3005A6020A1 21:38mg/L AGN5 3/8/18 10444Barium 3/9/18< 0.10 0.10 SW1311 SW3005A6020A1 16:10mg/L AGN100 3/8/18 10444Cadmium 3/9/18< 0.010 0.010 SW1311 SW3005A6020A1 16:10mg/L AGN1 3/8/18 10444Chromium 3/8/18< 0.10 0.10 SW1311 SW3005A6020A1 21:38mg/L AGN5 3/8/18 10444Lead 3/8/18< 0.050 0.050 SW1311 SW3005A6020A1 21:38mg/L AGN5 3/8/18 10444Mercury 3/9/18< 0.0020 0.0020 SW1311 SW7470A1 15:55mg/L AJD0.2 3/9/18 10445Selenium 3/8/18< 0.10 0.10 SW1311 SW3005A6020A1 21:38mg/L AGN1 3/8/18 10444Silver 3/8/18< 0.050 0.050 SW1311 SW3005A6020A1 21:38mg/L AGN5 3/8/18 10444

Page 2 of 4

188445 SHA-Swanton VTProject ID:43615Job ID:


Sample ID:Matrix:


Date Time

Sample #:


2/27/18 0:00Sampled:

43615-004

AnalystInstr Dil'n

FactorUnits


TCLP Limit


Arsenic 3/8/18< 0.050 0.050 SW1311 SW3005A6020A1 21:45mg/L AGN5 3/8/18 10444Barium 3/9/180.15 0.10 SW1311 SW3005A6020A1 16:17mg/L AGN100 3/8/18 10444Cadmium 3/9/18< 0.010 0.010 SW1311 SW3005A6020A1 16:17mg/L AGN1 3/8/18 10444Chromium 3/8/18< 0.10 0.10 SW1311 SW3005A6020A1 21:45mg/L AGN5 3/8/18 10444Lead 3/8/18< 0.050 0.050 SW1311 SW3005A6020A1 21:45mg/L AGN5 3/8/18 10444Mercury 3/9/18< 0.0020 0.0020 SW1311 SW7470A1 15:57mg/L AJD0.2 3/9/18 10445Selenium 3/8/18< 0.10 0.10 SW1311 SW3005A6020A1 21:45mg/L AGN1 3/8/18 10444Silver 3/8/18< 0.050 0.050 SW1311 SW3005A6020A1 21:45mg/L AGN5 3/8/18 10444


Sample ID:Matrix:


Date Time

Sample #:


2/27/18 0:00Sampled:

43615-005

AnalystInstr Dil'n

FactorUnits


TCLP Limit


Arsenic 3/8/180.47 0.050 SW1311 SW3005A6020A1 21:51mg/L AGN5 3/8/18 10444Barium 3/9/18< 0.10 0.10 SW1311 SW3005A6020A1 16:23mg/L AGN100 3/8/18 10444Cadmium 3/9/18< 0.010 0.010 SW1311 SW3005A6020A1 16:23mg/L AGN1 3/8/18 10444Chromium 3/9/180.17 0.10 SW1311 SW3005A6020A1 16:23mg/L AGN5 3/8/18 10444Lead 3/8/180.092 0.050 SW1311 SW3005A6020A1 21:51mg/L AGN5 3/8/18 10444Mercury 3/9/18< 0.0020 0.0020 SW1311 SW7470A1 15:59mg/L AJD0.2 3/9/18 10445Selenium 3/8/18< 0.10 0.10 SW1311 SW3005A6020A1 21:51mg/L AGN1 3/8/18 10444Silver 3/8/18< 0.050 0.050 SW1311 SW3005A6020A1 21:51mg/L AGN5 3/8/18 10444

Page 3 of 4

APPENDIX C

APPENDIX D

EXAMPLE PICTURES

Site Address: Sanborn Head & Associates Swanton, Vermont


Overall view of 1, 3 &

5 Canada Street.

Shingles on 3 Canada St west slope, no

asbestos detected in shingles or underlying black paper (HG1 &

HG2).

EXAMPLE PICTURES



Black asphalt shingles and paper on north

buildout on 3 Canada. No asbestos detected

(HG3 & HG4).

Two layers of asphalt shingles on upper and lower porch roof on

west side of 1 Canada. No asbestos detected. (HG5 & HG6) Black flashing along upper edge of roof, also no

asbestos detected (HG8).

EXAMPLE PICTURES



Brown debris material under slate shingles on

1 Canada Street. No asbestos detected

(HG7).

Tan paper under slate roofing on 3 Canada St east slope. No asbestos

detected (HG9).

EXAMPLE PICTURES



ACBM black/silver flashing along lower

edge of slate roof on 3 Canada Street (HG10).

ACBM black flashing compound in patches

throughout slate roofing on 1 and 3 Canada

Street (HG11).

EXAMPLE PICTURES



White and grey caulk at northeast corner of 3

Canada St at wall repair. White caulk

(HG12) is non-asbestos, grey caulk (HG13) is asbestos containing.

White non-ACBM synthetic roofing

(HG14) over alley roof with ACBM black modified bitumen

roofing underneath (HG15).

EXAMPLE PICTURES



White synthetic non-ACBM roofing (HG18)

over ACBM black modified bitumen

roofing (HG19) at 5 Canada St.

Example of patch installed by owner’s representative using Grace Ice and Water

Shield.

EXAMPLE PICTURES



Example of patch over Alley roof owner’s representative using Grace Ice & Water

Shield.

Roof over memorial building, not included

in scope of work. Metal roof potentially

installed over suspect roofing materials.

EXAMPLE PICTURES



Metal roof on Memorial Building. Suspect

flashing and caulking along front parapet

wall. Potentially other suspect materials

present.

Metal roof over warehouse building

attached to Memorial Building not in scope of

work.

EXAMPLE PICTURES



Chamber of Commerce Building. No asbestos

detected in asphalt shingle roofing (HG6 &

HG7).

Interior of Chamber of Commerce Building.

No asbestos detected in gypsum board joint compound (HG1),

carpet adhesive (HG2), or laminate countertop

(HG5).

EXAMPLE PICTURES



Bathroom, no asbestos detected in brown vinyl sheet flooring (HG3). >1% asbestos detected in yellow vinyl sheet

flooring (HG4) present beneath brown flooring.

Utility closet, no asbestos detected in brown vinyl sheet

flooring (HG3). >1% asbestos detected in yellow vinyl sheet

flooring (HG4) present beneath brown flooring.

Also present is air conditioner with potential CFCs.

APPENDIX E

Summary of Methodology: Asbestos-Containing Building Materials Survey EPA accredited inspector(s) surveyed accessible space in the building or site areas included within the RPF Scope of Work (SOW) to identify suspect asbestos-containing building material (ACBM). Suspect ACBM was inventoried and categorized into homogeneous groups of materials. To the extent indicated in the report, samples were then extracted from the different groups of homogeneous materials in accordance with applicable State and federal rules and regulations. For surveys in which the SOW included full inspections of the affect space, sampling methodologies were based on the requirements set forth in 40 CFR Part 763 (EPA) and 29 CFR Part 1926.1101 (OSHA). For preliminary or limited surveys, findings apply to only the affected material or space as indicated in the RPF SOW and Report and additional inspection and testing will be required to satisfy regulatory obligations associated with renovation, demolition, maintenance and other occupational safety and health requirements. Collected samples were individually placed into sealed containers, labeled, and submitted with proper chain of custody forms to the RPF NVLAP-accredited vendor laboratory. Sample containers and tools were cleaned after each sample was collected. Samples were analyzed for asbestos content using polarized light microscopy (PLM). Although PLM is the method currently recognized in State and federal regulations for asbestos identification in bulk samples, PLM may not be sensitive enough to detect all of the asbestos fibers in certain types of materials, such as floor tile and other nonfriable ACBM. In the event that more definitive results are requested in cases of with negative or trace results of asbestos are detected, RPF recommends that confirmation testing be completed using transmission electron microscopy. For each homogeneous group of suspect material, a “stop at first positive” (SFP) method may have been employed during the analysis. The SFP method is based on current EPA sampling protocols and means that if one sample within a homogeneous group of suspect material is found to contain >1% asbestos, then further analysis of that specific homogenous group samples is terminated and the entire homogeneous group of material is considered to be ACBM regardless of the other sample results. This is based on the potential for inconsistent mix of asbestos in the product yielding varying findings across the different individual samples collected from the same homogeneous group. Unless otherwise noted in the report, sample groups found to have 1% to <10% asbestos content are assumed to be ACBM; to rebut this assumption further analysis with point count methods are required. Inaccessible and hidden areas, including but not limited to wall/floor/ceiling cavity space, space with obstructed access (such as fiberglass insulation above suspended ceilings), sub floors, interiors of mechanical and process equipment, and similar spaces were not included in the inspection and care should be used when accessing these areas in the future. Unless otherwise noted in the RPF Report, destructive survey techniques were not employed during this survey. In the event that additional suspect materials are encountered that are not addressed in this report, the materials should be properly tested by an accredited inspector. For example, during renovation and demolition it is likely that additional suspect material will be encountered and such suspect materials should be assumed to be hazardous until proper inspection and testing occurs. RPF followed applicable industry standards; however, various assumptions and limitations of the methods can result in missed materials or misidentification of materials due several factors including but not limited to: inaccessible space due to physical or safety constraints, space that is difficult to reach to fully inspection, assumptions regarding the determination of homogenous groups of suspect material, assumptions regarding attempts to conduct representative sampling, and potential for varying mixtures and layers of material sampled not being representative of all areas of similar material. Also reference the Limitations document attached to the report.

Summary of Methodology: Lead in Paint Survey Screening for lead in paint (LP) was performed using bulk sampling of paint or using an X-Ray Fluorescence (XRF) meter for in situ measurements of various painted surfaces. For bulk sampling, samples for determinations were collected by scraping lead paint chips from the substrate. The surveyor attempted to sample layers of paint down to the substrate surface at each sample location. Samples were placed into proper sample containers, the containers were then sealed, labeled and shipped with chain of custody to the RPF AIHA accredited vendor laboratory. The samples were analyzed for total lead content using SW 846 3050B - NIOSH Method 7420. For XRF screening, the device was used and calibrated in accordance with the equipment and industry guidelines applicable for the specific testing performed. Unless specific TCLP waste characterizations were included in the RPF Scope of Work (SOW), further analysis of waste streams for toxicity characteristics including, but not necessarily limited to lead, may be required prior to disposal of the waste stream. Other toxics may also be present including other heavy metals and PCBs and it may also be necessary to conduct waste characterization for these materials. Sampling was limited to the specific components as listed in the RPF Report and testing and survey was not completed on every different surface in every room or area in the building. In addition unless otherwise noted in the RPF Report, surface dust, air and soil testing were not conducted during this survey. In order to conduct thorough hazard assessments for lead exposures, representative surface dust testing and air monitoring throughout the building, LBP testing of all surfaces in the building, and representative soil testing in the exterior areas should be completed. This type of testing and analysis was beyond the SOW for the initial survey The intent of this survey is for lead in construction purposes, not for lead abatement, lead inspections, or lead hazard assessments in residential situations. Specific survey and inspection protocols are required for residential lead-based paint inspections that were not included in the RPF SOW. RPF followed applicable industry standards for construction related identification in nonresidential settings; however, RPF does not warrant or certify that all lead or other hazardous materials in or on the building has been identified and included in this report. Various assumptions and limitations of the methods can result in missed materials or misidentification of materials due several factors including but not limited to: inaccessible space due to physical or safety constraints, space that is difficult to reach to inspect of sample, assumptions regarding the determination of homogenous or like types of paint, assumptions regarding attempts to conduct representative sampling, and potential for varying mixtures and layers of material sampled not being representative of all areas of similar appearing material. Also reference the Limitations document attached to the report.

Summary of Methodology: Polychlorinated Biphenyls, Mercury and Refrigerants Various, accessible fluorescent light fixtures were inspected to determine if the ballasts contain a “No PCBs” label. Ballasts that do not have the “No PCBs” label are assumed to contain PCB. Only limited fixtures were checked based on accessibility and safety concerns. Further inspection will be required during the course of construction, maintenance, renovation and demolition. Various equipment and machinery within the building may also contain PCB oils. Specific findings relating to such equipment and machinery were not included in the RPF SOW. It is common to find fluorescent light bulbs, thermostats and switches are present in buildings. RPF performed a visual inspection of specific areas included in the RPF SOW in an attempt to identify such materials. Findings are limited to the specific accessible space accessed by RPF. Various compressor and refrigerant equipment may be present and is should be assumed that such equipment contains Freon or other chlorofluorocarbons unless otherwise tested or documented. Although general comment may be provided in the RPF Report, the specific identification of all potential Freon and CFCs is not included in the RPF SOW. The findings may or may not be fully representative of all of the entire building. Confirmation testing and analysis of PCB, refrigerants and mercury was not included in the RPF SOW. RPF followed applicable industry standards; however, RPF does not warrant or certify that all hazardous material in or on the building has been identified and included in this report. Various assumptions and limitations of the methods can result in missed materials or misidentification of materials due several factors including but not limited to: inaccessible space due to physical or safety constraints, space that is difficult to reach to fully inspection, electrical safety considerations, and assumptions relating to areas or material being representative of other locations which in fact may not be representative. Also reference the Limitations document attached to the report.

LIMITATIONS

1. The observations and conclusions presented in the Report were based solely upon the services described herein, and not on scientific tasks or procedures beyond the RPF Environmental, Inc. Scope of Work (SOW) as discussed in the proposal and/or agreement. The conclusions and recommendations are based on visual observations and testing, limited as indicated in the Report, and were arrived at in accordance with generally accepted standards of industrial hygiene practice and asbestos professionals. The nature of this survey or monitoring service was limited as indicated herein and in the report or letter of findings. Further testing, survey, and analysis is required to provide more definitive results and findings.

2. For site survey work, observations were made of the designated accessible areas of the site as indicated in

the Report. While it was the intent of RPF to conduct a survey to the degree indicated, it is important to note that not all suspect ACBM material in the designated areas were specifically assessed and visibility was limited, as indicated, due to the presence of furnishings, equipment, solid walls and solid or suspended ceilings throughout the facility and/or other site conditions. Asbestos or hazardous material may have been used and may be present in areas where detection and assessment is difficult until renovation and/or demolition proceeds. Access and observations relating to electrical and mechanical systems within the building were restricted or not feasible to prevent damage to the systems and minimize safety hazards to the survey team.

3. Although assumptions may have been stated regarding the potential presence of inaccessible or concealed

asbestos and other hazardous material, full inspection findings for all asbestos and other hazardous material requires the use of full destructive survey methods to identify possible inaccessible suspect material and this level of survey was not included in the SOW for this project. For preliminary survey work, sampling and analysis as applicable was limited and a full survey throughout the site was not performed. Only the specific areas and /or materials indicated in the report were included in the SOW. This inspection did not include a full hazard assessment survey, full testing or bulk material, or testing to determine current dust concentrations of asbestos in and around the building. Inspection results should not be used for compliance with current EPA and State asbestos in renovation/demolition requirements unless specifically stated as intended for this use in the RPF report and considering the limitations as stated therein and within this limitations document.

4. Where access to portions of the surveyed area was unavailable or limited, RPF renders no opinion of the condition and assessment of these areas. The survey results only apply to areas specifically accessed by RPF during the survey. Interiors of mechanical equipment and other building or process equipment may also have asbestos and other hazardous material present and were not included in this inspection. For renovation and demolition work, further inspection by qualified personnel will be required during the course of construction activity to identify suspect material not previously documented at the site or in this survey report. Bordering properties were not investigated and comprehensive file review and research was not performed.

5. For lead in paint, observations were made of the designated accessible areas of the site as indicated in the Report. Limited testing may have been performed to the extent indicated in the text of the report. In order to conduct thorough hazard assessments for lead exposures, representative surface dust testing, air monitoring and other related testing throughout the building, should be completed. This type of in depth testing and analysis was beyond the scope of services for the initial inspection. For lead surveys with XRF readings, it is recommended that surfaces found to have LBP or trace amount of lead detected with readings of less than 4 mg/cm2 be confirmed using laboratory analysis if more definitive results are required. Substrate corrections involving destructive sampling or damage to existing surfaces (to minimize XRF read-through) were not completed. In some instances, destructive testing may be required for more accurate results. In addition, depending on the specific thickness of the paint films on different areas of a building component, differing amounts of wear, and other factors, XRF readings can vary slightly, even on the same building component. Unless otherwise specifically stated in the scope of services and final report, lead testing performed is not intended to comply with other state and federal regulations pertaining to childhood lead poisoning regulations.


6. Air testing is to be considered a “snap shot” of conditions present on the day of the survey with the understanding that conditions may differ at other times or dates or operational conditions for the facility. Results are also limited based on the specific analytical methods utilized. For phase contrast microscopy (PCM) total airborne fiber testing, more sensitive asbestos-specific analysis using transmission electron microscopy (TEM) can be performed upon request.

7. For asbestos bulk and dust testing, although polarize light microscopy (PLM) is the method currently

recognized in State and federal regulations for asbestos identification in bulk samples, some industry studies have found that PLM may not be sensitive enough to detect all of the asbestos fibers in certain nonfriable material, vermiculate type insulation, soils, surface dust, and other materials requiring more sensitive analysis to identify possible asbestos fibers. In the event that more definitive results are requested, RPF recommends that confirmation testing be completed using TEM methods or other analytical methods as may be applicable to the material. Detection of possible asbestos fibers may be made more difficult by the presence of other non-asbestos fibrous components such as cellulose, fiber glass, etc., by binder/matrix materials which may mask or obscure fibrous components, and/or by exposure to conditions capable of altering or transforming asbestos. PLM can show significant bias leading to false negatives and false positives for certain types of materials. PLM is limited by the visibility of the asbestos fibers. In some samples the fibers may be reduced to a diameter so small or masked by coatings to such an extent that they cannot be reliably observed or identified using PLM.

8. For hazardous building material inspection or survey work, RPF followed applicable industry standards; however, RPF does not warrant or certify that all asbestos or other hazardous materials in or on the building has been identified and included in this report. Various assumptions and limitations of the methods can result in missed materials or misidentification of materials due to several factors including but not limited to: inaccessible space due to physical or safety constraints, space that is difficult to reach to fully inspect, assumptions regarding the determination of homogenous groups of suspect material, assumptions regarding attempts to conduct representative sampling, and potential for varying mixtures and layers of material sampled not being representative of all areas of similar material.

9. Full assessments often requires multiple rounds of sampling over a period of time for air, bulk material, surface dust and water. Such comprehensive testing was beyond the scope of RPF services. In addition clearance testing for abatement, as applicable, was based on the visual observations and limited ambient area air testing as indicated in the report and in accordance with applicable state and federal regulations. The potential exists that microscopic surface dust remains with contaminant present even in the event that the clearance testing meets the state and federal requirements. Likewise for building surveys, visual observations are not sufficient alone to detect possible contaminant in settled dust. Unless otherwise specifically indicated in the report, surface dust testing was not included in the scope of the RPF services.

10. For abatement or remediation monitoring services: RPF is not responsible for observations and test for

specific periods of work that RPF did not perform full shift monitoring of construction, abatement or remediation activity. In the event that problems occurred or concerns arouse regarding contamination, safety or health hazards during periods RPF was not onsite, RPF is not responsible to provide documentation or assurances regarding conditions, safety, air testing results and other compliance issues. RPF may have provided recommendations to the Client, as needed, pertaining to the Client’s Contractor compliance with the technical specifications, schedules, and other project related issues as agreed and based on results of RPF monitoring work. However, actual enforcement, or waiving of, contract provisions and requirements as well as regulatory liabilities shall be the responsibility of Client and Client’s Contractor(s). Off-site abatement activities, such as waste transportation and disposal, were not monitored or inspected by RPF.

11. For services limited to clearance testing following abatement or remediation work by other parties: The testing was limited to clearance testing only and as indicated in the report and a site assessment for possible environmental health and safety hazards was not performed as part of the scope of this testing. Client, or Client’s abatement contractor as applicable, was responsible for performing visual inspections


of the work area to determine completeness of work prior to air clearance testing by RPF.

12. For site work, including but not limited to air clearance testing services, in which RPF did not provide full site safety and health oversight, abatement design, full shift monitoring of all site activity, RPF expresses no warranties, guarantees or certifications of the abatement work conducted by the Client or other employers at the job site(s), conditions during the work, or regulatory compliance, with the exception of the specific airborne concentrations as indicated by the air clearance test performed by RPF during the conditions present for the clearance testing. Unless otherwise specifically noted in the RPF Report, visual inspections and air clearance testing results apply only to the specific work area and conditions present during the testing. RPF did not perform visual inspections of surfaces not accessible in the work area due to the presence of containment barriers or other obstructions. In these instances, some contamination may be present following RPF clearance testing and such contamination may be exposed during and after removal of the containment barriers or other obstructions following RPF testing services. Client or Client’s Contractor is responsible for using appropriate care and inspection to identify potential hazards and to remediate such hazards as necessary to ensure compliance and a safe environment.

13. The survey was limited to the material and/or areas as specifically designated in the report and a site assessment for other possible environmental health and safety hazards or subsurface pollution was not performed as part of the scope of this site inspection. Typically, hazardous building materials such as asbestos, lead paint, PCBs, mercury, refrigerants, hydraulic fluids and other hazardous product and materials may be present in buildings. The survey performed by RPF only addresses the specific items as indicated in the Report.

14. For mold and moisture survey services, RPF services did not include design or remediation of moisture intrusion. Some level of mold will remain at the site regardless of RPF testing and Contractor or Client cleaning efforts. RPF testing associated with mold remediation and assessments is limited and may or may not be representative of other surfaces and locations at the site. Mold growth will occur if moisture intrusion deficiencies have not been fully remedied and if the site or work areas are not maintained in a sufficiently dry state. Porous surfaces in mold contaminated areas which are not removed and disposed of will likely result in future spore release, allergen sources, or mold contamination.

15. Existing reports, drawings, and analytical results provided by the Client to RPF, as applicable, were not verified and, as such, RPF has relied upon the data provided as indicated, and has not conducted an independent evaluation of the reliability of these data.

16. Where sample analyses were conducted by an outside laboratory, RPF has relied upon the data provided, and has not conducted an independent evaluation of the reliability of this data.

17. All hazard communication and notification requirements, as required by U.S. OSHA regulation 29 CFR

Part 1926, 29 CFR Part 1910, and other applicable rules and regulations, by and between the Client, general contractors, subcontractors, building occupants, employees and other affected persons were the responsibility of the Client and are not part of the RPF SOW.

18. The applicability of the observations and recommendations presented in this report to other portions of the site was not determined. Many accidents, injuries and exposures and environmental conditions are a result of individual employee/employer actions and behaviors, which will vary from day to day, and with operations being conducted. Changes to the site and work conditions that occur subsequent to the RPF inspection may result in conditions which differ from those present during the survey and presented in the findings of the report.

APPENDIXE

RPF’SHBMABATEMENTDESIGNPLANS

APPENDIXE.1

ASBESTOSABATEMENTSPECIFICATIONS

© RPF Environmental Inc. April 10, 2018 Asbestos Abatement & Related Work Page 1 of 34

ASBESTOS ABATEMENT & RELATED WORK

Swanton Municipal Lot – Corrective Action Plan 1-3-5 Canada Street & Merchants Row

Swanton, Vermont

Contents PART 1 – GENERAL 2

1.1 RELATED DOCUMENTS 2 1.2 PROJECT SCOPE-OF-WORK 2 1.3 WORK SCHEDULES 2 1.4 CONTRACTOR ESTIMATES 3 1.5 EXISTING CONDITIONS 3 1.6 POTENTIAL ASBESTOS HAZARD 3 1.7 CONTRACTOR USE OF PREMISES 4 1.8 STOP WORK 4 1.9 PROJECT COORDINATION 4 1.10 STANDARDS 5 1.11 CODES, REGULATIONS, AND STANDARDS 6 1.12 DEFINITIONS 7 1.13 NOTICES 11 1.14 SUBMITTAL REQUIREMENTS 11 1.15 AIR MONITORING 13 1.16 TEMPORARY FACILITIES 15 1.17 PRESSURE DIFFERENTIAL AND AIR CIRCULATION SYSTEM 16 1.18 WORKER PROTECTION 16 1.19 TEMPORARY ENCLOSURES 18

PART 2 - PRODUCTS 18

2.1 PRODUCTS 18 2.2 WATER SERVICE 20 2.3 ELECTRICAL SERVICE 20 2.4 PRESSURE DIFFERENTIAL AND FILTRATION 20 2.5 AUXILIARY GENERATOR 21

PART 3 – EXECUTION 21

3.1 TEMPORARY ENCLOSURES 21 3.2 REMOVAL OF ASBESTOS-CONTAINING MATERIALS 24 3.3 INITIAL CLEAN-UP WORK 30 3.4 PROJECT DECONTAMINATION 30 3.5 WORK AREA CLEARANCE 32 3.6 DISPOSAL OF ASBESTOS-CONTAINING WASTE MATERIAL 32 3.7 RESTORATION AND REPLACEMENT 33 3.8 ASBESTOS PROJECT CLOSEOUT 33


PART 1 – GENERAL 1.1 RELATED DOCUMENTS

A. General provisions of the Contract, including General and Supplementary Conditions and Other Abatement Specification Sections, apply to the work of each of the Specification Sections.

B. This section addresses abatement of asbestos-containing material (ACM) only.

C. Related Work: The following items are closely related to this work but not included in this Section and will be performed under the designated Sections.

1. Lead Specification 2. Universal Waste Specification

1.2 PROJECT SCOPE-OF-WORK

A. General: Furnish all labor, materials, equipment and perform all work required to safely remove, and otherwise abate as indicated herein, transport, and legally dispose of all asbestos-containing materials (ACM) listed in Appendix A. The scope-of-work includes the removal, transport, and disposal of designated ACM at the Swanton Municipal Lot located at 1-3-5 Canada Street & Merchants Row in Swanton, Vermont. All work is to be completed in accordance with the schedules stated herein, in the Contract Documents, and as designated by the Maquam Holdings-Canada Street, LLC (Owner). It is essential that all work be phased and scheduled as required to facilitate Owner’s renovation and upgrade work. All work is to be completed in strict accordance with applicable local, State of Vermont (State), and federal codes and regulations and the requirements stated in this specification and Contract Documents.

B. Reference full inspection reports for discussions and additional information and limitations of

Owner survey. Quantities listed in Table 1 are approximate only and Contractor shall remove all ACM in the work areas.

C. The work areas have or may have other regulated or hazardous materials present that are not

covered in the Section including but not limited to polychlorinated biphenyl (PCB)-containing materials, mercury, lead paint, guano, mold contamination, other hazardous materials and universal waste. Contractor’s OSHA-competent person shall also inspect the work place for other potential hazardous building material during the work. If encountered during the work immediately notify Owner’s Representative. Use only qualified, trained workers to properly remove, package, transport, and dispose (or recycle) of such material in strict compliance with all local, State, and Federal requirements.

1.3 WORK SCHEDULES

A. All work shall be completed in accordance with the schedule requirements as indicated by the Owner and as stated in the Contract Documents.

B. All work shall be strictly coordinated and scheduled by the Contractor as indicated by and approved

by Owner and the Owner’s industrial hygiene consultant (IH Consultant). Work is to be phased as required to facilitate Owner operations, general occupancy of the site, and general construction activity. Contractor must provide proposed daily schedules to Owner and IH Consultant for each


phase of work and each Owner work request. Adequate advance notice shall be provided to Owner and the IH Consultant prior to any schedule changes. Start and completion dates for the work and specific phasing requirements not otherwise specified herein shall be submitted to Owner and IH Consultant for approval.

1.4 CONTRACTOR ESTIMATES

A. Estimates: Contractor shall conduct necessary field measurements and site review as deemed necessary by Contractor to delineate the scope of work and site conditions prior to submittal of bid. Contractor shall note on bid any discrepancies between Contractor field measurements and listings of work stated herein. It is the responsibility of the Contractor to verify all project information and site conditions as necessary to satisfy the Contractor as to the requirements of the work for each specific phase of the project. The Contractor must notify Owner and the IH Consultant of any conflicting information or clarifications required for the preparation of any bids, estimates, and submittal documentation. Unless otherwise stated by Owner, the Contractor is responsible for the removal of all designated ACM at Owner facility, so designated by the Owner.

1.5 EXISTING CONDITIONS

A. Prior to commencement of work, inspect areas in which work will be performed. Prepare a listing and photographs of damage to structure, surfaces, finishes, insulations, and equipment that could be misconstrued as damage resulting from the work. Contractor is responsible for all damages to equipment, furnishings, finishes and building surfaces in the work area and adjacent caused by the Contractor during the course of abatement and general housecleaning. Contractor is responsible for completing all repairs to damaged items/surfaces caused by the work. In addition, all tape, adhesive, and other staining and damage must be fully repaired by Contractor to meet or exceed existing conditions.

1.6 POTENTIAL ASBESTOS HAZARD

A. The work site contains ACM. Review all site survey reports and conduct ongoing inspections of the work areas to identity potential hazardous material that may be encountered. Provide OSHA competent person to supervise and review work procedures and conduct ongoing work area inspections. Properly train all affected personnel at the job site based on the hazards and hazardous material to be encountered, impacted or disturbed including but not limited to ACM.

B. The disturbance or dislocation of ACM may cause asbestos fibers to be released into the buildings atmosphere, thereby creating potential health hazards to workmen and building occupants. Apprise all employers at site, workers, supervisory personnel, subcontractors and consultants who will be at the job site of the seriousness of the hazards, other possible site hazards, and of proper work procedures that must be followed.

C. Where in the performance of the work, workers, supervisory personnel, subcontractors, or consultants may encounter, disturb, or otherwise function in the immediate vicinity of any identified asbestos-containing materials, take appropriate continuous measures as necessary to protect all building occupants from the potential hazard of exposure to airborne asbestos fibers and dust. Such measures shall include the procedures and methods described herein, and compliance with regulations of applicable federal, state and local agencies.

D. Complete, and coordinate with Owner’s Representative as applicable, all communication of hazards in strict accordance with 29 CFR 1926.1101 (k) and other applicable OSHA and State


regulations. The contractor shall coordinate with Owner’s Representative to review all existing inspection records and testing results as needed. Ensure that complete inspections of the space and affected materials have been completed of copies of inspection reports have been provided to the Owner, Contractor site supervisor and other affected contractors and subcontractors at the site as applicable. All site personnel working in areas containing ACM shall be apprised of the locations, types and quantities of ACM present and all such personnel shall be provided a minimum of asbestos awareness level training (for non-asbestos contractors) or additional training as indicated herein. In the event that other suspect material are encountered (or previously inaccessible spaces are accessed) that are not identified in the inspection report as having been properly inventoried and testing, then immediately cease work that would impact such materials and notify Owner’s Representative such that proper testing and inspection can be performed.

1.7 CONTRACTOR USE OF PREMISES

A. General: The Contractor shall limit his use of the site to the work indicated, so as to allow for Owner operations and general construction activity. Confine operations at the site to the specified work areas of the Specification. Take all precautions necessary to protect the site, buildings, any occupants, and surrounding areas from work-related hazards during the construction period. Maintain building in a safe and structurally sound condition throughout the work. Maintain access to the public and other trades in designated areas (for example, stairwells) as indicated herein and as otherwise noted by Owner. Provide additional barriers and site security as needed to accommodate such access. Use care to prevent damages to existing surfaces during installation of solid barriers, critical barriers and primary isolation barriers.

B. Install solid barriers to prevent unauthorized access and visibility from adjacent, public or Owner-occupied areas as designated by Owner and using materials and construction methods approved by Owner. Contractor shall work in cooperation with and coordinate all work with Owner and the IH Consultant.

1.8 STOP WORK

A. If Owner or the IH Consultant presents a written or verbal stop work order immediately and automatically stop all work. Do not recommence work until authorized in writing by Owner and IH Consultant.

1.9 PROJECT COORDINATION

A. Site Supervisor: Provide a full-time Site Supervisor who is experienced in administration and supervision of asbestos abatement projects including work practices, protective measures for building and personnel, disposal procedures, etc. This person is the Contractor's Representative responsible for compliance with the specification and all applicable federal, state and local regulations, particularly those relating to asbestos-containing materials.

1. Experience and Training: The Site Supervisor must have completed a course at an EPA

Training Center or equivalent certificate course in asbestos abatement procedures, and have had a minimum of five (5) years on-the-job training in similar asbestos abatement procedures.

2. Accreditation/Qualifications: The Site Supervisor is to be (1) a Competent Person as required

by OSHA in 29 CFR 1926, and (2) accredited and certified in accordance with the AHERA regulation 40 CFR Part 763, Subpart E, Appendix C; and (3) licensed in accordance with current State requirements.


B. Project Manager: Provide a qualified and experienced project manager to perform administrative

and project management responsibilities and to serve as Contractor management point of contact in addition to the project supervisor.

C. Pre-Construction Conference: An initial progress meeting, recognized as "Pre-Construction

Conference” will be convened by Owner with Contractor prior to the start of work for each phase. This meeting will be held to review the scope-of-work, scheduling, coordination, and contractor plan of action and submittals and other applicable items.

D. Daily Log: Maintain at the work area a daily log documenting the dates and time of but not limited to, the following items: 1. Visitations; authorized and unauthorized 2. Daily sign-in sheet for all personnel entering and leaving the work area (name, certification,

expirations). 3. Special or unusual events, i.e. barrier breaching, equipment failures, accidents 4. Documentation of the following:

a) Supervisor’s daily inspections and exposure monitoring test results b) Work progress each day for each work area c) Removal of waste material (number and type of containers) from each work area d) Removal of waste from site including a copy of the accompanying waste shipment record e) Decontamination of work area and equipment f) Final inspection and air clearance results, and g) Documentation of containment removal and final general housecleaning activity

5. Complete and maintain daily log in accordance with applicable State and federal record

keeping requirements. Provide access to logs to Owner and IH Consultant at all times and provide copies of logs with the submittal package in accordance with the construction submittal requirements.

1.10 STANDARDS

A. Applicability of Standards: It is the Contractor's responsibility to complete all work in accordance with (or exceeding) all applicable industry standards and guidelines. Except where Contract Documents include more stringent requirements, all applicable construction industry standards have the same force and effect as if bound or copied directly into Contract Documents. Applicable construction standards are made a part of the Contract Documents by reference. Where compliance with an industry standard is required, comply with the most current standards in effect as of date of Contract Documents.

B. Conflicting Requirements: Where compliance with two or more standards is specified, and they establish different or conflicting requirements for minimum quantities or quality levels, the most stringent requirement will be enforced, unless the Contract Documents indicate otherwise. Refer to Owner and IH Consultant any requirements that are different or conflicting; outline the more stringent requirement before proceeding.

C. Comply with applicable standards including, but not limited to, American National Standards Institute (ANSI) standards and American Society for Testing and Materials (ASTM) standards.


1.11 CODES, REGULATIONS, AND STANDARDS

A. Adhere to work practices and procedures set forth in applicable codes, regulations and standards related to work. Obtain permits, licenses, inspections, and similar documentation, as well as payments and similar requirements associated with codes, regulations, and standards. Update permits as necessary.

B. The Contractor shall assume full responsibility and liability for compliance with all applicable Federal, State, and local regulations pertaining to work practices, hauling, disposal, and protection of workers, visitors to the site, and persons occupying areas adjacent to the site. The Contractor is responsible for providing medical examinations and maintaining medical records of personnel as required by the applicable Federal, State, and local regulations. The Contractor shall hold Owner and IH Consultant harmless for failure to comply with any applicable work, hauling, disposal, safety, health or other regulation on the part of himself, his employees, or his subcontractors.

C. All work performed under this contract shall comply with applicable provisions, including most current versions, and not limited to the listed and all other applicable local, state and federal codes and regulations.

D. Federal Requirements: which govern asbestos abatement work or hauling and disposal of asbestos waste materials include but are not limited to the following:

OSHA: U.S. Department of Labor, Occupational Safety and Health Administration, including but not limited to:

1. Occupational Exposure to Asbestos, Tremolite, Anthophyllite, and Actinolite; Final Rules 2. 29 CFR 1910.1001 and 29 CFR Part 1926.1101 3. Respiratory Protection: Title 29, Part 1910, Section 134 of the CFR 4. Construction Industry: Title 29, Part 1926, of the CFR and all related Subparts 5. Access to Employee Exposure and Medical Records: 29 CFR, Part 1910, Section 2 6. Hazard Communication: Title 29, Part 1910, Section 1200 of the CFR 7. Specifications for Accident Prevention Signs and Tags: 29 CFR Part 1910, Sec. 145

DOT: U. S. Department of Transportation, including but not limited to:

1. Hazardous Material Regulations: Title 49, Part 171-180 CFR

EPA: U. S. Environmental Protection Agency (EPA), including but not limited to:

1. Asbestos Abatement Projects; Worker Protection Rule: Title 40 Part 763, Sub-part G 2. Asbestos School Hazard Abatement Reauthorization Act (ASHARA) 3. Asbestos Containing Materials in Schools Final Rule 40 CFR Part 763, Sub-part E 4. National Emission Standard for Hazardous Air Pollutants (NESHAPS); National Emission

Standard for Asbestos, 40 CFR Part 61, Sub-part A, and Sub-part M (Revised Sub-part B)

E. Local Requirements: Abide by all local requirement that govern asbestos abatement work or hauling and disposal of asbestos waste materials.

F. State of Vermont Requirements: which govern asbestos abatement work or hauling, and disposal

of asbestos waste materials include but are not limited to the following:


1. Vermont Regulations for Asbestos Control, V.S.A. Title 18, Chapter 26, Effective February 1987; Amended November 1995.

1.12 DEFINITIONS

A. General Definitions: Definitions contained in this Section are not necessarily complete but are general to the extent that they are not defined more explicitly elsewhere in the Contract Documents.

1. Directed: Terms such as "directed", "requested", "authorized", "selected", "approved",

"required", and "permitted" mean "directed by Owner's representative", "requested by the "IH Consultant", and similar phrases. However, no implied meaning shall be interpreted to extend the IH Consultant's responsibility into the Contractor's area of construction supervision.

2. Approve: The term "approved," where used in conjunction with the Owner or the IH

Consultant's action on the Contractor's submittals, applications, and requests, is limited to the responsibilities and duties of the IH Consultant as indicated in the Contract Documents. Such approval or acceptances do not express or claim any certification of completeness, compliance, or approval of programs and documentation, including but not limited to review of analytical results, historical information, and interpretations. Such approval shall not release the Contractor from responsibility to fulfill Contract Document requirements, unless otherwise provided in the Contract Documents.

3. Furnish: The term "furnish" is used to mean "supply and deliver to the project site, ready for

unloading, unpacking, assembly, installation, and similar operations."

4. Install: The term "install" is used to describe operations at project site including the actual "unloading, unpacking, assembly, erection, placing, anchoring, applying, working to dimension, finishing, curing, protecting, cleaning and similar operations."

5. Provide: The term "provide" means "to furnish and install, complete and ready for the intended

use."

6. Installer: An "Installer" is an entity engaged by the Contractor, either as an employee, subcontractor, or sub-subcontractor for performance of a particular construction activity, including installation, erection, application and similar operations. Installers are required to be experienced in the operations they are engaged to perform.

7. IH Consultant: This is the entity employed or engaged as industrial hygiene consultant as

described in the Contract Documents. All references to Owner's Consultant, Air Monitoring Consultant, or Consultant with regard to asbestos abatement in the Contract Documents in all cases refer to the IH Consultant. The IH Consultant will represent Owner during abatement and until final payment is due. The Owner representative may also constitute other persons representing Owner, other than the IH Consultant or consultant, as indicated by Owner. Owner's instructions to the Contractor will be made directly to the Contractor or forwarded through the IH Consultant.

8. Site Supervisor: This is the Contractor's Representative at the work site. This person will be

the Competent Person required by OSHA in 29 CFR 1926 and licensed Site Supervisor/Foreman as required by the State. Provide licensed supervisor at each individual work site during work.


B. Definitions - Asbestos Abatement:

1. Accredited or Accreditation (when referring to a person or laboratory): A person or laboratory accredited in accordance with section 206 of Title II of the Toxic Substances Control Act (TSCA).

2. Adequately Wet: Means sufficiently mix or penetrate with liquid to prevent the release of

particulate. If visible emissions are observed coming from the asbestos-containing material, then that material has not been adequately wetted. The absence of visible emissions is not sufficient evidence, or measure, of a material being adequately wet.

3. Air Monitoring: The process of measuring the fiber content of a specific volume of air.

4. Amended Water: Water to which a surfactant has been added to decrease the surface tension to

35 or less dynes.

5. Asbestos: The asbestiform varieties of serpentinite (chrysotile), riebeckite (crocidolite), cummingtonite-grunerite, anthophyllite, and actinolite-tremolite. For purposes of determining respiratory and worker protection both the asbestiform and non-asbestiform varieties of the above minerals and any of these materials that have been chemically treated and/or altered shall be considered as asbestos.

6. Asbestos-Containing Material (ACM): Any material containing more than 1% of asbestos of

any type or mixture of types.

7. Asbestos-Containing Building Material (ACBM): Surfacing ACM, thermal system insulation ACM, or misc. ACM in or on interior structure or other parts of a building.

8. Asbestos-Containing Waste Material: Any material that is or is suspected of being or any

material contaminated with an asbestos-containing material that is to be removed from a work area for disposal. May also be referred to as “asbestos waste”.

9. Asbestos debris: Pieces of ACBM or ACM that can be identified by color, texture, or

composition, or means dust, if the dust is determined by an accredited inspector to be ACM or reasonably likely to have asbestos fibers present under conditions present and based on work operations.

10. Authorized Visitor: Owner, the IH Consultant, testing lab personnel, emergency personnel or a

representative of any federal, state and local regulatory or other agency having authority over the project.

11. Barrier: Any surface that seals off the work area to inhibit the movement of fibers.

12. Breathing Zone: A hemisphere forward of the shoulders with a radius of approximately 6 to 9

inches. 13. Category I Non-Friable ACM: means ACM packings, gaskets, resilient floor covering, and

asphalt roofing products containing more than 1% asbestos. Also see definition for Regulated ACM.


14. Category II Non-Friable ACM: means any non-friable ACM, except for Category I Non-Friable ACM.

15. Certified Industrial Hygienist (CIH): An industrial hygienist certified in Comprehensive

Practice by the American Board of Industrial Hygiene.

16. Critical Barrier: Polyethylene sheeting, typically 6-mil polyethylene sheeting, over windows, doors, and air passageways separating the work area from non work area portions of the building. Critical barriers remain in place until clearance testing or inspections are completed and results meet clearance test criteria.

17. Demolition: The wrecking or taking out of any building component, system, finish or assembly

of a facility together with any related handling operations.

18. Disposal Bag: A properly labeled 6 mil thick leak-tight plastic bags used for transporting asbestos waste from work and to disposal site.

19. Contractor: The contractor engaged by Owner to perform asbestos related activities must be

licensed by the State, as applicable, and in accordance with Vermont Regulations for Asbestos Control, V.S.A. Title 18, Chapter 26. All workers and site supervisors engaging in asbestos activity must also be trained and licensed in accordance with current State regulations and 40 CFR Part 763 (AHERA).

20. Encapsulant: A material that surrounds or embeds asbestos fibers in an adhesive matrix, to

prevent release of fibers.

a. Bridging encapsulant: an encapsulant that forms a discrete layer on the surface of an in situ asbestos matrix.

b. Penetrating encapsulant: an encapsulant that is absorbed by the in situ asbestos matrix without leaving a discrete surface layer.

21. Encapsulation: Treatment of asbestos-containing materials, with an encapsulant and application

of appropriate post removal encapsulant on substrate and containment barriers.

22. Enclosure: The construction of an air-tight, impermeable, permanent barrier around asbestos-containing material to control the release of asbestos fibers into the air.

23. Excursion Limit: Ensure that no employee is exposed to airborne concentrations of asbestos in

excess of 1.0 fibers per cubic centimeter of air (1.0 f/cc) as averaged over a sampling period of thirty (30) minutes, as determined by PCM analysis in accordance with NIOSH Method 7400 and as indicated in 29 CFR Part 1926. Also referred to as the short-term exposure limit, (STEL).

24. Friable Asbestos Material: Material that contains more than 1.0% asbestos and that can be

crumbled, pulverized, or reduced to powder by hand pressure when dry. This also includes materials which, when subjected to removal methods and other disturbances, may release fibers and dust due to the abatement actions.

25. Glovebags: Glovebags for removal of insulation in accordance with 29 CFR Part 1926.

26. HEPA Filter: A High Efficiency Particulate Air (HEPA) filter capable of trapping and retaining

99.97% of asbestos fibers greater than 0.3 microns in diameter.


27. HEPA Filter Vacuum Collection Equipment (or vacuum cleaner): High efficiency particulate

air filtered vacuum collection equipment with a filter system capable of collecting and retaining asbestos fibers. Filters should be of 99.97% efficiency for retaining fibers of 0.3 microns or larger.

28. Negative Pressure Respirator: A respirator in which the air pressure inside the respiratory-inlet

covering is positive during exhalation in relation to the air pressure of the outside atmosphere and negative during inhalation in relation to the air pressure of the outside atmosphere.

29. Permissible exposure limit (PEL): The Contractor shall ensure that no employee is exposed to

an airborne fiber concentration of asbestos in excess of 0.1 f/cc of air as an eight (8) hour time-weighted average (TWA) in accordance with 29 CFR Part 1926.

30. Personal Monitoring: Sampling of the asbestos fiber concentrations within the breathing zone

of an employee.

31. Pressure Differential and Ventilation System: A local exhaust system, utilizing HEPA filtration capable of maintaining a pressure differential with the inside of the Work Area at a lower pressure than any adjacent area, and which cleans re-circulated air or generates a constant air flow from adjacent areas into the Work Area.

32. Regulated ACM (RACM): RACM means friable ACM, Category I Non-friable ACM that has

been rendered friable, Category I ACM that will be or has been subjected to sanding, cutting, grinding, or abrading (abrasive action), or Category II Non-friable ACM that has a high probability of becoming, or has become, crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of renovation or demolition operations. Grinding means breaking into small pieces or fragments.

33. Repair: Returning damaged ACBM or ACM to an undamaged condition or to an intact state so

as to prevent fiber release.

34. Respirator: A device designed to protect the wearer from the inhalation of harmful atmospheres.

35. Time Weighted Average (TWA): The average concentration of a contaminant in air during a specific time period.

36. Visible Emissions: Any emissions, coming from RACM, ACM, ACBM, asbestos debris or

asbestos waste material, which is visually detectable without the aid of instruments. This does not include condensed uncombined water vapor.

37. Waste Shipment Record: Means the shipping document, required to be originated and signed

by the waste generator, used to track and substantiate the disposition of Asbestos waste.

38. Wet Cleaning: The process of eliminating asbestos contamination from building surfaces and objects by using clothes, mops, or other cleaning utensils which have been dampened with amended water and afterwards thoroughly decontaminated or disposed of as asbestos-contaminated waste.


39. Work Area: The area where asbestos-related work or removal operations are performed which is defined and/or isolated to prevent the spread of asbestos dust, fibers or debris, and entry by unauthorized personnel. Work area is a Regulated Area as defined by 29 CFR 1926.

1.13 NOTICES

A. U.S. Environmental Protection Agency: Send proper written notification as required by USEPA National Emission Standards for Hazardous Air Pollutants (NESHAPS) Asbestos Regulations (40 CFR 61, Subpart M) to the regional Asbestos NESHAPS Contact - Reno/Demo Clerk - at least 10 working days prior to beginning any work which will directly or indirectly result in disturbance of asbestos-containing materials. Post notifications at job site.

B. State and Local Agencies: Send written notification as required by state and local regulations prior

to beginning any work on asbestos-containing materials. At least 10 working days prior to the start of work, submit appropriate notification to the Vermont Department of Health. Post notifications at job site.

C. Permits: Obtain all local, state and federal permits necessary to conduct the work of this

specification. Obtain water permits as necessary for release of any water originating from the Work. Notify all local emergency agencies of the abatement work to be completed as required. All asbestos containing waste is to be transported by an entity maintaining a current "DOT Common Hauler Permit" specifically for asbestos-containing materials, as required for transporting of waste asbestos-containing materials to a disposal site.

D. Licenses: Maintain current licenses as required by applicable state and local jurisdictions for the

removal, transporting, disposal or other regulated activity relative to the work of this contract. Post all company, supervisor, and worker licenses at work area entrance.

E. Posting and Filing of Regulations: Post all notices required by applicable federal, state and local

regulations. Maintain at least one (1) copy of applicable federal, state and local regulations and standards at each job site. Post copies of the specification at the job site.

F. Coordinate with Owner and local fire department authorities the notification and handling of heat and smoke detectors in the work areas, including sealing of detectors during work and removal of seals at the completion of work or shifts.

1.14 SUBMITTAL REQUIREMENTS

A. Submittal Schedule: Submittals will be provided by the Contractor as specified herein including (1) Preconstruction Submittal Documentation prior to start of work and (2) Project Closeout Submittals within 25 days upon completion of on-site work. Submit ongoing submittals as required herein and as specified by the Owner and IH Consultant. Provide at the job site a copy of all current submittal packages and related documentation. Ongoing submittals will also be submitted during the work as required to update the Pre-construction and Closeout submittals including, but not limited to:

1. Schedule or phasing changes, including description and explanations as applicable.

2. Proposed alternative work methods. Requests for revisions in work procedures must be

approved by the Owner and IH Consultant.


3. Updated notifications and permitting.

4. Changes to licenses and training records for all personnel at the site

5. Other changes or revisions to the submittals.

B. Submittal Preparation

1. Package and furnish to Owner and IH Consultant each submittal appropriately. Submittal packages shall be in a neat and orderly fashion, will include an index, and shall be compiled in the order requested herein. Clearly mark and label all sections of the submittal documents.

2. In the event that a submittal package does not meet the requirements herein the submittal may

not be accepted, and the Contractor will make necessary revisions and re-submit the submittal documents.

3. By “approval” or acceptance of submittals, Owner and IH Consultant do not express or claim

any certification of completeness, compliance, or approval of programs and documentation, not limited to review of analytical results, historical information, regulatory compliance, and interpretations. Contractor is solely responsible for compliance with Specification and regulatory requirements associated with the work and submittal documentation.

C. Preconstruction Submittal Documentation

1. Provide the following Preconstruction Submittal Documentation prior to the start of each phase

of work:

a) Notifications: Copies of EPA, State, and local notifications.

b) Waste Hauler and Landfill Permits and notifications. Submit names, address, and licenses/permits for the waste hauler(s) and disposal facilities.

c) Names, addresses, experience, and references for any subcontractors the Contractor proposes to utilize for Work. Indicate if any asbestos workers or supervisors to be used for Work are subcontracted labor.

d) Names and 24-hour phone numbers/pagers for Project Supervisor and other key personnel for the Contractor. Post emergency contact information at Decontamination Unit entrance.

e) List of personnel to be on-site. Copies of all company, supervisor, and worker licenses, training

and certifications required in accordance with this Specification.

f) Notarized Certifications: Submit notarized certification signed by an officer of the Contract stating that exposure measurements, respiratory protection programs, medical surveillance, worker training, and recordkeeping has and will be completed and maintained during the Work for all involved personnel in accordance with 29 CFR Part 1926 and other applicable State and federal regulations.

g) Certify the dates for primary and secondary HEPA filter changes for all negative air units.


h) Level of respiratory protection anticipated for each operation required by the project. Include supporting documentation of previous exposure monitoring on a sufficient number similar project and operations in accordance with OSHA requirements.

i) Detailed schedule and phasing, containment layouts, and summary of approach; detail of any special work procedures or methods to be used if not included or addressed in the abatement specification.

j) Safety Data Sheets: for all materials to be used on-site not limited to encapsulants, spray adhesives, and other related work material. Note: It is Contractor's responsibility to notify all other contractors and parties in accordance with applicable OSHA hazard communication regulations.

k) Contingency Plan: Prepare a site-specific contingency plan for emergencies including fire, accident, power failure, pressure differential system failure, supplied air system failure, or any other event that may require modification or abridgement of decontamination or work area isolation procedures. Include in plan specific procedures for decontamination or work area isolation. Note that nothing in this specification should impede safe exiting or providing of adequate medical attention in the event of an emergency. The emergency contingency plan must be in accordance (meet or exceed the requirements of) with applicable OSHA requirements.

l) Other submittals required by the Contract Documents or as indicated by Owner.

D. Closeout Submittals

1. The following Closeout Submittals will be provided upon substantial completion of Work.

a) Copies of all daily logs in accordance with Section 1.9 Project Coordination of this

specification. b) A copy of each waste shipment record, hazardous waste manifest, and chain-of-custody form,

signed by the transporter and disposal facility operator, indicating that waste was packaged and disposed of properly. Include a description of any temporary storage facilities used including, dates, times, and locations of temporary storage. Note: In accordance with NESHAPS, submit all waste shipment documentation within 35 days from transport of waste from the site (provide interim submittals during the work as needed to comply with federal regulations). Note: copies of waste shipment records in progress shall also be provided to IH Consultant and Owner immediately upon removal of waste from site.

c) Complete copy of all revisions and changes to the Pre-Construction Submittals.

d) Copy of other written construction documents such as Change Orders and work modifications

issued in printed form during construction. Mark these documents and a site drawing to show the work completed and to show substantial variations in actual work performed in comparison with the text of the Specifications and modifications.

1.15 AIR MONITORING

A. Ambient Area Air Monitoring: IH Consultant will/may monitor ambient area airborne fiber counts in and around the Work Area. The purpose of this air monitoring will be to detect airborne asbestos


concentrations that may challenge the ability of the Work Area isolation procedures to protect the balance of the building or outside of the building from contamination by airborne fibers and to monitor concentrations outside the containment or work area perimeter.

B. Clearance Air Monitoring: Refer to Work Area Clearance section of this specification.

C. Stop Action Levels

1. Inside Work Area: Maintain an average airborne count in the Work Area of less than 0.10 fibers

per cubic centimeter. If the fiber counts rise above this figure for any sample taken, revise work procedures and engineering controls to lower fiber counts.

2. Outside Work Area: If any air sample taken outside of the Work Area exceeds 0.010 f/cc,

immediately and automatically stop all work except corrective action necessary to address elevated concentrations. If it is determined by Owner or IH Consultant that the elevated concentration was the result of a failure of Work Area isolation measures or Contractor work methods, initiate the following actions:

a) Erect additional critical barriers to isolate the affected area b) Install HEPA filtration negative air units in affected area c) Decontaminate the affected area in accordance with appropriate cleaning procedures. d) Require that respiratory protection and personal protective equipment is used in affected

area until area is cleared for re-occupancy in accordance with the work area clearance requirements.

3. Effect on Contract Sum: Complete corrective work with no change in the Contract Price or Sum

if high airborne fiber counts were caused by Contractor activities.

D. Analytical Methods: Owner reserves the right to use either phase contrast microscopy (PCM) and/or transmission electron microscopy (TEM) to analyze air samples. PCM analysis will be performed using the NIOSH 7400 method at the job site or at an off-site laboratory. TEM may also be used as Owner deems necessary for ambient area air samples using the analysis method as determined by IH Consultant. Also see Work Area Clearance section.

E. Schedule of Air Samples

1. Prior to the start of work: The IH Consultant may collect air samples to establish a base line

before start of work. Base line is an action level expressed in fibers per cubic centimeter that is twenty-five percent greater than the largest of the following:

a) Average of the PCM samples collected outside each Work Area b) Average of the PCM samples collected outside the building c) And 0.010 f/cc

2. Daily: From start of work involving Temporary Enclosures through the work of Project

Decontamination, IH Consultant may be collecting samples during the Work, including but not necessarily limited to:

a) At HEPA Exhaust areas b) Non-work-area portions of the building c) At entrance to the Decontamination Unit


d) Outside the building e) Clearance sampling: See the Air Clearance Requirements.

F. Laboratory Testing:

1. The services of a testing laboratory will be employed by Owner to perform laboratory analyses

of the air samples. Samples will be sent overnight on a daily basis, so that verbal reports on air samples can be obtained within 24 hours. Results of all air monitoring tests will be available at the job site on a daily basis.

G. OSHA Monitoring and Additional Testing:

1. Additional Testing: The Contractor may conduct his own air monitoring and laboratory testing.

If he elects to do this the cost of such air monitoring and laboratory testing shall be at no additional cost to Owner.

2. OSHA Compliance and Ambient Area Monitoring: Contractor must provide for collection and

laboratory analysis services of Contractor's OSHA personal exposure samples, including daily TWA and STEL monitoring for asbestos and other contaminants resulting from the Work, including but not limited to carbon monoxide, volatile organic compounds, and chemical exposures.

1.16 TEMPORARY FACILITIES

A. General: Provide temporary connection to existing building utilities or provide temporary facilities as required to complete work. Owner must approve all connections to utilities and facility components. Provide temporary portable water and power sources for all exterior work as indicated and coordinated with Owner, as applicable.

B. Water Service:

1. Temporary Water Service Connection: Provide hot and cold water to the Work Area. Provide

a qualified and experienced licensed plumber as necessary to complete all water service work in conformance with applicable building codes and regulations.

2. All connections to the Owner's water system shall include back-flow protection. Monitor for leaks and repair or replace as needed.

3. Water Hoses: Employ suitable heavy-duty abrasion-resistant hoses to provide water into each

work area and to each Decontamination Unit.

C. Electrical Service:

1. General: Provide a qualified and experienced licensed electrician to complete all electrical service work. Comply with applicable OSHA, NEMA, NECA, UL and other industry standards and governing regulations for materials and layout of temporary electric service. Provide adequate temporary power to the Work Area sized and equipped to accommodate all electrical equipment required for completion of the work and related testing and inspections. Provide temporary electrical panel as needed sized and equipped to accommodate all electrical equipment and lighting required by the work. Connect temporary panel to existing building electrical system. Protect with circuit breaker or fused disconnect. Locate temporary panel


outside of the work area and in a location acceptable to Owner. Equip all circuits for any purpose entering Work Area with ground fault circuit interrupters (GFCI).

2. Lamps and Light Fixtures: Provide appropriate temporary work area lighting. Protect lamps

with guard cages or tempered glass enclosures where fixtures are exposed to breakage by construction operations.

D. First Aid: Comply with governing regulations and recognized recommendations within the

construction industry. Provide appropriate first aid supplies.

E. Fire Extinguishers: Provide appropriate fire extinguishers for temporary offices, storage, work areas and other portions of the site occupied or used by Contractor for the work.

F. Execution: Use qualified tradesmen for installation of temporary services and facilities. Locate

temporary services and facilities where they will serve the entire project adequately and result in minimum interference with the performance of the Work. Coordinate all such work with Owner. Require that tradesmen be licensed as required by local authorities. Relocate, modify and extend services and facilities as required during the course of work so as to accommodate the entire work of the project.

1.17 PRESSURE DIFFERENTIAL AND AIR CIRCULATION SYSTEM

A. Continuously monitor and record the pressure differential between the Work Area and the building outside of the Work Area. Maintain accurate records of time and locations of testing on-site and in daily logs.

B. HEPA Filtered Fan Units: Supply the required number of HEPA filtered fan units to the site in

accordance with these specifications. Units must meet the requirements of all applicable regulations and standards.

1.18 WORKER PROTECTION

A. Comply with respiratory protection requirements as specified in this specification and applicable regulations. Provide worker protection as required by the most stringent OSHA and/or EPA regulations and industry standards applicable to the work. The following procedures are minimum requirements to be adhered to regardless of fiber concentrations in the Work Area.

B. Worker Training

1. AHERA Accreditation: All workers are to be accredited as Abatement Workers as required by

the AHERA regulation 40 CFR 763 Appendix C to Subpart E, April 30, 1987. All training must be current including current annual refresher training.

2. Train all supervisors and workers in accordance with EPA NESHAPs and 29 CFR Part 1926

(OSHA) for asbestos and other hazards anticipated during the work. All workers and supervisors must be licensed and certified as required by applicable State regulations.

C. Medical Examinations: Provide medical examinations for all workers who will enter the Work Area

for any reason in accordance with OSHA requirements as set forth in 29 CFR 1926 and 29 CFR 1910.20.


D. Protective Clothing

1. Coveralls: Provide cloth full-body coveralls and hats, and require that they be worn by all workers in the Work Area. Require that workers change out of coverall in the Equipment Room of the Personnel Decontamination Unit. Dispose of used coverall as asbestos waste.

2. Other: Provide other personal protective equipment as required by OSHA regulations and

industry standards, not limited to: hard hats, eye protection (goggles), gloves, fall safety, and footwear.

E. Entering Work Area: Each time Work Area is entered, remove all street clothes in the changing

(clean) room of the personnel decontamination unit and put on new disposable coverall, new head cover, and a clean respirator. Proceed through shower room to equipment room and put on work boots. Only properly licensed/certified personnel shall enter the decontamination unit and work area. All personnel entering the work area must post their State license at the decontamination unit entrance.

F. Decontamination Procedures: Require all workers to adhere to the following personal

decontamination procedures whenever they leave the Work Area:

1. HEPA vacuum all gross debris from the protective clothing prior to entering the equipment room of the decontamination unit. When exiting area, remove disposable coveralls, disposable head covers, and disposable footwear covers or boots in the equipment room.

2. Still wearing respirators, proceed to showers. Showering is mandatory. Care must be taken to

follow reasonable procedures in removing the respirator to avoid asbestos fibers while showering. The following procedure is required as a minimum:

3. Carefully wash face piece of respirator inside and out. Each worker leaving the work area must

shower completely with soap and water. Rinse thoroughly. Proceed from shower to clean room and change into street clothes or into new disposable work items.

G. Within Work Area: Require that workers NOT eat, drink, smoke, chew tobacco or gum, or apply

cosmetics in the Work Area. Maintain proper use of personnel protective equipment.

H. Respiratory Protection: Provide sufficient respiratory protection in accordance with applicable OSHA requirements in addition to ANSI and NIOSH standards. Select proper level of protection based on personnel exposure monitoring and the applicable OSHA Permissible Exposure Limits. Require that respiratory protection be used at all times that there is any possibility of disturbance of asbestos-containing materials whether intentional or accidental. 1. Instruct and train each worker for proper respirator use in accordance with OSHA and other

applicable industry standards. Require that a respirator be worn by anyone in a Work Area at all times, regardless of activity, until the area has been cleared for re-occupancy.

2. Provide and complete all necessary fit testing for respiratory protection in strict accordance with

applicable OSHA regulations. 3. In the event that applicable OSHA PEL's (8-hour TWA and 30-minute STEL) are exceeded,

stop work. Do not recommence work until work procedures, including use of engineering controls, are modified to maintain exposures within the acceptable PEL's.


I. Complete all lock-out and tag-out of power and air handling systems within the Work Area in

accordance with OSHA regulations. Coordinate all lock-out and tag-out with Owner. 1.19 TEMPORARY ENCLOSURES

A. Work areas are to be considered contaminated during the work and shall be completely isolated from other locations such that asbestos fibers cannot pass through or beyond the perimeters of the work area and into non-work areas. Should areas beyond the work area become contaminated with asbestos as a result of the Contractor's work, the Contractor shall be responsible for cleaning non-work areas as required. All costs including cleaning, decontaminating, monitoring and testing shall be borne by the contractor.

B. Contractor shall construct temporary containment enclosures in each work area. Prior to proceeding

with ACM abatement coordinate and complete inspections of the work area with the IH Consultant. Proceed with work sequentially as listed or indicated.

C. Disable ventilating systems or any other system bringing air into or out of the Work Area. Disable

system by disconnecting wires, removing circuit breakers, by lockable switch or other positive means that will prevent accidental premature restarting of equipment as approved by Owner.

PART 2 - PRODUCTS

2.1 PRODUCTS

A. Provide new or used materials and equipment that are undamaged and in serviceable condition. Provide only materials and equipment that are recognized as being suitable for the intended use and in strict compliance with appropriate standards. Do not bring products, materials, and equipment to the Owner's site or Owner work areas that are damaged or contain construction or potential contaminated debris.

B. Warning Signs, Caution Signs and Demarcation: Provide all demarcation, warning signs, caution

signs, and other postings required for the work and in accordance with State and federal codes and regulations.

C. Polyethylene Sheet: A single polyethylene film in the largest sheet size possible to minimize seams,

in 6.0 mil thickness, clear or black as indicated.

D. Duct Tape: Provide duct tape in 3" widths with an adhesive, which is formulated to stick aggressively to sheet polyethylene.

E. Spray Cement: Provide spray adhesive in aerosol cans which is specifically formulated to stick

tenaciously to sheet polyethylene.

F. Foam Pack: Provide foam pack for sealing small crevices and cracks at critical barriers as required. All foam pack must be approved by Owner and local authorities, not limited to the Fire Department.

G. Scaffolding: Provide all scaffolding, ladders and/or staging, etc. as necessary to accomplish the

work of this contract. Scaffolding may be of suspension type or standing type such as metal tube and coupler, tubular welded frame, pole or outrigger type or cantilever type. The type, erection and use of all scaffolding shall comply with all applicable OSHA provisions. Equip rungs of all metal


ladders, etc. with an abrasive non-slip surface. Provide a nonskid surface on all scaffold surfaces subject to foot traffic.

H. First Aid Supplies: Comply with governing regulations and recognized recommendations within

the construction industry.

I. Fire Extinguishers: Provide Type "A" fire extinguishers for temporary offices and similar spaces where there is minimal danger of electrical or grease-oil-flammable liquid fires. In other locations provide type "ABC" dry chemical extinguishers, or a combination of several extinguishers of NFPA recommended types for the exposures in each case.

J. Wetting Materials: For wetting prior to disturbance of ACM use amended water: Provide water to which a surfactant has been added. Use a mixture of surfactant and water which results in wetting of the Asbestos-Containing Material and retardation of fiber release during disturbance of the material equal to or greater than that provided by the use of one ounce of a surfactant consisting of 50% polyoxyethylene ester and 50% polyoxyethylene ether mixed with five gallons of water.

K. Encapsulant: Provide suitable encapsulant material intended by manufacturer for the treatment of

asbestos and ACM. Provide SDS and manufacture information for products to be used. Ensure that all encapsulant to be applied is suitable for the substrate and condition thereof and is compatible with replacement materials to be installed by Contractor or Owner following the Work.

L. Disposal Bags: Provide 6 mil thick leak-tight polyethylene bags labeled as required by applicable

sections of this Specification and federal and state regulations.

M. Fiberboard Drums of Equivalent: Provide sufficient quantity of fiberboard drums or equivalent (as determined by IH Consultant) for packaging of wire mesh and other contaminated materials with sharp or rough edges.

N. Disposal Bag/Container Labels and Signs: Provide leak-tight waste bags or containers for disposal

of asbestos-containing materials with labels in accordance with OSHA, EPA, and the latest revisions to the US Department of Transportation requirements, not limited to material identification number (#NA2212), material packaging group (PGIII), and labels. Warning labels will also include:

Legend: DANGER

CONTAINS ASBESTOS FIBERS AVOID CREATING DUST

CANCER AND LUNG DISEASE HAZARD

1. In accordance with NESHAPS, label each waste bag with the name of the waste generator and address where the material was generated. Include the Contractor name and address on each label also. Attach label in a sufficient manner such that they are properly sealed to or on the containers.

2. Label all waste bags, containers, and transport vehicles as required by applicable U.S.

Department of Transportation Rules and Regulations.

O. Coveralls: Provide disposable full-body coveralls and head cover in accordance with State and federal regulations. Provide a sufficient number for all required changes, for all workers in the Work Area. Provide sufficient number for use by IH Consultant.


P. Other PPE: Provide other personal protective equipment as required by OSHA regulations and industry standards, not limited to: hard hats, eye protectives, gloves, and footwear.

Q. Respiratory Protection: Provide respiratory protection in strict accordance with ANSI Z88.2 - 1992

"Practices for Respiratory Protection" and 29 CFR 1926 and 1910.134. The respirators will be sanitized and maintained in accordance with manufacturer's specifications and recommendations. Provide sufficient respiratory protection based on applicable ANSI and NIOSH standards. Select proper level of protection based on personnel exposure monitoring and the applicable OSHA Permissible Exposure Limits. Use only respirators and filter that are NIOSH-approved for use with asbestos and other atmospheres anticipated during the work.

R. Solvents: Provide appropriate solvent materials to aid in the removal of flooring materials and

mastics. Such solvent materials should be "low-odor" rated and all SDS's shall be submitted to the Owner for review prior to storing or using such materials at the job site. Contractor is solely responsible for all environmental and worker protection precautions required for the safe use, clean-up, and disposal of such materials. Additional air testing (area and personal exposure monitoring) must be completed by the Contractor (at no additional cost to the Owner) depending on the solvents to be used and as necessary to ensure a safe environment for site workers and adjacent public. Coordinate with Owner as necessary to assure compatibility with replacement materials prior to installation of solvents and coordinate special cleaning efforts with Owner for replacement issues in accordance with manufacturer’s guidelines and flooring industry standards. Contractor shall sufficiently wash and clean all floor areas where solvent is used. Conduct necessary wash, dry, and air change sequences to eliminate residual solvent odors and residual. Note: Charcoal pre-filters will be required on all HEPA exhaust/filter equipment during use of solvents.

S. Construction Materials: Provide other construction materials such as plywood, strapping, studs,

other related abatement materials, etc., as required to complete the work in accordance with this Specification.

T. All necessary testing and monitoring equipment as applicable to complete work, including but not limited to gas detection equipment, manometers, exposure sampling equipment.

2.2 WATER SERVICE

A. Provide water service as necessary to complete Work in accordance with applicable local, state, and federal building codes and regulations.

2.3 ELECTRICAL SERVICE

A. Provide electric service as necessary to complete Work in accordance with applicable local, state, and federal building codes and regulations.

2.4 PRESSURE DIFFERENTIAL AND FILTRATION

A. General: Supply the required number of HEPA filtered negative air fan units to the site in accordance with this Specification, industry standards, and applicable State and federal requirements. Use fan units that are intended for asbestos abatement as stated by the manufacturer. Provide HEPA filters that are individually tested and certified by the manufacturer to have an efficiency of not less than 99.97 percent when challenged with 0.3 um dioctylphthalate (DOP) particles or equivalent when tested in accordance with Military Standard Number 282 and Army Instruction Manual


136-300-175A. Provide filters that bear a UL586 label to indicate ability to perform under specified conditions.

B. Pre-filters: which protect the final filter by removing the larger particles, are required to prolong the

operating life of the HEPA filter. Two stages of pre-filtration are required.

C. Provide appropriate charcoal pre-filters during all work involving use of solvents to minimize odors. Allow HEPA units to run for a sufficient period of time after use of solvents to allow for adequate number of air changes and filtration to adequately dilute odors.

D. Safety and Warning Devices: Provide units with the appropriate safety and warning devices

including but not limited to missing or failure of HEPA filter, automatic shut down in the event of filter rupture or blockage, operating status indicator lights, and audible alarms.

2.5 AUXILIARY GENERATOR

A. Provide adequate, suitable alternative power with a capacity adequate to power a minimum of 50% of the HEPA filtered fan units in operation at any time during the work as needed for emergency use and backup.

PART 3 – EXECUTION 3.1 TEMPORARY ENCLOSURES

A. Control Access: Isolate the Work Area to prevent entry by building occupants and the public into Work Area. Notify the Owner of all doors and other openings that must be secured to isolate Work Area. Maintain safety access to stairwells and building exits. Construct work area containments and isolation barriers as required allowing for Owner operations and as approved by Owner.

1. Secured Access: Arrange Work Area so that the only access into Work Area is through

securable doors to personnel and equipment decontamination units.

2. Solid Construction Barriers: Provide solid construction barriers as indicated by Owner to prohibit unauthorized access and visibility by adjacent occupants and public. At a minimum provide solid barriers as necessary to isolate all work areas with abatement activity from portions of the building to maintain normal Owner operations.

3. Provide Warning Signs at each door and barrier leading to Work Area reading as follows:

Legend: DANGER

KEEP OUT BEYOND THIS POINT

CONSTRUCTION WORK IN PROGRESS

4. Immediately inside door (leading to Work Area) and outside all accessible critical barriers post

a manufactured asbestos danger sign, approximately 20 inch by 14 inch, displaying the following legend with letter sizes and styles of a visibility required by 29 CFR 1926:


LEGEND: DANGER ASBESTOS

CANCER AND LUNG DISEASE HAZARD AUTHORIZED PERSONNEL ONLY

RESPIRATORS AND PROTECTIVE CLOTHING ARE REQUIRED IN THIS AREA

B. Critical Barriers: Completely separate the Work Area from other portions of the building and the

outside by closing and sealing all openings with sheet plastic barriers at least 6 mil in thickness, or by sealing cracks leading out of Work Area with duct tape or equivalent methods. Seal the perimeter of all sheet plastic barriers with duct tape, spray adhesive or other mechanical supports as necessary. Individually seal all ventilation openings (supply and exhaust), lighting fixtures, clocks, doorways, windows, convectors and speakers, roof exhausts, and other openings into the Work Area with duct tape alone or with polyethylene sheeting at least 6 mil in thickness, taped securely in place with duct tape. Maintain seal until all work including Project Decontamination is completed. Take care in sealing of lighting and other fixtures, as applicable, to avoid melting or burning of sheeting, as applicable. Coordinate with Owner to provide adequate ventilation to space and equipment that requires air ventilation.

C. Pressure and Circulation in the Work Area and Decontamination Units

1. Isolate the Work Area from all adjacent areas or systems of the building with a Pressure

Differential that will cause a movement of air from outside to inside at any breach in the physical isolation of the Work Area.

2. Relative Pressure in Work Area: Continuously maintain the work area at an air pressure that is

lower than that in any surrounding space in the building, or at any location in the immediate proximity outside of the building envelope. This pressure differential when measured across any physical or critical barrier must equal or exceed a static pressure of: 0.02 inches of water. Accomplish the pressure differential by exhausting a sufficient number of HEPA negative air filtered fan units from the work area. Provide sufficient ventilation for a minimum of 8 air changes per hour and sufficient air movement throughout entire containment area.

3. Vent HEPA negative air ventilation units to outside of building. Ensure adequate security and

weather tight seals at each exhaust point.

4. Provide a differential pressure meter or manometer to demonstrate the required pressure differential at every barrier separating the Work Area from the balance of the building or outside. Provide continuous manometer measurements and printouts for all work performed adjacent to public occupied spaces if such spaces are occupied during the work.

5. Start fan units before beginning work involving disturbance of ACM or debris and run units

continuously to maintain a constant pressure differential and air circulation until decontamination of the work area is complete and the air clearance criteria has been met.

6. At completion of abatement work, allow fan units to run as specified under Project

Decontamination requirements, to remove airborne fibers that may have been generated during abatement work and cleanup and to purge the Work Area with clean makeup air.


D. Pre-Clean and Other Preparation Work Area:

1. Complete the following after installation of (1) critical barriers, (2) pressure differential/air filtration systems, and (3) decontamination facilities as indicated below and in other Specification Sections.

a) Pre-clean all work area surfaces, fixtures, and equipment using HEPA vacuums and wet

wiping. b) Seal non-removable fixtures and equipment with polyethylene sheeting. Provide a

minimum of 12" of overlap, sealed with spray adhesive and duct tape on both flap ends, on all joints in the barriers. Do not damage materials and items to be covered.

2. Provide and install transparent inspection windows in the containment barriers as indicated by

the IH Consultant. Maintain inspection window clean of debris to allow for inspection of work in progress.

3. Complete other preparation work as necessary to allow for complete precleaning and allow for

installation of containment barriers.

E. Primary Barrier:

1. Do not install primary barriers until all work area surfaces have been pre-cleaned using wet cleaning and HEPA vacuuming.

2. Protect building and other surfaces in the Work Area from damage from water and high humidity

or from contamination from asbestos-containing debris, slurry or high airborne fiber levels by covering with a primary barrier as described below. Coordinate with Owner to prevent adequate ventilation to space and equipment that requires air ventilation.

3. Primary Barrier Sheet Plastic: Protect floor surfaces with a minimum of 2 layers of 6-mil plastic

sheeting on floors. Provide additional floor protection as required to prevent damage to carpets and other existing flooring surfaces to remain after construction. Protect all existing wall, ceiling, fixed equipment, and other building surfaces with a minimum of 1 layer of 6-mil plastic sheeting in addition to critical barrier systems.

a) For work areas with abatement limited to nonfriable flooring only, provide a minimum of

48” (extending up from the floor) polyethylene sheeting barrier as a splash-guard.

b) In all cases provide additional barriers and covering as needed to protect building surfaces from damage during the work.

4. Provide a minimum of 12" of overlap, sealed (poly-to-poly) with spray adhesive and duct tape

on both flap ends, on all joints in the barriers. Extend floor sheeting up adjoining walls a minimum of 18 inches. Do not place seams at, or within 18" of any wall, ceiling, or floor joints. Stagger all joints by at least 18 inches. Wall and vertical surface poly shall extend over floor sheeting such that floor sheeting extends up the wall and is covered by the wall sheeting overlap.

5. Protect all existing building surfaces and fixed equipment/items, also including non-ACM

insulations in the work areas, with a minimum of 2 layers of 6-mil plastic sheet as required to maintain existing conditions and to prevent contamination, water damage, or other damages due


to the work. Provide a minimum of 12" of overlap, sealed with spray adhesive and duct tape on both flap ends, on all joints in the barriers.

F. Seal all ducts and equipment with primary barriers. Isolate and shut down air systems in work area

during abatement. Isolate all exterior intakes sufficiently from HEPA exhaust points. Ventilation units and ductwork shall be fully sealed with polyethylene sheeting.

G. Stop Work: If the Critical or Primary Barrier fails or is breached in any manner stop work

immediately and repair the breach as required. Do not start work until authorized by the IH Consultant. Any contamination and/or suspect contamination, as determined by Owner and the IH Consultant, resulting from a breach in the barriers or other neglect by the Contractor shall be thoroughly abated in accordance with this Specification at no additional cost to Owner.

H. Decontamination Units

1. Provide personnel and equipment decontamination facilities in accordance with State and OSHA regulations and require that the personnel decontamination unit be the only means of ingress and egress for the Work Area (for personnel, waste, equipment and other related items). Provide portable shower units, with continuous dedicated water source, sufficient for personnel decontamination in accordance with State and OSHA regulations, and cascaded filter units on drain lines from showers or any other water source carrying asbestos-contaminated water from the Work Area. Provide units with disposable filter elements as indicated below. Connect so that discharged water passes primary filter and output of primary filter passes through secondary filter and final filter.

a) Primary Filter - Passes particles 20 microns and smaller b) Secondary Filter - Passes particles 10 microns and smaller c) Final Filter - Passes particles 5 micron and smaller

2. Do not discharge filtered water unless testing and permitting has been completed as applicable

in accordance with State and local requirements.

3. Clean debris and residue from inside of Decontamination Units on an ongoing basis.

4. Post an asbestos warning sign at the entrance of the decontamination unit.

5. Adequately secure door to entrance of decontamination unit at the completion or each shift.

I. Containment Locations

1. Construct and install containment barriers around each work area as coordinated and indicated by Owner and IH Consultant. Do not allow containment location and installation to inhibit access and adequate airflow to all other areas of the building and mechanical equipment. Coordinate with Owner the isolation of mechanical equipment in the work area.

3.2 REMOVAL OF ASBESTOS-CONTAINING MATERIALS

A. Inspections: Prior to commencing with ACM removal or other ACM disturbance, each individual work area must pass an inspection by the IH Consultant. If deficiencies are observed, immediate correct in a manner satisfactory to IH Consultant.


B. Maintain all work area isolation and controls during work of this section. The Contractor shall conduct ongoing inspections of the work area, adjacent areas and surrounding areas beneath, as applicable, for containment breaches, leaks or other containment failures. In the event breeches or potential breeches are identified, immediately repair the containment barriers as needed and complete all clean up and decontamination work.

C. Secondary Barrier: Over any floors and surfaces beneath ACM to be removed in the work areas,

install as a drop cloth a clear 6-mil sheet plastic in all areas where asbestos removal work is to be carried out. Completely cover floor with sheet plastic. Install Secondary Barrier at the beginning of each work shift. Install only sufficient plastic for work of that shift. Remove Secondary Barrier at end of each work shift or as work in an area is completed. Carefully pack in disposal bags

D. Wet Removal and Waste Packaging - General:

1. Thoroughly wet ACM to be removed or otherwise disturbed prior to disturbance, stripping

and/or tooling to reduce fiber dispersal into the air. Maintain materials as adequately wetted during Work and as required by NESHAPS. Accomplish wetting by a fine spray (mist) of amended water. Saturate material sufficiently to wet to the substrate without causing excess dripping. Allow time for amended water to penetrate material and seams thoroughly. Spray material repeatedly during the work process to maintain a continuously wet condition.

2. Where necessary, carefully remove ACM while simultaneously spraying amended water to

minimize dispersal of asbestos fibers into the air. Mist work area continuously with amended water whenever necessary to reduce airborne fiber levels. Do not allow ACM to dry out. As it is removed, simultaneously pack material into appropriate asbestos waste disposal bags/containers. For waste bags, twist neck of waste bags, bend over and seal with minimum three wraps of duct tape. Clean outside of packaging and move packaged waste to the equipment decontamination unit for further cleaning and waste re-packaging. Once in equipment decontamination unit and cleaned, repackage waste in 2nd waste bag and seal as indicated above.

3. Continuously clean excess water using wet wiping and HEPA vacuuming such that excess water

build up on the floor and other containment surfaces does not occur and so that water does not leak or migrate outside of the work area.

4. Use work procedures that result in 8-hour TWA and STEL airborne fiber counts less than the

required limits established by OSHA and as described herein. If airborne fiber counts exceed this level immediately mist the area with amended water to lower fiber counts and revise work practices and engineering controls to maintain level within the required limits.

E. Contractor may encounter and shall investigate all areas of the building to identify, concealed ACM

insulation and miscellaneous ACM. Provide full access and selective controlled demolition, as necessary, to identify and fully remove all ACM. Remove as ACM all co-mingled debris or building materials where ACM is embedded or has come in contact with such material and decontamination is not feasible.

F. Other Safety: As applicable, comply with all appropriate safety procedures during Work in accordance with industry standards and all applicable OSHA regulations including but not limited to: confined space work safety procedures in accordance with 29CFR Part 1910.146; proper personal protective equipment; worker safety training and written programs per current OSHA requirements; fall protection; lockout tag out; and take precautions to avoid burns and heat stress when working in areas of hot equipment and excessive heat as applicable.


G. Glovebag Removal of Pipe and Pipe Fitting Insulation

1. Glovebags shall be used to remove pipe and pipe fitting insulation. Conduct glovebag removal

within negative pressure enclosures or full containment barriers as indicated in Section 3.2. Glovebags will be used in strict accordance with 29 CFR 1926.1101 (OSHA) and other applicable regulations. Conduct work in negative pressure enclosure or full containment barriers. Install polyethylene sheeting drop cloths beneath pipe areas to be worked and along all foot traffic areas in the work area. After the negative pressure enclosure in constructed, install glovebags in accordance with manufacturer's instructions and regulatory requirements.

2. Once completely sealed around the pipe to be worked, inspect glovebag for adequate seals and

using proper smoke testing. Allow amended water to saturate material to substrate and ensure ACM remains adequately wetted. Cut bands holding preformed insulation, slit jackets at seams, remove, and hand-place in a disposal bag or bottom of glovebag as applicable. Provide dedicated water supply to each glovebag during the entire removal and cleaning operation within the glovebag. Remove job-molded fitting insulation in chunks and hand place to the bottom of the glovebag. Spray amended water continuously such that ACM is adequately wetted. Do not drop any material or allow material or water to fall out of the glovebag or to fall to the floor. Remove any residue on pipe or fitting with stiff-bristle-nylon hand brush. Once all cleaning is complete, twist the glovebag with the debris at the bottom of the glovebag and seal with duct tape. Remove the glovebag, bend the top over, and then reseal the neck with duct tape.

H. Gypsum Board with Joint Compound

1. Gypsum board with joint compound containing trace chrysotile asbestos will be removed prior

to demolition or renovation activities and disposed of as asbestos waste. Conduct work within full containment barriers. Drop cloths will be placed below each work area. Drop cloths and any debris generated will be disposed of as asbestos waste following each shift and at the completion of work. Allow amended water to saturate material to substrate and ensure ACM remains adequately wetted. Use care to maintain ACM intact and do not render the material friable. Remove gypsum panels and ACM in sections with care to minimize breaking and cutting to the extent needed to remove and package manageable sections of the ACM. As the material is removed, immediately package it as asbestos waste. Remove all residual gypsum as asbestos waste. Remove and dispose fiberglass batting or other fibrous insulation in contact with the ACM, and insulation materials that are dislodged and exposed to the work area during removal, as asbestos waste.

2. Provide temporary support if needed and as applicable in order to remove the ACM and other

ceiling material. Provide temporary mechanical supports to all fixtures, heat and smoke detectors, vents and other items attached to or above the gypsum board and ACM joint compound to be removed. Owner must approve all temporary support systems.

I. Vinyl Sheet Flooring and Adhesive, Floor Tile and Mastics:

1. Ensure ACM, carpet and associated materials remains adequately wetted. Remove carpet

covering ACM, as applicable, within negative pressure enclosure as indicated in Section 3.2. Carpet that has been in contact with ACM may be disposed of as general construction waste as long as no ACM or suspect debris is attached to carpet. Carpet that has ACM or suspect debris adhered to it shall be packaged and disposed of as asbestos waste. Remove cove base material in areas of flooring abatement and carpet removal (cove base mastic to remain). The ACM will


be removed by hand scrapers and will not be allowed to dry out during removal and packaging. Do not render the materials friable and use care not to break ACM into small fragments during removal. Friable removal requires full containment barriers on all wall, floor, and ceiling surfaces. Mechanical or bead blasting methods are prohibited unless specifically approved in writing by Owner and Owner’s IH Consultant. As removed, the ACM will be simultaneously packed while still wet into corrugated boxes or burlap bags and then sealed shut. The boxes/bags will then be sealed and placed into proper disposal bags. The necks of the disposal bags will be twisted, bent over and sealed with minimum three wraps of duct tape. Caution will be used to protect the bags and wrapping from tears and rips due to sharp edges.

2. Coordinate with Owner as necessary to assure compatibility with replacement materials prior to

installation of solvents and coordinate special cleaning efforts with Owner for replacement issues in accordance with manufacturer’s guidelines and flooring industry standards. Mastic on concrete shall be removed using a suitable solvent and manual scraping/brushing, wet wiping, and HEPA vacuums. Do not use solvents on any wood or other porous substrates. Do not allow solvent to leak out of the work area or seep into floor or wall cracks, and take precautions to prevent solvent from entering cracks and/or crevices in the concrete and wall/floor joints. All waste will be packaged into appropriate waste containers. Residue on the floor will be removed with stiff-bristle-nylon hand brush. This work will be repeated until all visible debris has been removed from substrate. In areas with solvent use, as requested by the Owner, leave adequate air filtration and pressure differential systems in continuous operation for at least 24 hours after the air clearance criteria has been met to allow for ventilation of odors.

3. For wood substrate with ACM mastic, remove wood substrate layer that has mastic applied to

it. Fully remove the substrate layer in contact with mastic, mastic and associated debris using wet methods, brushes, and HEPA vacuums. Do not use solvents on wood substrate. Do not leave any sharp protrusions, not limited to nails and screws in the floor. Provide temporary floor work surface as needed to ensure safety.

4. As applicable and possible, provide adequate inspection of the building spaces below areas of floor removal to detect, prevent and correct damage from liquids that escape the work area. Adequately wash all floor substrates and other building surfaces following abatement and clearance testing using an appropriate cleaner and water as needed to clean residual film and minimize residual odor. Do not damage remaining finishes and substrates and do not use excessive water. Package waste as asbestos waste.

J. Door, Window and Building Caulking Material and Door Glaze Material:

1. Conduct work within exterior, demarcated, OSHA regulated Work area. Drop cloths of 6-mil

polyethylene sheeting will be placed on ground below each work area and extending out sufficiently to protect the ground from possible debris. The drop cloths and any debris generated will be disposed of as asbestos waste at the end of each work shift and following the work. Install critical barriers over windows, doors and other openings in the building within 15 feet of the material to be removed. Wet ACM caulking using amended water and ensure ACM remains adequately wetted throughout entire removal process. Use hand tools (scrapers) to remove caulking from substrate with HEPA vacuums and wet wiping to remove any residue. For caulking on window or door casings, remove entire window casing units intact without damaging caulk, package, and dispose of entire unit as ACM waste. Use care to prevent the material from becoming friable. Clean all caulk material that may be encountered during window or door removal from the building substrate. Coordinate with the Owner for safety and building security for any areas that have entire window and/or door units removed.


2. The asbestos contractor will conduct necessary inspections to ensure safe working conditions

and install necessary supports, engineering controls and fall protection to allow for the safe removal of the ACM. Employee and/or general contractor operations in the surrounding areas will also be restricted as deemed necessary by the site supervisor/OSHA competent person.

3. The IH Consultant may be providing representative perimeter area air monitoring during

exterior ACM removal work. The acceptable perimeter air monitoring result is 0.010 f/cc.

K. Roofing Materials

1. Coordinate with Owner and other contractors at the site as applicable for phasing and work area delineation. Conduct work within exterior OSHA regulated Work area. The Contractor shall install barrier tape and otherwise properly demarcated the work site areas to prevent unauthorized access in accordance with 29 CFR 1926.1101. Employee and/or general contracting operations in the surrounding areas will also be restricted as deemed necessary by the OSHA competent persons on site. The Contractor will conduct necessary inspections to ensure safe working conditions and install necessary supports, engineering controls and fall protection to allow for the safe removal of the ACM.

2. Install drop cloths of 6-mil polyethylene sheeting on ground and lower levels below each work area, as applicable, and extend drop cloths out sufficiently to protect the ground from possible debris. The drop cloths and any debris generated will be disposed of as asbestos waste at the end of each work shift and following the work. Install critical barriers, consisting of 6-mil polyethylene sheeting, over all windows, doors, roof top ducts, vents or other openings in the work area. All ACM roof (asphalt products, flashings, caulk, and sealants) work will be completed in accordance with current State requirements in addition to this specification and federal requirements. The ACM to be removed will be adequately wetted by the asbestos contractor during all phases of work as required to minimize dust and visible emissions in accordance with State and federal regulations. Ensure ACM remains adequately wetted throughout the entire removal process. The ACM will be removed using hand tools, wetting, and, as deemed necessary by the asbestos contract, HEPA-equipped saws. Verify areas beneath roof decking are adequately sealed off to prevent debris from dislodging from roof work into attic or other building space.

3. The ACM and associated debris generated during the work shall be either placed into proper asbestos waste bags or sealed and labeled in two layers of 6-mil polyethylene sheeting. Care will be used to cover rough edges and prevent tearing of waste packaging. Properly packaged waste will be transported by hand, lowered to the ground, and placed within the waste dumpster to be provided by the Contractor adjacent to the work area. In the event the waste chutes are used for roofing materials, the chute system will be air-tight and chute directly to an ACM waste dumpster which is lined with a minimum of 2 layers of 10-mil polyethylene sheeting, labeled, and seal with duct tape and spray adhesives, as needed.

4. The IH Consultant may be providing representative perimeter area air monitoring during

exterior ACM removal work. The acceptable perimeter air monitoring result is 0.010 f/cc.

L. Ceiling Tile

1. Removal of ACM ceiling tiles will be conducted within a negative pressure, full containment work area. Once containment barriers are installed and negative pressure is established, the


ACM ceiling tiles around the perimeter of the work area will be carefully removed to allow inspection of the space above the ceiling for any openings extending into non-work areas. Wet-wipe and HEPA vacuum any debris and surfaces extending into non work areas and then install critical and primary barriers as required. All fixtures shall be pre-cleaned and sealed with primary barriers prior to removal work. Install temporary support hangers as needed in areas of tile removal using methods approved by Owner. Commence with gross removal only after this work has been conducted.

2. Adequately wet ceiling tiles and surrounding areas with amended water, and allow the ACBM

to absorb water such that the ACBM is adequately wet. Using a two-person team, remove tiles from grid with care to minimize breaking and immediately hand place directly into proper waste bags. Do not allow tile waste to build up on floor. Do not drop tiles to the floor. HEPA vacuum and wet wipe all surfaces above ceilings. All fiberglass insulation in contact with the ACBM ceiling tile or with debris present shall be handled and disposed of as ACBM waste. Grid systems shall be HEPA vacuumed and wet wiped clean for reuse by Owner, as specified by Owner and in accordance with Contract documents. For areas that grids are to be salvaged for re-use, use care not to damage the grid systems during the work. Once gross removal is completed, the exposed walls and grid system will be wetted and brushed as necessary to remove all visible debris and then wet wiped to remove any residue. The grid system and exposed walls above the grid system will then be cleaned and encapsulated.

M. Transite Panel Removal

1. Conduct work within regulated area. Drop cloths of 6-mil polyethylene sheeting will be placed

on floors below each work area, and the drop cloths and any debris generated will be disposed of as asbestos waste following the work. The transite panels will be removed in whole sections as much as feasible. The panels will be adequately wetted during the entire process. The panels will be removed by removal of the trim, screws, and nails that secure the panels using wet-wiping, HEPA vacuums, and continuous misting. Immediately wet-wipe and HEPA vacuum any debris or dust. Do not break panels. All substrate and trim will also be cleaned using wet wiping and HEPA vacuums. As the panels are removed, wrap in three separate layers of 6-mil polyethylene sheeting, seal with duct tape and spray adhesives. Seal each layer separately. Properly label the outside of the sheeting as an asbestos waste container as indicated in this Work Plan and in accordance with State and federal regulations. Clean all substrate, floor surfaces, and other items in the immediate work area using wet-wiping and HEPA vacuums. Do not render panels friable.

N. Sink Basin Undercoating

1. Conduct work within demarcated, OSHA regulated work area. Drop cloths of 6-mil

polyethylene sheeting will be placed on the floor surrounding the sink. The sink basin containing ACM undercoat will be adequately wetted with amended water and removed as whole component by the removal of all plumbing, clips and other fasteners holding the wink in place on the counter. Any debris will be immediately removed using HEPA vacuums and wet wiping. The sink will be placed into an asbestos disposal bag or wrapped in two layers of poly sheeting, separately sealed, and labelled as asbestos waste. Clean all substrate, floor surfaces, and other items in the immediate work area using wet-wiping and HEPA vacuums. Do not render sink basin undercoat friable.


3.3 INITIAL CLEAN-UP WORK

A. Once gross removal is completed, clean all visible debris on the substrate and containment barriers using HEPA vacuums, scrub brushes, and wet-wiping. Do not allow materials to dry out. As material is removed and clean-up is completed, simultaneously pack wetted material into proper waste disposal bags or package as noted above. For waste bags, twist the neck of the bags, bend the neck over, and seal with a minimum of three wraps of duct tape. Clean the outside of the bags with wet wiping and HEPA vacuum and move to the wash down station in the Equipment Decontamination Unit. Once washed clean, place the clean disposal bags into a second asbestos disposal bag and seal the bag in the same manner as the first. Bags will then be transported from the work area to the asbestos waste dumpster. Note: Waste dumpster must remain labeled and locked at all times when loading is complete or idle.

B. Label waste dumpsters in accordance with 29 CFR 1910.145: Legend

DANGER

ASBESTOS DUST HAZARD CANCER & LUNG DISEASE HAZARD

AUTHORIZED PERSONNEL ONLY

C. Change all filters on the pressure differential systems and properly dispose of as asbestos waste. Maintain adequate filtration and pressure differential during all filter changes.

3.4 PROJECT DECONTAMINATION

A. Work of This Section includes the decontamination of air and surfaces in the Work Area which has been, or may have been, contaminated by the elevated airborne asbestos fiber levels generated during abatement activities, or which may previously have had elevated fiber levels due to ACM in the space.

1. First Cleaning

a) Carry out a first cleaning of all surfaces of the work area including items of remaining

sheeting, tools, scaffolding and/or staging by use of damp- or wet-cleaning and mopping, and HEPA vacuuming. Do not perform dry dusting or dry sweeping. Use each surface of a cleaning cloth one time only and then dispose of as contaminated waste. Continue this cleaning until there is no visible debris from the substrate and other work area surfaces.

b) At the completion of the above cleaning Contractor Supervisor shall visually inspect all

work area surfaces. Re-clean if any dust, debris, etc. is found. Inspect the area and if any debris or dust is found, repeat the cleaning. Continue this process until no debris dust or other material is found while sweeping of all surfaces with forced air equipment (important: forced air sweeping to be used only in full containment work areas).

c) Remove and replace all negative air unit pre-filters, dispose of used filters as asbestos waste.

2. Second and Third Cleaning

a) At the completion of the first cleaning and Contractor inspection, carry out a second

cleaning of all surfaces in the work area in the same manner as the first cleaning. For containments with multiple layers of polyethylene sheeting on floors, remove top layers of


sheeting on the floor leaving one layer of the primary barrier remaining. Clean newly exposed areas as outlined above and dispose of removed sheeting as asbestos waste.

b) Carry out a third cleaning of all surfaces in the same manner as the first cleaning. Change

filters on pressure differential systems and properly dispose of as asbestos waste. Allow for sufficient settling period prior to clearance testing. Complete additional cleaning as required and until no visible dust or debris is present.

B. Visual Inspection: After completion of above cleaning and Contractor’s own visual inspection, The

IH Consultant shall perform a visual inspection for debris from any sources, residue on surfaces, dust or other matter in the Work Area to confirm the Contractor’s inspection findings.

1. For full containment work areas, during visual inspection sweep entire work area including

walls, ceilings, ledges, floors, and other surfaces in the room with exhaust from forced air equipment (leaf blower with approximately 1 horsepower electric motor or equivalent).

2. IH Consultant Visual inspection is complete when the area is visually clean, and no debris, residue, dust or other material is found. If any debris, residue, dust or other matter is found repeat Contractor cleaning and the IH Consultant Visual Inspection.

3. Encapsulation of substrate: After successful final visual inspection, perform encapsulation of

substrate as approved by Owner using suitable encapsulant material. Coordinate with Owner to ensure compatibility with replacement materials and fire retardant ratings for the surfaces to be encapsulated. Do not allow overspray to damage other surfaces, materials and equipment in the work area and do not allow overspray and build up or pooling of encapsulant.

C. Clearance Testing: Air clearance sampling will be conducted by the IH Consultant. See Work Area

Clearance section. Air clearance testing will not be completed until the work area passes visual inspection, has had adequate air changes, and sufficient time for surfaces to adequately dry.

D. Removal of Work Area Isolation: Complete only after the work area clearance sections have been

met and verified by the IH Consultant. Remove all Primary Barrier sheeting and equipment decontamination unit(s), leaving only: critical barriers, personnel decontamination unit, and operational pressure differential/air filtration systems. Properly dispose of sheeting as asbestos-waste. Use care to prevent damage to building surfaces and materials during teardown. All damages to surfaces and materials shall be repaired by Contractor unless otherwise noted and agreed to in writing by Owner.

1. Re-inspect all work area surfaces and adjacent areas for any dust and debris that may have

originated from the work. Clean all surfaces using HEPA-vacuums and wet-wiping as required and until all surfaces are clean of visible debris. Shut down and remove the Pressure Differential System. Seal HEPA filtered fan units, HEPA vacuums and similar equipment with 6 mil polyethylene sheet and duct tape to form a tight seal at intake end before being moved from Work Area.

2. Remove personnel decontamination unit. Remove the critical barriers and properly dispose of

as asbestos-waste. Clean all surfaces using HEPA-vacuums and wet-wiping as required and until all surfaces are clean of visible debris.

E. Final Cleaning: This cleaning is now being applied to existing room conditions. Take care to avoid

watermarks or other damages. Wet-wipe and HEPA vacuum surfaces in the work area until clean


and free from dust and debris. Complete final cleaning in accordance with the project close-out requirements. Accompanied by Owner, Contractor Site Supervisor shall complete a final post-abatement inspection of all surfaces and re-clean and conduct repairs as necessary.

3.5 WORK AREA CLEARANCE

A. Contractor Release Criteria: The Work Area shall be considered cleared when the Work Area meets the final visual inspection criteria described in the project decontamination section and airborne fiber structure concentrations have been reduced to the level specified below and pursuant to applicable State and federal asbestos regulations. Contractor must provide at least 48 hours advance notice to the IH Consultant for any clearance testing or other inspections required.

B. Clearance Air Monitoring: Air clearance samples will be collected by the IH Consultant. In full

containment areas air clearance sampling will be conducted using aggressive sampling techniques in accordance with state and federal regulations.

C. Analytical Method: The number and volume of air samples taken and analytical methods used by

the IH Consultant based on conditions of work and the various State and federal requirements. Phase Contrast Microscopy (PCM) and Transmission Electron Microscopy (TEM) may be used for analysis of clearance samples collected to confirm completion of abatement of ACM in accordance with applicable State and federal regulations. Other analytical methods may also be used as determined by IH Consultant based on conditions of the work and other factors.

D. PCM Air Clearance Testing: Decontamination of Work Areas requiring PCM air clearance testing

only is complete when every Work Area clearance sample collected has total fiber concentrations below the 0.010 f/cc. If any sample does not meet the clearance criteria, the decontamination is incomplete, and Contractor shall repeat final cleaning. The Contractor shall be responsible for all costs for each subsequent and additional round of testing and analysis required until the clearance criteria is met.

3.6 DISPOSAL OF ASBESTOS-CONTAINING WASTE MATERIAL

A. General: Asbestos-containing waste materials and debris which is packaged in accordance with the provisions of this Specification may be disposed of at designated sanitary landfills when certain precautions are taken not limited to: notice to appropriate EPA Regional Offices and notice and permit from appropriate State and local agencies are completed. Waste disposal site(s) must be properly licensed, permitted, and qualified to accept and handle Asbestos waste in accordance with all applicable local, State, and federal codes and regulations.

B. Disposal: Comply with the following sections during all phases of this work: worker protection

requirements and respiratory protection requirements. All waste is to be hauled by a waste hauler with all required licenses and permits from all state and local authority with jurisdiction.

1. Carefully load all containerized asbestos-containing waste material on sealed and lined trucks

or other appropriate vehicles for transport. Exercise care before and during transport, to ensure that no unauthorized persons have access to the materials.

2. All ACM and asbestos materials removed are to be properly containerized in one of the

following: (1) Two 6 mil disposal bags, or (2) Two 6 mil disposal bags and a fiberboard drum, or (3) equivalent method as approved by Owner and State. Do not store disposal bagged material


outside of the work area. Take bags or drums from the work area directly to a sealed truck or dumpster. Glove bags shall not be used as waste disposal bags.

3. Owner will provide a designated location for placement of proper waste dumpster. Line waste

dumpster with a minimum of 2 layers of 6 mil polyethylene sheeting and such that a minimum total of 20 mils of lining exists (including waste bags). Waste dumpster(s) will not be allowed to remain at the job site for longer than 72 hours upon completion of each phase (work area) of work by the Contractor. Do not transport disposal bagged materials on open trucks. During loading and unloading, properly demarcate and label dumpster on all 4 sides. Dumpster shall be sealed, labeled and locked during all non-loading periods.

4. In accordance with NESHAPs and State regulations, advise the landfill operator or processor in

advance of transport, of the quantity of material to be delivered. At a disposal site, sealed plastic bags may be carefully unloaded from the truck. If bags are broken or damaged, leave in truck and clean entire truck and contents using procedures set forth herein. Retain receipts from landfill or processor for materials disposed of. At completion of hauling and disposal of each load submit copy of waste manifest, chain of custody form, and landfill receipt to Owner and IH Consultant.

5. Provide copy of waste shipment record (complete to date) to Owner and IH Consultant prior to

removing waste from the site. Provide final copy of completed waste shipment record to Owner and IH Consultant within 25 days of removing waste from the site.

3.7 RESTORATION AND REPLACEMENT

A. Conduct restoration and replacement work in accordance with the Contract Documents and provide certification that all materials used in the construction, restoration, renovation, and other work are asbestos-free. Repair all damaged surfaces, tape damage, adhesive, and other damages resulting from the work or other damages caused by the Contractor as indicated by Owner, to meet or exceed existing conditions, and as otherwise stated in the Contract Documents. Conduct additional house cleaning and floor cleanings as necessary.

3.8 ASBESTOS PROJECT CLOSEOUT

A. Contractor shall achieve Substantial Completion and then Final Completion as indicated below prior to requesting final payment.

B. General cleaning during and after construction is required as needed to maintain general housekeeping and as otherwise required herein. Complete all final, general house-keeping and cleaning in the work areas in accordance with 29 CFR Part 1910 and 29 CFR Part 1926, as applicable. Remove temporary protection and facilities installed for protection or security of the work during construction. Comply with regulations of authorities having jurisdiction and safety standards for cleaning. Do not burn waste materials. Do not bury debris or excess materials on the Owner's property. Do not discharge volatile, harmful or dangerous materials into drainage systems. Remove waste materials from the site and dispose of in a lawful manner. Where extra materials of value remaining after completion of associated Work have become the Owner's property, arrange for disposition of these materials as directed.

C. Conduct all other related work, non-asbestos work, and general construction activity in accordance with the Contract Documents and Owner’s written request.


D. Substantial Completion consists of the following: (1) all work area abatement, decontamination and related site work is complete; (2) interim submittal requirements are submitted; (3) final visual inspection and air clearance requirements have been met in each work area; (4) removal of containment barriers and Contractor equipment is complete; (5) all general cleaning has been performed as indicated herein; (6) other work tasks and administrative requirements have been completed in accordance with the contract documents and specification; and (7) post-abatement site inspection and review with Owner has been performed.

E. Final Completion consists of the following: (1) Substantial Completion met; (2) completion of all

Closeout Submittal requirements; and (3) complete, to Owner’s satisfaction, any remaining punch-list items identified during the post-abatement site inspection with Owner.

END

SUMMARY OF ACBM & ASBESTOS TO BE REMOVED


Swanton, Vermont

Building Material



1 Canada Street

Interior Window Caulking

South store front windows 6 windows @36 linear feet/unit


Trace Tremolite

Gypsum Board with Joint Compound

Interior walls 6,500 square feet


Trace Chrysotile

Door Caulk Exterior side door 25 linear feet Category II Nonfriable

2% Chrysotile

Window Caulk Exterior store front windows 6 windows @36 linear feet/unit


3% Chrysotile

Black Flashing Roof, patches throughout slate roofing


5% Chrysotile

3 Canada Street

9” Floor Tile Entrance to stairwell to basement (however, additional materials are likely below newer floor coverings)

50 sq. ft. Category I Nonfriable

5% Chrysotile

2x4 Ceiling Tiles Throughout suite 2,500 square feet

Friable 5% Amosite

Gypsum Board with Joint Compound

Throughout suite 1,800 square feet


Trace Chrysotile

Transite Panels Basement, boiler room above boiler


20% Chrysotile

Pipe Fitting Insulation Debris

Basement boiler room 15 fittings, less than 6 square feet

Friable RACM 40% Chrysotile

Black/Silver Flashing Roof, east slope, along lower edge of roof at ice shield, 3 ft high and the length of roof

180 square feet

Category I Nonfriable

6% Chrysotile

Black Flashing Roof, patches throughout slate roofing


5% Chrysotile

Grey Caulk Northeast corner at roofline, repairs to brick walls

6 linear feet Category I Nonfriable

4% Chrysotile


Roof over alley between 1 and 3 Canada Street and extending along front overhang of entire structure, under white synthetic roofing

1,500 square feet


3% Chrysotile

Transite Debris Roof over alley between 1 and 3 Canada Street


18% Chrysotile

SUMMARY OF ACBM & ASBESTOS TO BE REMOVED


Swanton, Vermont

Building Material



5 Canada Street

Flooring Adhesive Assumed to be throughout space under laminate flooring

1,050 square feet


5% Chrysotile


Roof over 5 Canada under white synthetic roofing

1,200 square feet


8% Chrysotile

2nd floor: Canada Street Apartment 1

Door Glaze Apartment vestibule entrance door


3% Chrysotile

Building Seam Caulk Exterior seam joint on vestibule stairwell


2% Chrysotile

2nd floor: Canada Street Apartment 2

Sink basin undercoat Kitchen 1 sink unit Category II Nonfriable

6% Chrysotile

BMTM Services

Floor Tile and Mastic Bathroom off warehouse 50 square feet Category II Nonfriable

4%-5% Chrysotile

Teen Center

Airocell Pipe Insulation

Basement main room in wall <1 linear feet Friable RACM 40% Chrysotile

Pipe Wrap Basement ladies room and sprinkler room

16 linear feet Friable RACM 20% Chrysotile

Pipe Insulation Basement sprinkler room 10 linear feet Friable RACM 15% Amosite

Transite Panel Entrance stairwell ceilings and stairs on east and west side of entrance

225 square feet


30% Chrysotile


Yellow Vinyl Sheet Flooring and Adhesive

Bathroom and Utility Closet underneath non-ACBM brown vinyl sheet flooring


15% Chrysotile

Notes: • Please refer to the original survey reports prepared by RPF Environmental dated January 4, 2017 and March 23, 2018

which identifies the types, locations and quantities of ACBM present at this site. • It is possible that some concealed or inaccessible ACBM is present. Care should be used when renovating/demolishing

inaccessible building space. Further explorative survey work may be necessary during design and/or in conjunction with demolition

APPENDIXE.2

LEAD‐BASEDPAINTABATEMENTSPECIFICATIONS

© RPF Environmental Inc. April 10, 2018 Lead Paint Related Work Page 1 of 7

LEAD PAINT RELATED WORK

Swanton Municipal Lot – Corrective Action Plan

1-3-5 Canada Street & Merchants Row

Swanton, Vermont

Contents

PART 1 GENERAL 1

1.1 RELATED DOCUMENTS 1 1.2 PROJECT SCOPE-OF-WORK 1 1.3 REFERENCES 2 1.4 SUBMITTALS 3 1.5 POTENTIAL LEAD HAZARD 3

PART 2 PRODUCTS 4

2.1 PROTECTIVE EQUIPMENT 4

PART 3 EXECUTION 4

3.1 HAZARDOUS MATERIALS/WASTE 4 3.2 LEAD PAINT 5

GENERAL

RELATED DOCUMENTS

A. General provisions of the Contract, including General and Supplementary Conditions and Other

Abatement Specification Sections, apply to the work of each of the Specification Sections.

B. This section addresses abatement of asbestos-containing material (ACM) only.

C. Related Work: The following items are closely related to this work but not included in this Section and will be performed under the designated Sections.

1. Asbestos Section 2. Universal Waste Specification

PROJECT SCOPE-OF-WORK

A. General: Furnish all labor, materials and equipment to complete the work specified of this

Section including, removal and lawful transport and disposal of building materials coated with lead containing paint (LP) encountered during the demolition of structures at the above referenced site.

B. All lead removal work is to be completed in accordance with the requirements set forth herein. The scope-of-work includes the removal, transport, and disposal of designated lead-containing paint (LP) contaminated materials at the Swanton Municipal Lot located at 1-3-5 Canada Street & Merchants Row in Swanton, Vermont. All work is to be completed in accordance


with the schedules stated herein, in the Contract Documents, and as designated by the Maquam Holdings-Canada Street, LLC (Owner). It is essential that all work be phased and scheduled as required to facilitate Owner’s renovation and upgrade work. All work is to be completed in strict accordance with applicable local, State of Vermont (State), and federal codes and regulations and the requirements stated in this specification and Contract Documents.

C. Reference full inspection reports for discussions and additional information and limitations of

Owner survey.

D. The work areas have or may have other regulated or hazardous materials present that are not covered in the Section including but not limited to polychlorinated biphenyl (PCB)-containing materials, mercury, asbestos, guano, mold contamination, other hazardous materials and universal waste. Contractor’s OSHA-competent person shall also inspect the work place for other potential hazardous building material during the work. If encountered during the work immediately notify Owner’s Representative. Use only qualified, trained workers to properly remove, package, transport, and dispose (or recycle) of such material in strict compliance with all local, State, and Federal requirements.

REFERENCES

A. The Contractor is advised to thoroughly review the documents referenced in this Section.

Strict adherence to the hazardous materials, noise, air and water pollution regulations and requirements is required.

1. Code of Federal Regulations

29 CFR 1910, “Occupational Safety and Health Standards” (General Industry Standards) 29 CFR 1910.20, “Access to Employee Exposure and Medical Records” 29 CFR 1910.134, “Respiratory Protection” 29 CFR 1910.146, “Permit Required Confined Space” 29 CFR 1910.1200, “Hazard Communication” 29 CFR 1926, "Safety and Health Regulations for Construction" (Construction Industry Standards) 29 CFR 1926.62 "Lead-Construction" 40 CFR 117, "Determination of Reportable Quantities for Hazardous Substances" 40 CFR 122, "EPA Administered Permit Program: The National Pollutant Discharge Elimination System" 40 CFR 172, "Hazardous Waste Transportation" 40 CFR 261, "Identification and Listing of Hazardous Waste" 40 CFR 262, "Standards Applicable to Generators of Hazardous Waste" 40 CFR 263, "Standards Applicable to Transporters of Hazardous Waste" 40 CFR 268, "Land Disposal Restrictions" 40 CFR Part 745, EPA Lead Renovation, Repair and Painting (RRP) Rule

2. Occupational Safety and Health Administration OSHA Booklet 3126 "Working with Lead in the Construction Industry".

3. National Institute for Occupational Health and Safety

NIOSH Method 7082, "Lead"


4. American Society for Testing and Materials

ASTM D3335, "Test Method for Low Concentration for Lead, Cadmium, and Cobalt in Paint by Atomic Absorption Spectroscopy"

5. Steel Structures Painting Council

SSPC Guide 61 (CON) Guide for Containing Debris Generated During Paint Removal Operations

6. State of Vermont

Vermont Regulations for Lead Control, V.S.A. Title 18 ,Chapter 38.

B. Local Town, City or County bylaws, rules and regulations

SUBMITTALS

A. Prior to removal of hazardous materials, submit a Hazardous Waste Handling Plan, including identification of the proposed waste hauler and disposal facility with copies of all applicable licenses, registrations and approvals.

B. Provide a detailed plan describing method of removal and disposal of the lead waste. C. Provide copies of all worker certifications associated with OSHA 40 Hour Hazardous Waste

Site Health and Safety Training in accordance with 29 CFR 1910.120. D. Prepare and maintain at the work area a daily log documenting the dates and time of but not

limited to, the following items: progress of work, daily inspections and results, quantity of waste generated each day, waste and other test results, list of all workers and visitors to site, waste removed from site, and other related documentation of work site conditions as applicable. Provide copy of daily log with close out submittals.

E. After completion of hazardous materials removal, provide a final report and close out

submittals documenting removal, transportation and disposal activities. This shall include copies of manifests, shipping slips, daily logs, permits and licenses for this project. Provide final report and close out submittals within 25 calendar days of completion of site work.

POTENTIAL LEAD HAZARD

A. Work involving lead-containing components, as indicated in the lead removal specification, may generate lead dust and debris, and could therefore pose a potential health hazard to both workers and other building occupants. Because lead is a cumulative and persistent toxic substance and because lead-caused health effects may result from low levels of exposure over prolonged periods of time, engineering controls and good work practices must be used to minimize employee exposure to lead. Therefore, workers must be made to realize the seriousness of non-approved procedures and their consequences.

B. During the course of the LP removal or other related work, if workers or other trades-people encounter and/or disturb existing lead-containing components, then appropriate safety and


worker protection measures will be taken to ensure protection from potential lead exposure. These safety measures shall include those procedures contained herein, as applicable, and any additional controls not originally necessary. Safety measures shall be in accordance with all federal, state, and local regulations. Complete, and coordinate with Owner as applicable, all communication of hazards in strict accordance with 29 CFR 1926 and other applicable State and federal regulations for lead, asbestos, PCB, mercury, fluorescent light bulbs, and other anticipated hazards. The Contractor shall coordinate with the Owner and the IH Consultant to review all existing inspection records and testing results as needed.

PRODUCTS

PROTECTIVE EQUIPMENT

A. Provide health and safety equipment required to protect workers and to comply with the Health and Safety Plan.

DRUMS A. Provide DOT approved drums or containers for the disposal of specified materials.

EXECUTION

HAZARDOUS MATERIALS/WASTE

A. All hazardous materials shall be characterized and disposed of in accordance with applicable

regulations. Disposal manifests shall be provided for all waste disposal.

B. Workers who handle hazardous materials shall be licensed and trained in safe and proper hazardous materials handling procedures. At a minimum, this shall include OSHA 40 Hour Hazardous Waste Site Health and Safety Training in accordance with 29 CFR 1910.120.

C. Any hazardous materials containers in poor condition shall be removed as soon as possible.

D. Handling Hazardous Waste 1. Place waste in DOT approved containers and label the containers for transport to a

licensed disposal site.

2. Use an authorized hazardous waste transporter to haul waste to a hazardous waste facility.

3. Follow all record keeping, chain-of-custody and reporting requirements including a copy of the hazardous waste manifest.

4. Accurately measure and weigh the volume of each container or load of waste removed from the site. Submit records of waste volumes to Owner.

5. Special attention shall be given to the time of storage, amount of material stored at any one time, use of proper containers and personnel training.


6. Paint debris shall not be placed on the unprotected ground and shall be shielded to prevent dispersion of the debris by wind or rain water.

7. Provide appropriate notifications to regulatory agencies if there is a release to the environment exceeding the CERCLA reporting requirements (e.g. lead -–1 pound).

8. Any evidence of improper storage shall be cause for immediate shutdown of the project until corrective action is taken.

9. Provide legal transportation of the waste to the disposal landfill, and complete or obtain all required licenses, manifests, landfill slips, or other forms. Copies of all forms or licenses, and the signed original of the Waste Manifest for each waste load, shall be given to the Owner.

LEAD PAINT

A. Lead paint is present on many surfaces throughout the facility. Any Contractor whose activities may generate leaded dust or impact a leaded surface shall be responsible for regulating his work area so that dust migration is contained properly within the regulated area. Once the work is complete, the same Contractor shall be responsible for the proper clean-up and disposal of leaded dust and materials.

B. This specification is intended to address the demolition of structures at the subject site which are coated with lead containing paint. This plan does not address lead related removal work involving abrasive blasting, open-flame burning or torching, machine sanding or grinding without high-efficiency particulate exhaust control, uncontained hydro-blasting or high pressure washing. If any of these methods are to be used, the process shall be re-evaluated and a new work plan developed.

C. Contractor shall isolate the work area using a regulated area in accordance with 29 CFR Part

1926.62. Only authorized, trained personnel will be allowed in the lead work areas during activity involving disturbance of LP. A personnel and equipment decontamination facility, or wash station, will be provided adjacent to the work area. The Contractor shall coordinate with the owner to notify all workers, contractors, subcontractors, and occupants of the presence of LP in accordance with 29 CFR Part 1926 and of the need to prevent any disturbance to the LP during incidental work and other related work at the site.

D. All work practices shall comply with current State DEP, EPA, and US DOL OSHA Standards,

including but not limited to 29 CFR Part 1926.62. Demolition waste containing LP shall be properly containerized and then transported and disposed of in accordance with local, State and federal requirements.

E. Protect all building surfaces not scheduled to undergo removal or other related work in the

work areas and surrounding areas as necessary to prevent any damage. Install polyethylene sheeting to cover building surfaces in the work and as critical barriers to separate and completely isolate the work area from non work areas and outside areas. All removal of building materials containing LP shall be conducted within demarcated, OSHA regulated work areas.


F. Provide personnel and equipment decontamination units contiguous to the work area as

described in the Asbestos Abatement & Related Work Specification Section. All site personnel and equipment shall enter and exit the work area through the decontamination unit and undergo full decontamination.

G. Appropriate dust control methods will be employed during all work impacting all building materials coated with LP including but not limited to spraying with water, stopping work during high wind conditions, etc.

H. Clean all debris that may be encountered during work impacting surfaces where LP is present

from the floor area and elevated surfaces using a combination of HEPA vacuuming and wet wiping methods. Perform continuous cleaning in work area. Utilize a HEPA vacuum to collect residual lead containing paint and blast media remaining on flooring areas and elevated surfaces. This work will be repeated until all visual debris has been removed from substrate. Do not allow dry sweeping in work area. Continually mist work area with water to contain lead contaminated dust dispersal during lead enclosure work and debris collection process. All waste generated during the removal process will be packaged into appropriate waste containers and segregated for testing for proper disposal or disposal as hazardous waste.

I. Polyethylene sheet barriers and air filtration units must be used to isolate the work area if any

mechanical blasting methods are to be used. During use of any blasting methods, provide worker training and safety in accordance with OSHA 1926.62 requirements and equipment manufacturer’s instructions and guidelines. Provide proper personal protective equipment and respiratory protection in accordance with OSHA 1926.62 requirements.

J. Lead paint repair, removal, clean up and other related work procedures shall comply with work procedures as set forth in the EPA’s Lead Removal, Repair and Painting (RRP) Rule. Contractor shall perform on going and clearance work area inspections as needed to ensure compliance with this Section and the EPA RRP rule. Final cleaning and testing criteria for each LP work area shall be as set forth in the EPA’s RRP Rule and current state and federal guidelines for lead paint as follows: 1. Visual inspection of surfaces shows no visible paint remaining on substrates 2. No visible dust or paint debris present, and 3. Airborne concentrations of lead have been reduced to below 1.5 micrograms per cubic

meter (ug/m3) K. All waste generated during this process shall be segregrated and disposed of as either

construction and demolition (C&D) waste or as lead hazardous waste. This determination shall be made by the contractor and based on proper sampling for lead content by Toxicity Characteristic Leaching Procedure (TCLP). Segregation of wastes shall be conducted and directed through screening of wastes at the site using a field testing method such as a x-ray fluorescence (XRF) meter or other suitable screening method.

L. All waste that is found to contain lead greater or equal to 5.0 milligrams per liter (mg/L) by TCLP analysis must be handled and treated as hazardous waste. All waste confirmed to contain lead less than 5.0 mg/L by TCLP may be disposed as C&D waste.

END OF SECTION

APPENDIXE.3

UNIVERSALWASTEABATEMENTSPECIFICATIONS

PCB BALLAST & MERCURY-CONTAINING FLUORSCENT LAMPS

Swanton Municipal Lot – Corrective Action Plan

1-3-5 Canada Street & Merchants Row Swanton, Vermont

PART 1 – GENERAL All workers, contractors, subcontractors, and occupants of the presence of Polychlorinated Biphenyls (PCB) containing light ballasts and mercury-containing fluorescent lamps in accordance with 29 CFR Part 1926 and of the need to prevent any unplanned disturbance to the materials during the work. PCB ballasts and mercury-containing fluorescent lamps present in the work areas shall be removed, transported and disposed of in off-site Environmental Protection Agency (EPA) approved treatment, storage, and disposal facility. Prior to the state of any work, the fixtures shall be de-energized and appropriate energy lockout-tag out pursuant to OSHA standards. Any fixtures with PCB containing light ballasts (any fixture present that does not have a “PCB-Free” label adhered to the ballast) shall be taken down and stacked in the construction staging area. All fixtures and adjacent surfaces shall be cleaned by the subcontractor of any PCB or mercury contamination. PCB or PCB contaminated items shall be placed in approved, labeled disposal containers. Fluorescent Lamps shall be removed from the lighting fixture and carefully packed into appropriate, labeled containers. The Contractor shall provide properly filled out Uniform Hazardous Waste Manifests from the transporter and certificate of destruction from the treatment, storage, and disposal facility. Contractor shall obtain and pay all necessary fees and permits related to the removal, handling, transportation and disposal of PCB waste. PART 2 - HEALTH & SAFETY All mercury and PCB-related work including separation of tubes and ballasts from light fixtures and handling of related items or fluids of any type shall be completed by qualified, trained workers supervised by an OSHA-Competent person. Work Area Protection and Marking: Prior to commencing any PCB or mercury related work activities, the Contractor shall provide barricades, and warning signs to clearly identify and effectively guard against unauthorized entry into the work area. Protective Clothing and Equipment: The following PPE and respiratory protection shall be used at all times when PCB or mercury materials are not sealed in drums, containers or electrical equipment:

• Disposable, nonporous gloves. • Disposable, whole-body clothing impermeable to PCB's. • Respiratory protection (NIOSH/MSHA approved) against organic vapors and particulates (at least

the level of particulate protection required at the stage of work for asbestos protection). • Eye protection.

© RPF Environmental Inc. April 10, 2018 Universal Waste & Related Work Page 2 of 2

Personnel Protection and Procedures: The work area shall be supervised during all PCB and mercury tasks until the tubes, ballasts and related waste has been sealed in the waste containers. If immediate transportation to the disposal/treatment facility is not feasible, the temporary waste storage area shall be approved by Contract Officer and properly labeled and secured. Upon exiting the work area, all disposable protective clothing shall be placed in open-top drums, sealed and removed for disposal. PART 3 - HANDLING, STORAGE AND DISPOSAL Waste Handling & Disposal: All ballasts containing PCB material shall be stored in sealed DOT 17R closed top drums. All PCB waste containers shall be labeled and recorded including type of action, date of action and the name of Contractor and Generator. Prior to submitting the hazardous waste manifest for a shipment of waste to the Owner for signature, Contractor shall make available the transport vehicle and the waste for inspection by the Owner. All waste drums shall be adequately secured to the transport vehicle to prevent movement in transit. Waste transport, loading, unloading and disposal/treatment activity off site shall be completed in accordance with State and federal requirements. Storage Containers for PCBs shall be in accordance with 49 CFR 178. PCB containers shall be approved by DOT for PCB. Storage Containers for mercury-containing lamps shall be in appropriate DOT containers. The waste drums or boxes shall be stored and labeled for transport in accordance with 40 CFR 273. Upon completion of all PCB work related activities, the Contractor shall provide a complete record and storage data to the Owner. The record shall include the following data: Name of Contractor and Competent Person. Description and quantity of material packaged and removed. Description, quantity and weight of waste containers generated. Hazardous waste manifest(s) signed by Contractor, transporter(s), transferrer(s) and/or treater(s), and by the disposal facility within ten (10) days of the time at which the hazardous materials are received at the disposal facility. Clean-up of Work Area: After the last ballasts are removed from fixture, all tools and equipment used in the work shall be decontaminated. Where work surfaces have contacted PCB fluids they shall be scraped clean, flushed with solvent, wiped clean and all debris properly packaged. All tools that may have some in contact with PCB at any concentration shall be thoroughly flushed with solvent and wiped clean. All exterior surfaces of electrical equipment to be removed that may have come in contact with PCBs or contaminated oils or fluids either during the course of work activities or due to past leaks shall be thoroughly cleaned with solvent and wiped clean. All concrete (or other surfaces) which have come in contact with PCBs or PCB mixtures in the course of the work as a result of past leaks shall be thoroughly cleaned using a combination of sorbent, solvent and cleaners. End.

APPENDIXF

STEGOWRAPPRODUCTSHEETANDINSTALLATIONINSTRUCTIONS

TABLE 4.1: PHYSICAL PROPERTIES OF STEGO WRAP 20-MIL VAPOR BARRIER

PROPERTY TEST RESULTS

Under Slab Vapor Retarders ASTM E1745 Class A, B & C – Standard Specification for Water Vapor Retarders Used in Contact with Soil or Granular Fill under Concrete Slabs Exceeds Class A, B & C

Water Vapor Permeance ASTM F1249 – Test Method for Water Vapor Transmission Rate Through Plastic Film and Sheeting Using a Modulated Infrared Sensor 0.0071 perms

Permeance After Conditioning ASTM E154 Section 8, F1249 – Permeance after wetting, drying, and soaking 0.0088 perms(ASTM E1745 ASTM E154 Section 11, F1249 – Permeance after heat conditioning 0.0081 permsSections 7.1.2 - 7.1.5) ASTM E154 Section 12, F1249 – Permeance after low temperature conditioning 0.0084 perms ASTM E154 Section 13, F1249 – Permeance after soil organism exposure 0.0077 perms

Methane Transmission Rate ASTM D1434 - Standard Test Method for Determining Gas Permeability 152.2 GTR* Characteristics of Plastic Film and Sheeting (mL(STP)/m2*day)

Radon Diffusion Coefficient K124/02/95 9.9 x 10-12 m2/second

Puncture Resistance ASTM D1709 – Test Method for Impact Resistance of Plastic Film by Free-Falling Dart Method 3500+ grams**

Tensile Strength ASTM D882 – Test Method for Tensile Properties of Thin Plastic Sheeting 97.7 lbf/in

Thickness 20 mil

Roll Dimensions width x length: 14' x 105' area: 1470 ft2

Roll Weight 140 lb

Note: perm unit = grains/(ft2*hr*in-Hg) *GTR = Gas Transmission Rate**The material maxed out the testing equipment and did not fail at 3746 grams.

P1 OF 2

STEGO® WRAP 20-MIL VAPOR BARRIERA STEGO INDUSTRIES, LLC INNOVATION | VAPOR RETARDERS 07 26 00, 03 30 00 | VERSION: JAN 5, 2018

Continued... Note – legal notice on page 2.

1. PRODUCT NAME

STEGO WRAP 20-MIL VAPOR BARRIER

2. MANUFACTURER

Stego Industries, LLC216 Avenida Fabricante, Suite 101San Clemente, CA 92672 USASales, Technical AssistancePh: (877) [email protected]

3. PRODUCT DESCRIPTION

USES: Stego Wrap 20-Mil Vapor Barrier is used as a below-slab vapor barrier.

COMPOSITION: Stego Wrap 20-Mil Vapor Barrier is a multi-layer plastic extrusion manufactured with only the highest grade of prime, virgin, polyolefin resins.

ENVIRONMENTAL FACTORS: Stego Wrap 20-Mil Vapor Barrier can be used in systems for the control of soil gases (radon, methane), soil poisons (oil by-products) and sulfates.

4. TECHNICAL DATA

STEGO® WRAP 20-MIL VAPOR WRAP BARRIERA STEGO INDUSTRIES, LLC INNOVATION | VAPOR RETARDERS 07 26 00, 03 30 00 | VERSION: JAN 5, 2018

P2 OF 2

5. INSTALLATION

UNDER SLAB: Unroll Stego Wrap 20-Mil Vapor Barrier over an aggregate, sand or tamped earth base. Overlap all seams a minimum of 6 inches and tape using Stego® Tape or Stego® Crete Claw® Tape. All penetrations must be sealed using a combination of Stego Wrap and Stego Accessories.

For additional information, please refer to Stego's complete installation instructions.

6. AVAILABILITY & COST

Stego Wrap 20-Mil Vapor Barrier is available through our network of building supply distributors. For current cost information, contact your local Stego distributor or Stego Industries’ Sales Representative.

7. WARRANTY

Stego Industries, LLC believes to the best of its knowledge, that specifications and recommendations herein are accurate and reliable. However, since site conditions are not within its control, Stego Industries does not guarantee results from the use of the information provided and disclaims all liability from any loss or damage. NO WARRANTY, EXPRESS, IMPLIED OR STATUTORY, IS GIVEN AS TO THE MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR OTHERWISE WITH RESPECT TO THE PRODUCTS REFERRED TO. Please see www.stegoindustries.com/legal.

8. MAINTENANCE

None required.

9. TECHNICAL SERVICES

Technical advice, custom CAD drawings, and additional information can be obtained by contacting Stego Industries or by visiting the website.

Contact Number: (877) 464-7834Website: www.stegoindustries.com

10. FILING SYSTEMS

• www.stegoindustries.com

DATA SHEETS ARE SUBJECT TO CHANGE. FOR MOST CURRENT VERSION, VISIT WWW.STEGOINDUSTRIES.COM

(877) 464-7834 | www.stegoindustries.com

Stego, the stegosaurus design logo[s], Crete Claw, StegoTack, StegoCrawl, Beast, and the Beast design logo are all deemed to be registered and/or protect-able trademarks or service marks of Stego Industries, LLC. © 2018 Stego Industries, LLC. All Rights Reserved. Please see www.stegoindustries.com/legal.

https://www.stegoindustries.com/products/vapor-barrier-20-mil

UNDER-SLAB INSTRUCTIONS:1. Stego Wrap can be installed over an aggregate, sand, or tamped

earth base. It is not necessary to have a cushion layer or sand base, as Stego Wrap is tough enough to withstand rugged construction environments.

2. Unroll Stego Wrap over the area where the slab is to be placed. Stego Wrap should completely cover the concrete placement area. All joints/seams both lateral and butt should be overlapped a minimum of 6” and taped using Stego® Tape.

NOTE: The area of adhesion should be free from dust, dirt, moisture, and frost to allow maximum adhesion of the pressure-sensitive tape.

3. ASTM E1643 requires sealing the perimeter of the slab. Extend vapor retarder over footings and seal to foundation wall, grade beam, or slab at an elevation consistent with the top of the slab or terminate at impediments such as waterstops or dowels. Consult the structural engineer of record before proceeding.

SEAL TO SLAB AT PERIMETER:* NOTE: Clean the surface of Stego Wrap to ensure that the area of adhesion is free from dust, dirt, moisture, and frost to allow maximum adhesion of the pressure-sensitive adhesive.

a. Install Stego® Crete Claw® Tape on the entire perimeter edge of Stego Wrap. b. Prior to the placement of concrete, ensure that the top of Stego

Crete Claw Tape is free of dirt, debris, or mud to maximize the bond to the concrete.

IMPORTANT: Please read these installation instructions completely, prior to beginning any Stego Wrap installation. The following installation instructions are based on ASTM E1643 - Standard Practice for Selection, Design, Installation, and Inspection of Water Vapor Retarders Used in Contact with Earth or Granular Fill Under Concrete Slabs. If project specifications call for compliance with ASTM E1643, then be sure to review the specific installation sections outlined in the standard along with the techniques referenced in these instructions.

VAPOR BARRIER

STEGO TAPE

Minimum 6” overlap

FIGURE 1: UNDER-SLAB INSTALLATION

VAPOR BARRIER

STEGO CRETE CLAW TAPE

SLAB PERIMETER

VAPOR BARRIER

FOOTING

STEGOTACK TAPE

FIGURE 2a: SEAL TO SLAB AT PERIMETER

FIGURE 2b: SEAL TO PERIMETER WALL

STEGO LABOR SAVER! This method not only complies with ASTM E1643, but it also:• reduces labor compared to other perimeter sealing techniques.• can be used even without an existing wall or footing, unlike alternatives.

OR SEAL TO PERIMETER WALL WITH STEGOTACK® TAPE:*

a. Make sure area of adhesion is free of dust, dirt, debris, moisture, and frost to allow maximum adhesion.

b. Remove release liner on one side and stick to desired surface.

c. When ready to apply Stego Wrap, remove the exposed release liner and press Stego Wrap firmly against StegoTack Tape to secure.

* If ASTM E1643 is specified, consult with project architect and structural engineer to determine which perimeter seal technique should be employed for the project.

STEGO® WRAP VAPOR BARRIER/RETARDERINSTALLATION INSTRUCTIONS

www.stegoindustries.com Continued... Note – legal notice on page 2.

P1 of 2

MULTIPLE PIPE PENETRATION SEALING:Multiple pipe penetrations in close proximity and very small pipes may be sealed using Stego Wrap and Stego Mastic for ease of installation (See Figure 5).

STEGO TAPE

STEGO MASTICCOMPLETELY FILL ALL VOIDS

FIGURE 5: MULTIPLE PIPE PENETRATION SEALING

STEGO WRAP PIPE PENETRATION REPAIR DETAIL:1: Install Stego Wrap around pipe penetrations by slitting/cutting material as needed. Try to minimize the void space created.2: If Stego Wrap is close to pipe and void space is minimized then seal around pipe penetration with Stego Tape and/or Stego Mastic.(See Figure 4a)

3: If detail patch is needed to minimize void space around penetration, then cut a detail patch to a size and shape that creates a 6” overlap on all edges around the void space at the base of the pipe. Stego Pre-Cut Pipe Boots are also available to speed up the installation.4: Cut an “X” the size of the pipe diameter in the center of the pipe boot and slide tightly over pipe.5: Tape down all sides of the pipe boot with Stego Tape.6: Seal around the base of the pipe using Stego Tape and/or Stego Mastic. (See Figure 4b)

STEGO TAPE

LARGE VOID SPACE CREATED

STEGO MASTICSTEGO TAPE

CUT AN “X” THE SIZE OFPIPE DIAMETER OR

STEGOPRE-CUTPIPE BOOT




FIGURE 4b: DETAIL PATCH FOR PIPE PENETRATION SEALING

MINIMAL VOID SPACE CREATED

STEGO MASTICSTEGO TAPE

OR

FIGURE 4a: PIPE PENETRATION SEALING

5. IMPORTANT: ALL PENETRATIONS MUST BE SEALED. All pipe, ducting, rebar, wire penetrations and block outs should be sealed using Stego Wrap, Stego Tape and/or Stego Mastic (See Figure 4a). If penetrations are encased in other materials, such as expansive materials like foam, unless otherwise specified, Stego Wrap should be sealed to the underlying penetration directly.

STEGO TAPE

DAMAGED AREA

STEGO TAPE STEGO TAPE

SMALL HOLEOR

FIGURE 3: SEALING DAMAGED AREAS

4. In the event that Stego Wrap is damaged during or after installation, repairs must be made. For holes, cut a piece of Stego Wrap to a size and shape that covers any damage by a minimum overlap of 6” in all directions. Clean all adhesion areas of dust, dirt, moisture, and frost. Tape down all edges using Stego Tape (See Figure 3).

NOTE: Stego Industries, LLC’s (“Stego”) installation instructions are based on ASTM E1643 - Standard Practice for Selection, Design, Installation, and Inspection of Water Vapor Retarders Used in Contact with Earth or Granular Fill Under Concrete Slabs. These instructions are meant to be used as a guide, and do not take into account specific job site situations. Consult local building codes and regulations along with the building owner or owner’s representative before proceeding. If you have any questions regarding the above mentioned installation instructions or Stego products, please call us at 877-464-7834 for technical assistance. While Stego employees and representatives may provide technical assistance regarding the utility of a specific installation practice or Stego product, they are not authorized to make final design decisions.

NOTE: Stego Industries recommends the use of vapor barrier-safe concrete accessories, like Beast® Screed, to help minimize the amount of penetrations in a Stego Wrap Installation.

2

1

3

Beast Screed Adjustable Cap

Beast Screed SystemBeast Screed will easily adjust to ensure a fixed elevation and more accurate FL numbers than traditional wet-screeding.

Beast Screed Post

Beast Foot

www.stegoindustries.com STEGO INDUSTRIES, LLC • SAN CLEMENTE, CA 92672 • 949-257-4100 • 877-464-7834 Stego, the stegosaurus design logo[s], Crete Claw, StegoTack, StegoCrawl, Beast, and the Beast design logo are all deemed to be registered and/or protectable trademarks or service marks of Stego Industries, LLC. © 2018 Stego Industries, LLC. All Rights Reserved. Please see www.stegoindustries.com/legal. 1/2018

P2 of 2

APPENDIXG

OPINIONOFCOSTTABLES

1 CertificateofCompletion‐DeedRestrictionPreparationofInstitutionalControlinformation

Principal hrs 1 162$ 162$Sr.PM hrs 2 130$ 260$E3/G3 hrs 4 97$ 388$Drafter hrs 2 84$ 168$Support hrs 2 65$ 130$ 1,108$ 1,108$

Contingency(10%) 111$ AlternativeTotal: 1,219$

AssistwithpreparationofInstitutionalControltorequirenotificationtoVTDECiffuturesoildisturbanceoccursinidentifiedcontaminationareasforVTDEC'sCertificateofCompletion.

Assumptions:Attorneyfeesthatmaybeincurredbythesiteownerarenotincluded.

ScopeDetails

Notes:1.Costshavebeenroundedtothenearestwholedollar.2.A10%contingencyhasbeenincludedtoaccountforchangesinredevelopmentplans,requestsforadditionalinformation,andunforeseencircumstances.

Rate UnitTotal Sub‐Total TaskTotalTask Units

April2018

Quantity

Alternative1b(Soil)[RECOMMENDEDALTERNATIVE]:On‐sitesoilreuse/NoticewithintheCOCthatrequiresnotificationtoDECifanyfuturesoildisturbancewilloccurinareaswherecontaminationhasbeenidentified

OpinionofCost‐CorrectiveActionPlan1‐3‐5CanadaStreetandMunicipalLot,Swanton,VT

Type

P:\4000s\4091.00\SourceFiles\CAP\App‐G_Cost\201804_Cost_Opinion.xlsx Page1of1 Sanborn,HeadAssociates,Inc.

1 ProjectCoordinationAgency/propertyownercommunications,recordkeeping

Principal hrs 1 162$ 162$Sr.PM hrs 4 130$ 520$Drafter hrs 1 84$ 84$Support hrs 1.5 65$ 98$ 864$ 864$

2 CommunityRelationsPlanFieldObservation/Reporting

Principal hrs 1 162$ 162$Sr.PM hrs 4 130$ 520$E3/G3 hrs 8 97$ 776$Drafter hrs 1 84$ 84$Support hrs 1.5 65$ 98$ 1,640$ 1,640$

3 Excavation,Transport,andDisposalofContaminatedSoilsQEPOversight/Sampling/Documentation

Sr.PM hrs 1 130$ 130$E3/G3 hrs 8 97$ 776$Drafter hrs 1 84$ 84$Mileage mi 80 0.54$ 43$ 1,033$

SoilExcavation/Backfill/DisposalExcavatorMobilization/Demobilization ea 1 950$ 950$Equipmentdayrate day 1 860$ 860$EquipmentOperator hours 10 65$ 650$FieldTechnician day 1 55$ 55$VibratoryRoller day 1 600$ 600$Sand CY 24 8$ 192$SandTransportation(14CYloads) loads 2 140$ 280$PolyMarkerLiner ea 1 100$ 100$Non‐HazUrbanSoilDisposalasADC tons 30 40$ 1,200$Transportation(Assumes28tonloads) tons 28 40$ 1,120$PickupTruck day 1 185$ 185$ 6,192$

QEP‐ConfirmatorySamplingLaboratoryAnalysisVOCs8260 sample 2 120$ 240$PAHs sample 2 135$ 270$ 510$ 7,735$

4 RemedialActionReportPrincipal hrs 2 162$ 324$Sr.PM hrs 4 130$ 520$E3/G3 hrs 20 97$ 1,940$Drafter hrs 2 84$ 168$Support hrs 2 65$ 130$ 3,082$ 3,082$

Contingency(10%) 1,332$AlternativeTotal: 14,653$

Alternative1c(Soil):TargetedSoilExcavationwithOff‐SiteSoilDisposal


Coordinationwithsiteowner,contractors,andAgencies.

Assumptions:‐ProjectManagertopreparemonthlyinvoices.

PreparationofaCommunityRelationsPlantoaddresspotentialpublicconcernsregardingtrucktraffic.

ScopeDetailsRate UnitTotal Sub‐Total TaskTotalTask Units

1.Costshavebeenroundedtothenearestwholedollar.2.A10%contingencyhasbeenincludedtoaccountforchangesinredevelopmentplans,requestsforadditionalinformation,andunforeseencircumstances.3.Contractorandlaboratorycostsassumedirectcontractingtositeowneranddonotincludemarkup.4.Actualcostsdescribedabovemayvaryifdifferentmethodsorsequencingareusedbythecontractor.

April2018

Draftremedialactionreporttodocumentoff‐sitesoildisposalandconfirmatorysamplinginaccordancewithVTDECI‐Rule.

Assumptions:IncludesreviewandstampbyVT‐licensedProfessionalEngineer.

QEPexcavation/backfillobservation,sampling,anddocumentation.ExcavatedowntoindicatormarkerfromUST‐Eastexcavationplus2feet(9ftbgstotaldepth),transportexcavatedsoiloff‐sitefordisposal,collecttwoconfirmatorysamplesforlaboratoryanalysis(VOCsandPAHs),placeindicatormarker,backfillwithsandandcompact.

Assumptions:‐Siteowner/representativewillperformDigSafenotification.‐QEProundtriptravelfromBurlingtontothesite‐Forcostpurposes,assume5ftx9ftx11ftvolume(approximatefootprintofformerUST‐East,plustwofeetbeneathformerUST)tobeexcavated(totalof18CY;assume1.5tons/CY)anddisposalofexcavatedmaterialasalternativedailycoveratNEWSVTLandfillinCoventry,Vermont.‐CollectionoftwoconfirmatorysamplesandonestockpilesamplebyQEP.‐Assume24‐hourlaboratoryanalysis.‐ShouldconfirmatorysoilsamplesindicateexceedancesofindustrialSSVs,additionalsoilexcavation(notcostedherein)wouldberequired.

QuantityType


1 CertificateofCompletion‐DeedRestrictionPreparationofInstitutionalControlinformation




Alternative2b(Groundwater)[RECOMMENDEDALTERNATIVE]:DeedRestrictiontoprohibitgroundwaterextraction


April2018

AssistwithpreparationofInstitutionalControltoprohibitgroundwaterextractionatthesiteforVTDEC'sCertificateofCompletion.


Task Units Quantity Rate UnitTotalType Sub‐Total TaskTotalScopeDetails


1 InstitutionalControlSupport‐DeedRestriction/ZoningChangePreparationofInstitutionalControlinformation



Rate UnitTotal Sub‐Total TaskTotal


ScopeDetailsAssistwithpreparationofInstitutionalControltoprohibitresidentialuseoftheMemorialBuildingthroughaDeedRestriction(e.g.,NoticetoLandRecords)orzoningchange.


Task Units QuantityType

Alternative3b(SoilGas):DeedRestrictionorzoningchangewillberequiredtoprohibitresidentialuseoftheMemorialBuilding


April2018


1 ProjectCoordinationAgency/propertyownercommunications,recordkeeping

Principal hrs 1 162$ 162$Sr.PM hrs 4 130$ 520$Drafter hrs 1 84$ 84$Support hrs 1.5 65$ 98$ 864$ 864$

2 BackfillMemorialBuildingBasement/VaporBarrierInstall/PourConcreteFloorQEPOversight/Documentation

Sr.PM hrs 1 130$ 130$E3/G3 hrs 10 97$ 970$Drafter hrs 1 84$ 84$Mileage mi 80 0.54$ 43$ 1,227$

SoilExcavation/Backfill/DisposalStegoWrapRoll ft2 8 600$ 4,800$StegoTape ft 8 60$ 480$DragoSeal 2gal 20 250$ 5,000$ExcavatorMobilization/Demobilization ea 1 950$ 950$Equipmentdayrate day 4 860$ 3,440$EquipmentOperator hours 40 65$ 2,600$FieldTechnician day 4 55$ 220$VibratoryRoller day 3 600$ 1,800$Sand CY 1917 8$ 15,336$SandTransportation(14CYloads) loads 137 140$ 19,180$Gravel CY 1490 6$ 8,940$GravelTransportation(14CYloads) loads 106 185$ 19,610$Concrete(3000psi,delivered) yards 190 165$ 31,350$32Meterboompump(4hourshift) shifts 2 1,250$ 2,500$PickupTruck day 1 185$ 185$ 116,391$ 117,618$



Alternative3c(SoilGas)[RECOMMENDEDALTERNATIVE]:MemorialBuildingBasementFillingandSealing


Coordinationwithpropertyowner,contractors,andAgencies.


ScopeDetailsRate UnitTotal Sub‐Total TaskTotalTask Units

Notes:1.Costshavebeenroundedtothenearestwholedollar.2.A10%contingencyhasbeenincludedtoaccountforchangesinredevelopmentplans,requestsforadditionalinformation,andunforeseencircumstances.3.Contractorandlaboratorycostsassumedirectcontractingtositeowneranddonotincludemarkup.4.Actualcostsdescribedabovemayvaryifdifferentmethodsorsequencingareusedbythecontractor.

April2018

DraftremedialactionreporttodocumentvaporMemorialBuildingdisposal.


Quantity

BackfillofMemorialBuildingBasementwith4.5feetofsandand3.5feetofgravel(placementandliftstobedeterminedbysitecontractor),andcompletionwith6‐inchconcretefloorslab.Placeandseal.OnedayofQEPobservationduringconcretepourforfielddocumentation.

Assumptions:‐AssumeafootprintofMemorialBuildingof10,000sq.ft.‐Siteowner/representativewillperformDigSafenotification(ifrequired).‐Existingbasementfoundationwallsandfloortoremaininplace.‐Assumeplacementof20‐milStegovaporbarrierlinerwithtapedseamsandDragoSealaroundpenetrations.‐NoslottedPVCpipeisrequiredtobeinstalledbeneaththevaporbarrierlinertoreceiveCertificateofCompletionwithoutbuildinguserestrictionsfromVTDEC.‐Fourdayswillberequiredtobackfillthebasementandpouraconcreteslab.‐Costsforpurchaseandinstallofrebar/structuralsteelfortheconcretefloorslabwillbeincludedasasiteredevelopmentactivitiesandarenotincludedherein.‐Assume190CYofconcretewillberequiredtoachieveathicknessof6‐inchesoverthefootprintoftheMemorialBuilding.‐Assume1,667CYofsandwillbeusedtoachieveathicknessof4.5feetoverthefootprintoftheMemorialBuilding,plus15%(totalof1,917CY).‐Assume1,296CYofgravelwillbeusedtoachieveathicknessof3.5feetoverthefootprintoftheMemorialBuilding,plus15%(totalof1,490CY).

Type


1 ProjectCoordinationAgency/propertyowner/contractorcommunications,recordkeeping

Principal hrs 1 162$ 162$Sr.PM hrs 4 130$ 520$Drafter hrs 1 84$ 84$Support hrs 2 65$ 130$ 896$ 896$

2 HBMAbatementMemorialBuilding ACM ea 1 4,110$ 4,110$

Universal ea 1 500$ 500$WarehouseBuilding ACM ea 1 420$ 420$

Universal ea 1 500$ 500$ProutyBuilding ACM ea 1 9,780$ 9,780$(1CanadaSt) LBPScreening day 1 2,000$ 2,000$

TCLP sample 5 240$ 1,200$LBP(hazdisposal) ea 1 6,000$ 6,000$Universal ea 1 250$ 250$

ConnectorBuilding ACM ea 1 19,320$ 19,320$(3CanadaSt) Universal ea 1 500$ 500$TheatreBuilding ACM ea 1 11,930$ 11,930$(5CanadaSt) Universal ea 1 250$ 250$SwantonCoC ACM ea 1 1,200$ 1,200$ 57,960$ 57,960$



Notes:1.Costshavebeenroundedtothenearestwholedollar.2.A10%contingencyhasbeenincludedtoaccountforchangesinredevelopmentplans,requestsforadditionalinformation,andunforeseencircumstances.3.Inordertomoreaccuratelycharacterizeanddelineatepotentiallyleadcontaminatedsurfaces,additionaltargetedcharacterizationsamplingoftheProutyBuildingat1CanadaStreetshouldbeconductedbythedemolitioncontractorpriortoorduringdemolitionofthestructure.Thetargetedcharacterizationcouldbeconductedusinganx‐rayfluorescence(XRF)meterorotherdirectreadingtechnologytodirectthesamplingeffortandassistinsegregatingleadcontaminatedfromnon‐leadcontaminatedwastes.TargetedcollectionofsamplesforTCLPanalysiscouldbeinformedbytheXRFresults.4.Contractorandlaboratorycostsassumedirectcontractingtositeowneranddonotincludemarkup.5.Actualcostsdescribedabovemayvaryifdifferentmethodsorsequencingareusedbythecontractor.

DraftremedialactionreporttodocumentHBMdisposal.


1‐3‐5CanadaStreetandMunicipalLot,Swanton,VT

Rate UnitTotal Sub‐Total TaskTotalTask Units Quantity

April2018

HBMabatement(segregation,transport,disposalatalicensedfacility)byqualifiedcontractors.

Assumptions:‐Siteowner/representativewillperformAgencynotifications.‐SuspectACMonMemorialBuildingandWarehouseBuildingroofswillremaininplace.‐OnlyanticipatedHBMabatementcostsareprovidedherein.Buildingdemolition/disposalcostsfornon‐HBMsincurredbythesiteownerarenotincludedintheseestimates.‐Ofthesitebuildings,onlytheProutyBuildingwillrequireLBPabatement.‐Identificationofpotentialcharacteristicallyhazardousleadmaterialwillrequireadditionalcharacterization(seenoteandHBMreportinAppendixD).Forcostestimatepurposes,weassumedonedayofleadscreeningusinganXRFtoidentifyelevatedleadconcentrations,collectionof5samplesforleadTCLPanalysis,andprofiling/transport/disposalofone25cubicyarddumpster.‐Wehaveassumedonlypaintedwoodwouldbesegregatedashazardousforlead(totalweightnomorethan4.5tons;assuming330poundspercubicyard).

ScopeDetails

OpinionofCost‐CorrectiveActionPlan

Alternative4b(HazardousBuildingMaterials[HBMs])[RECOMMDENEDALTERNATIVE]:AbatementofHBMs

CoordinationwithpropertyownerandAgencies.


Type
