iso lessons learned - knowledge @ urbanknowledge.urbanengineers.com/assets/ll0906b1.pdf12/13/2006 1...

12/13/2006 1

ISO LESSONS LEARNED

DATE: 12/13/2006

TO: URBAN ENGINEERS, INC.

CC: ISO MANAGEMENT COMMITTEE

FROM: BRUCE M. MUNDORF, ESQ

RE: ISO LESSONS LEARNED TO BE REVIEWED DURING PROJECT KICK-OFF MEETING

• Urban’s ISO procedure, 404P-1, Rev. 7, October 20, 2004, (7.3) 2000, requires, at Step 7, an internal kick-off meeting with a requirement that Lessons Learned will be reviewed.

See, http://knowledge.urbanengineers.com/index.cfm?event=ISOAssets&subNavID=29

• This document contains the Lessons Learned that are to be reviewed by the personnel attending the internal kick-off meeting to comply with that requirement.

• Please note, Lessons Learned can be generated at any time, by any Urbanite. Please forward any Lessons Learned to the General Counsel’s Assistant, Joanna Robinson, ext. 1737.

BMM

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http://knowledge.urbanengineers.com/index.cfm?event=ISOAssets&subNavID=29

Internal Use Only Not for Outside Distribution

Original to Project Notebook Copy to Knowledge @ Urban

Lessons Learned Input

Project: Morrisville Phase 2 Urban Project No. 025100 Prepared by: Alan Collins 1. List all Lessons Learned topics. Use key words only. Survey: Plan Details – Track & Catenary 2. Describe Lessons Learned for each key work topic. Use additional pages as required. Survey: Don’t cheap out on survey costs! By trying to SCR one day of survey crew

time, collection of some important data was delayed for months. Only when we finally got that survey data did we grasp the problem posed by proximity of existing PECO wires.

See prior e-mail about hanger tabulations and track geometry data.

Form No. Form Name Revision No.

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U-404-1 F1 Project Close-Out Check List 4 7/3/03 Executive VP 2 of 2

Bruce M. Mundorf, Esq.

Please note that these Lessons Learned extend over a number of years. Standards, Codes, Contract Clauses, and Regulations may have changed since these items were authored. They are collected for your review and are not to substitute for sound engineering/professional practices.




Project: 30th Street Parking Garage Urban Project No. 011600 Prepared by: A. Scott 1. List all Lessons Learned topics. Use key words only. Contract Assignment Design Changes During Construction 2. Describe Lessons Learned for each key work topic. Use additional pages as required. Contract Assignment The original contract between the Urban Engineers, Inc./STV joint venture and Aegis

Property Group was assigned at the completion of the design phase. While 30 SPA inherited the nights and responsibilities of Aegis, they were not party to some of the decisions made during the design period. This created several situations where our internal documentation and meeting minutes were important in resolving issues that otherwise might have resulted in claims. Record keeping of essentially all decisions and the reasons for doing so proved its value.

Design Changes During Construction Throughout the design phase, the design team was challenged to identify changes that

might be necessary if a office tower was constructed adjacent to the parking garage. This became a reality early in the construction phase resulting in numerous design changes. While most of the changes had been anticipated, the scope of the rework had not been defined well, thus the cost of the design changes were not anticipated by the client. On similar project, the potential cost of changes to the project budget should not be restricted to the construction costs, but thee related design costs as these may be substantial given that they are done out of the normal design sequence and on an expedited basis.


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Project: Litigation Support Urban Project No. 0144-02 Prepared by: Polivra Suntace Engineering, LTD 1. List all Lessons Learned topics. Use key words only. Records Daily Logs Agreements (Verbal) 2. Describe Lessons Learned for each key work topic. Use additional pages as required. Found out how important it is to keep accurate and detailed records. We kept very good records, which is going to benefit the General Contractor and his sues

in this litigation. The daily logs with the location of activities, manpower, equipment and material along

with documentation of events during the day are invaluable. Any agreements made on the site, make sure it’s in writing.


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Project: Livernois Intermodal Urban Project No. 020502 Prepared by: Alan Collins 1. List all Lessons Learned topics. Use key words only. Design of Inlets Survey of Existing Tracks 2. Describe Lessons Learned for each key work topic. Use additional pages as required. Design of Inlets: Better to do the detailed structural design ourselves rather than educate the precaster’s

engineer on the peculiarities of packer loading. In this case, the education took several iterations of shop drawing review. Survey of Existing Tracks: Survey only track at the periphery of the project site. Al Livernois, the existing track at

the top of the slope became an issue when the contractor ignored our design and cut too far into the slope.


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Project: 30th Street Intermodal Gateway Urban Project No. 985101-17 Prepared by: A. Scott 1. List all Lessons Learned topics. Use key words only. Client satisfaction Joint Venture Utility demand 2. Describe Lessons Learned for each key work topic. Use additional pages as required. Client Satisfaction: This project started out as a $200,000, 3 month assignment that has not entered its

seventh year with team fees exceeding $5,000,000. Despite a somewhat rocky start, the growth in contract value was basically as a result of providing service on demand to a demanding client. The client was not just interested in technical excellence, but wanted accurate and timely invoicing responsiveness to a significant number of changes in direction.

Joint Venture The project has undertaken as a joint venture. The project manager has switched between

JV partners and thus project record keeping is split between the two firms. JV agreements should include a description of how project files are to be integrated.

Utility Demand: An early assignment was to determine utility service demand for various concepts. The

base


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Project: 30th Street Master Plan Urban Project No: 039933 Prepared by: A.J. Scott 1. List all Lessons Learned topics. Use key words only. Base Plans 2. Describe Lessons Learned for each key work topic. Use additional pages as required. This planning update attempted to rely on digital plans prepared several years earlier by

another consultant. It was difficult to determine whether they accurately reflected the site conditions at the time since there was no revision block or other information. this was not a serious issue for a planning study, but could potentially be problematic on a design assignment. Digital bas plans should be electronically bound to a revision block.


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Project: Philadelphia TIS Urban Project No. 4123-00 Prepared by: 1. List all Lessons Learned topics. Use key words only. Non-compete agreements. 2. Describe Lessons Learned for each key work topic. Use additional pages as required. Be careful in agreeing to non-compete agreements, as there can be unintended

consequences.


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Project: E-Rail Urban Project No. 004702 Prepared by: Alan Collins 1. List all Lessons Learned topics. Use key words only. 2. Describe Lessons Learned for each key work topic. Use additional pages as required. Budget for more survey time if area is overgrown with brush


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Project: Conrail Relocation Urban Project No. 015403 Prepared by: Joseph T. Mongillo 1. List all Lessons Learned topics. Use key words only. Post Tensioning Records Daily Logs 2. Describe Lessons Learned for each key work topic. Use additional pages as required.

A. Before any post tensioning takes place make sure there is a plan for the uniform displacement. The specification has been re-written to cover this procedure.

B. Be sure all records are accurate, up to date and very thorough.

C. Daily logs should contain activities of the various crews, exact work location, manpower, equipment any delays or other related setbacks.


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Project: Safety Training Urban Project No: 4060-00 Prepared by: Alan Collins 1. List all Lessons Learned topics. Use key words only. 2. Describe Lessons Learned for each key work topic. Use additional pages as required. Teaching service, not the usual plans & specs.


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Project: Chicago Shop East Urban Project No. 4085-00 Prepared by: Alan Collins 1. List all Lessons Learned topics. Use key words only. 2. Describe Lessons Learned for each key work topic. Use additional pages as required. One time cost estimate.


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Project: Pier 124 Sale Urban Project No. 039902 Prepared by: Alan Collins 1. List all Lessons Learned topics. Use key words only. Source Documents 2. Describe Lessons Learned for each key work topic. Use additional pages as required. Source documents in this case map showing property splits between NS & CSX, should

be preserved at any cost.


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Project: E-Rail Phase II Urban Project No. 004702 Prepared by: FS Telford 1. List all Lessons Learned topics. Use key words only. Subcontractor 2. Describe Lessons Learned for each key work topic. Use additional pages as required. Survey Subcontractor Niak-Prasad’s progress was very slow. Productivity of UEI did not suffer. However, a reevaluation of NPI in K@U database of approved subs is warranted


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Project: Elkhart Diesel Shop Urban Project No. 503408 Prepared by: D. Sands 1. List all Lessons Learned topics. Use key words only. Invoices for sub-consultants. 2. Describe Lessons Learned for each key work topic. Use additional pages as required. Request that sub-consultant invoices be received by the first of each month so that we can

be billed in a timely manner with the billing to the client.


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Project: 5300-5318 Wynnefield Avenue Urban Project No. 600300 Prepared by: Jennifer Pesch 1. List all Lessons Learned topics. Use key words only. Fluorescent Light Ballasts 2. Describe Lessons Learned for each key work topic. Use additional pages as required. Testing for PCBs in the light ballasts is expensive and is not recommended by Urban .

Instead, we observe labels on some representative ballasts since they usually indicate if ballasts contain PCBs. Health risks associated with non-leaking fluorescent ballasts is small..


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Project: Salem Track Inspection Urban Project No. 039918 Prepared by: 1. List all Lessons Learned topics. Use key words only. Walking mileage 2. Describe Lessons Learned for each key work topic. Use additional pages as required. 4 miles/day was too much for this type of work


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Project: Soil Sampling of Fill Material Urban Project No. 601100 Prepared by: Jennifer Pesch 1. List all Lessons Learned topics. Use key words only. Safe Fill Regulations 2. Describe Lessons Learned for each key work topic. Use additional pages as required. Refreshed knowledge on PADEP’s Safe Fill regulations for this project.


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Project: Packer Avenue Marine Terminal – API Urban Project No. 602800 Prepared by: Jennifer Pesch 1. List all Lessons Learned topics. Use key words only. Asbestos and roofing Asbestos roofing and floor tile removal prior to demolition 2. Describe Lessons Learned for each key work topic. Use additional pages as required. When a building is demolished with the roof material in place, the roofing material must

be segregated after the demolition and disposed of at a landfill which is permitted to accept nonfriable Category I asbestos waste. A city of Philadelphia Asbestos Investigator should be onsite during the segregation to ensure roofing is disposed of properly.


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Project: Croxton Lighting Urban Project No. 039922 Prepared by: Alan Collins 1. List all Lessons Learned topics. Use key words only. Reference Files Subconsultants 2. Describe Lessons Learned for each key work topic. Use additional pages as required. Make sure your subconsultants are using good seed files so that their work can be

referenced into your work without any manipulation.


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Project: Elkart Loco Service Facility Urban Project No. 400100 Prepared by: D.J. Sands 1. List all Lessons Learned topics. Use key words only. Define Scope 2. Describe Lessons Learned for each key work topic. Use additional pages as required. The project manager must define scope specifically and review the definitive scope with

the subconsultant to confirm that they understand and agree with it. On the Elkhart project, the subconsultant, Rail quality By Design, was responsible for the mechanical, electrical and plumbing design. RQBD was not receptive to value engineering or client comments concerning design details. This caused the work to be a lot more expensive than budgeted.


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Project: Harrisburg Loco Dumps Urban Project No. 503418 Prepared by: 1. List all Lessons Learned topics. Use key words only. Regulatory Requirements 2. Describe Lessons Learned for each key work topic. Use additional pages as required. Harrisburg DPW is not inclined to let the railroad do what it wants, in this case, empty

locomotive toilet tanks into the city system. Rather than challenge them, we just changed our design so Harrisburg’s approval wasn’t required.


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Project: Stenton/Godfrey Signing Urban Project No. 0342-00 Prepared by: Susan Best 1. List all Lessons Learned topics. Use key words only. E-mailed instructions 2. Describe Lessons Learned for each key work topic. Use additional pages as required. Received direction and clarifications of guidelines from the client throughout the process

in telephone calls and email. Forwarded the comments to the responsible engineer as appropriate and filed the comments in email or network folders as appropriate. I should have maintained a more formal process for compiling the comments in an easily retrievable manner.


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Project: Croxton Paving Urban Project No. 413800 Prepared by: Alan Collins 1. List all Lessons Learned topics. Use key words only. Communication with client Finished Grades Specificity of Plans 2. Describe Lessons Learned for each key work topic. Use additional pages as required. Communication with NS We made some assumptions on gradients and proposed terrain and drainage. We should

have shared these with NS sooner, because they had different ideas. Finished Grades: No more than 2.5% for truck and chassis parking. We started using 4%. Specificity of Plans: NS wants everything “cut and dried” on the plans, with nothing left to the contractor’s

judgment. Show exactly what type of inlets you want, exactly where each hay bale dam goes, etc.


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Project: Dillerville Air Urban Project No. 507516 Prepared by: Alan Collins 1. List all Lessons Learned topics. Use key words only. Utility Requirements Owner furnished components 2. Describe Lessons Learned for each key work topic. Use additional pages as required. Pennsylvania Power & Light has detailed plans available on the web showing their

requirements for new service pole, meter, disconnect, etc. Norfolk Southern furnishes an air compressor in a 20’ container, complete with interior

ventilation, heat, light, and electric panel. Don’t alter it unless absolutely necessary.


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Lessons Learned - Petroleum Contaminated Soil Disposal Costs

Several questions concerning petroleum contaminated soil disposal costs have recently surfaced. I phoned a contact at Clean Earth of Philadelphia to get the scoop on bottom line costs. Although there are several variables in determining exact costs, the following general assumptions can be made:

1. The average cost for the actual “disposal” of soil contaminated with petroleum (TPH less than 20,000 PPM with a percent moisture less than 15%) is $30 per ton. This cost may vary by +/- 25% depending on the quantity of soil to be disposed. In addition, this cost may increase according to the following:

30,000 PPM will cost and additional $1 per ton to dispose).

moisture of 25% will cost an additional $5 per ton to dispose due to the extended period of time required to burn off the excess moisture).

The cost increases S O cents per ton every 5,000 PPM TPH above 20,000 (e.g. soil with a TPH of

The cost increases S O cents per ton for every 1% moisture above 15% (e.g. soil with a percent

2. The average cost to transport petroleum contaminated soil generally runs from $5 to $10 per ton based on the distance traveled, number of pickups per day, weather conditions, etc.

3. Additional costs to be included in soil disposal include excavation costs, consulting costs, etc.

With all these costs in mind, if a subconsultant is hired to perform most or all of the above services, you can expect the cost to dispose of petroleum-contaminated soil to run from $50 to $75 per ton. For further information, you can contact Terry Sulock at Clean Earth of Philadelphia, (2 15) 724-5520, Ext. 12.

ster - Third letter. doc

This form letter should be used when a third party, such as a bank, wishes to use Urban s Phase I report.When we can, we should charge for this, since we are theoretically subject to additional liability withoutcompensation.

Bruce Mundorf has reviewed the letter s language. The letter was used previously for United Savings Bankin connection to the Kintock Phase I (October , 1999). A previous version of the letter was also used toAlto Sign s bank (circa 98 - 99). Mike Dostilio is modifing the letter for use by the Penna IndustrialDevelopment Authority (January 26 2000).

Thomas G. MayJanuary 2000

October 26, 1999

Mr. NAM, Vice PresidentXX Savings BankADDRESS , ETC.

Subject: Environmental Report for PROPERTY

Dear Mr. NAM:

In DATE, Urban Engineers , Inc. (Urban) prepared a Phase I Environmental SiteAssessment (ESA) of the propert located at LOCATION for the CLEINT-NAME.XX Savings Bank may rely on the information contained in the report subject to thefollowing conditions:

XX Savings Bank acknowledges and agrees to be bound by the disclaimers andlimitations set forth in the report and the provisions set forth in Urban s contract withCLEINT-NAM (copies of which are attached hereto and incorporated by referenceas if fully set forth).

Any reliance by XX Savings Bank shall be consistent and in keeping with the projectwork scope deemed appropriate by CLIENT-NAM at the time Urban s serviceswere performed and the projects ' time and budget limitations.

XX Savings Bank acknowledges that Urban is making no representations as to thecurrent condition of the subject site.

XX Savings Bank acknowledges that the findings of a Phase I ESA, no matter howthoroughly conducted, are limited and Urban Engineers , Inc. cannot know or state asan absolute fact that the site is unaffected by reportable quantities of regulatedcontaminants. Further, even if Urban believes that reportable quantities of regulatedcontaminants are not present, there is still a risk, assumed by those relying on thePhase I ESA that such contaminants may have been present or may migrate to the siteafter completion of the assessment.

Bruce M. Mundorf, Esq.

Each project and lender are unique and these are only a starting point. Any request for a third party reliance must be reviewed by Legal and approved by a Principal. Generally speaking Urban does not wish to issue such letters.

Lester - Third letter.doc

XX Savings Bank acknowledges that it can have a Phase I ESA performed inaccordance with its own preferences and requirements , but has elected not to.

No other representation, expressed or implied, and no waranty or guarantee that anyreliance by XX Savings Bank on Urban s report will diminish or reduce futureliabilities or provide suitable due diligence for any future uses , sales , or investments isincluded or intended in this letter or in our report.

Very truly yours

URAN ENGINERS , INC.

Thomas G. May, PEVice President

Attachments:

e Lester - Third letter. doc

Thefollowing two templates are from ASFE...

... ...

( Date)(Name of Third-Part Representative)( Third-Par' s Full and Formal Name)( Third-Par' s Address)

Re: Agreement Concerning Release of ReportReport Number ( Report Number)

Dear (Name of Third-Par Representative):

The attached report was prepared pursuant to a specific scope of service and wrttencontract between (Name of Client) and (Name of Firm), dated (Date of Contract). (Name of Client) has given us written permssion to release the report to you. You mayrely on this report as though it were addressed to you at the time of issuance, with theexpress understanding that (Name of Firm ) shall not be responsible for problems arisingfrom events or changes that may have occurred subsequent to our preparation of saidreport.

This reliance letter is expressly contingent upon your acceptance of the general conditionsattached hereto and actual payment of $( amount) consideration. Your payment shall alsoindicate your acceptance of the attached general conditions which include a provisionlimiting consultant's liability to ( dollar amount in the aggregate , whether such liabilityarises in breach of contract or warranty, tort (including negligence), strict or statutoryliability, or any other cause of action, to the maximum extent permitted by law). Thisreliance letter shall be void in the event said consideration is not received within (14days) of the above date.Sincerely,

(Name of Firm)(Name of Firm Representative)( Representative s Title)

Attachments: Report

General Conditions

ster - Third letter. doc

( Date)(Name of Client Representative)(Client's Full and Formal Name)( Client's Address)

RE: Release of Report Number (Number) to (Name of Third-Part)

Dear (Name of Client Representative):

As you know, (Name of Firm) prepared the above-referenced report for your firm s solebenefit and use. Your firm has requested us to release a copy of that report to (Name ofThird-Part) so (Name of Third-Part) may rely on it to the same extent as your firm. Wewill oblige that request once you sign below on behalf of your firm to authorize therelease of the report, and to consent to the reliance letter fee in the amount of $( amount Please fax a signed copy of this letter to our office immediately.Sincerely,

(Name of Firm )(Name of Firm Representative)( Representative s Title)

Authorized on behalf of ( Name of Client) Date

Printed Name of Signatory

Signatory s Title

ster - Drummed Cuttin s.doc Pa e

Lesson Learned -- Drummed Boring Cuttings

We learned this lesson on a recent Home Depot job in York.

The driller insisted on drumming all cuttings trom the borings he was drilling, eventhough most of the cuttings appeared to be from clean soil. When the job was done thedriller left the drums on site, since their contract said they were not responsible fordisposal of drummed cuttings.

Once the cuttings were placed in the drums , the burden of proof that the material is cleanrests with the drum owner, which requires sampling and lab testing (a significant cost). better approach is to monitor cuttings as they are being generated, and dispose of them onsite, as long as they are clean.

How do you know if the cuttings are clean? By sight, smell, and, ifin doubt, a Pil.Only if there is a suspicion that the cuttings are contaminated should they be drummed.

An additional point: if the cuttings are contaminated trom a petroleum-based productthey are most likely non-hazardous , since petroleum products are not included underRCRA. The only caveat here is that the cuttings cannot exhibit one of the characteristicsofhaz waste (flammability, explosivity, corrosively, etc.). In most cases , such a wastecan be disposed of as residual waste, not hazardous.

a. URBAn.

Form No. Form Name Revision Rev Owner PageNo. Date: Count

404- 1 F1 Project Close-Out Check List 4/25/00 Executive VP 2 of 2


Project: 76 Schuvlkill Expresswav and Lackawanna Vallev Industrial Hie:hwav Urban Project No. 8425 and 9318

Prepared by: Joseph P. McAtee

List all Lessons Learned topics. Use key words only.

Temporarv Crossovers

Maintenance of Traffic

Individuals with experience on this topic: Al Alberts , Burt Kohlman, Leo Leonetti , Joe McAteeBrian Stover, Jeff Wendel

Describe Lessons Learned for each key work topic. Use additional pages asrequired.

Client: PennDOT

Nan-ative: On rehabilitation projects where bituminous overlays are used, there are oftenrequirements on limited access highways to furnsh crossovers at the limits of a project. Thereare also periodic needs to furnish a crossover in areas of entrance and exit ramps. In these casesthe designed must give thought to how he will tie the new paving to the existing paving. It hasbeen observed, in some cases , that the staging drawings simply show the crossovers where theyare to occur. This is done sometimes without thought of how the contractor is to accomplish thegrade difference between the new overlay and the existing pavement. Should the temporarycrossover be in the area of a super elevation buildup, the difference a contractor may have to dealwith may be up to 12" or more. This is sometimes not clearly foreseeable by the bidders , and itis also a situation where there are sometimes not bid items provided for the varable depth ofbuildup required for temporary paving.

Original to Project NotebookCopy to Corporate Development

ster - ASBST XLS

Preliminarv Cost Estimate for Asbest( sAb1 tementUrban Proiect #sbestos Abatement ofAME OF SITEOWN, STATE

12/18/98

Vinyl Asbestos Pipe Spray On Cementitious Plaster Wall GeneralUnit Transite Panels Roof Removal Boiler Insulation ContractFloor Tile Insulaton Fireproofing Material Removal

Items

Is. 134000. 100. 134000.

Baas 2680. 2 680.16750. 50. 33500.

620. 1 240.

Line Classification Unit Unit Price Price Price Price Price Price Price PriceNumber Pricenemolition in Asbestos Contaminated Area

R30-0250 ransite Panels IGvnsum Board' $1.B30-0410 Parttion Demolition nlaster lath studs

Bulk Asbestos Removal840-0200 Boiler Insulation $7.840-0610 14" to 8" diameter DiDe $4. $0.840-2100 i!crane Foam Firenroofina from irreaular surface $2. $275.840-3000 Remove cemetitious material from flat surface $4. $0.M0-500 Remove VAT from Floor bv hand 218 420.840-0000 Remove Mastic - Chemical Strinnina $134000.26-4000 Ishinales. asahalt Stria $0. $61640.

Waste Handlino. Packaalna. & DlsDosalR!iO-001 0 ol/ect and Ban Material 13 C. F. baas) $10. $28408.00 $0. $21. $0. 28 408. $0. $0.RS0-2000 ontainerize banned material in drums nPr ban $7. $20743. $0. $15. $0. 20 743. $0.850-3000 art bans 50' to dumaster $2.850-5000 bisoosal Charaes averaae 1$80-$180\ $100. $62037. $0. $185. $0. $0. $12407407 $0.

becontaminatlon and Clean-60-0100 i!nra exnnsed substrate with surfctant (bridain 60-0200 lat Surfces $1. $102. $0. $0.60-0300 PinPs Beams and Columns $0. $0.

General Proiect itemsMobilzation 500.hffce & Storaae Trailers 500.heconlShower $500.

emnnrarv Utiitiesleaninn/Decon $500.otal: 463 608. $0. $598. $0. $0. 234 865. 2 000.

SUB-TOTAL $701.072.

Preliminan Cost Estimate based on "Means Renair & Rem delina ost Data" 16th Annual E ition 199.lbows and Valves assumed to have a lenath of 1 L.F.

Y: fur

1.,,,,,,Lcrdfillng

IsiIAP'rf( OO

F art 61,::u part M)

NOTE: C( nfirmed bv contrctor on 10-27-98, cost ffloor tile rem( val, outside f Philadel phia is about $1 50/SF and Masti about $1.00/S F.Dis". sal charnes confirmed 9-98 to be $80 to 180/Cf( deDen ina on auan itv and ha lJl distance.

e Lester - Blue Marsh LlMS. DOC

URBAn.

Urban Engineers, Inc.530 Walnut Street, 14th FloorPhiladelphia, P A 19106(215) 922-8080 Fax:(215)922-8082E-mail: tgmay(gurban-hq. com

August 11 , 1999To: Environmental Dept. Staff

From: Thomas G. May

Subject: Electronic Data from Blue Marsh

We now have the ability to get electronic data from Blue Marsh, which should allow us to savere-typing it and reduce transcription errors.

According to Laura at the lab , you must note on the chain of custody form that you want anExcel spreadsheet of the LIMS data e-mailed to you (indicate your e-mail address).

The spreadsheet you receive will have a lot of unwanted columns , but you can easily delete whatyou don t want. The attached sheet indicates procedures for manipulating the data in Excel.

These procedures are being added to our Lessons Learned directory (t/lessn Ie.arlue Marsh LIMS).Feel free to add and update the information as we gain more experience with the LIMS/Excelinterface.

Steve Lester - Blue Marsh LlMS. DOC Pa e 2

Steps for Importing LIMS Data into Excel

Save the LlMS spreadsheet when Blue Marsh e-mails it to you, then open up in Excel (or, simply right click on theattachment icon in the e-mail and select Open from the pop-up menu).

Select columns from LlMS spreadsheet desired in your spreadsheet (the ones in gray below are likely candidates).Select columns by clicking on columns desired by holding down the Control key.

Paste selection into a new spreadsheet.

Sort data as desired (click on Data/Sort .. .). For example, organize data by Test Name (e. , Lead , pH , and TOC) byspecifying the following sort order: Sort by - Test Name; Then by - Sample 10. Other sorts are possible, suchas, for each sample point , list all test results (sort by Sample 10 , then by Test Name).

You can add additional columns (ex: Act 2 Standards) in Excel or you may prefer to move the table into Word to doso.

Use Excel to plot data. This may require going through the following procedure to eliminate an apparent lock onnumeric values that prevent proper graphing in Excel (this glitch may be caused by Blue Marsh's use of anotherversion of Excel). First, copy the entire spreadsheet, then paste it into a new Word document. Next, copy theWord table you just created , then paste it into a new Excel spreadsheet. This procedure destroys formatting butallows the data to now be plotted.

Column Headings in Blue Marsh's LIMS

Column HeadingNumber

LlMS#Lab#SortNumGrou pSortNoTestGrouplDSortNoSamplelDLogDateLOQTimeLogBySampleTypeSourceTestGroupNameTestlDTestNameReportedResultUnitsSelectedforReportingSubmitterLabSectionAnalysisDateAnalyzedByNoteProiect#Client Proiect#TurnAround

Column HeadingNumber

Due DateCollect DateCollect TimeCollect ByReportDatePrep MethodPrep DatePrep ByAnal MethodHold DaysHold DateMOLCalc MOLFlagNameDeptAddress 1

Address2CityStateZipContactPhoneExtFAXProvidenceReceived Date

r - SLUG TEST PROCEDURES.doc Pa e

SLUG TEST PROCEDURES

This "Lessons Learned" describes methods and templates for conducting a slug test andcalculating hydraulic conductivity.

Procedures for Conducting Slug Test

EP A has developed a good description of the procedures to use when conducting a slugtest. The protocol can be found at: http://ww.ertresponse.com/sops/2046.pdf.

A record keeping form for recording groundwater elevations can be found at thefollowing web site: http://er.roiect.lanl.gov/CommoniProcedures/Forms/SOP-07.03%20Slug%20Test%20Data.doc .

Angelo Waters has developed an alternative Excel-based form that can be used to recordfield measurements and will automatically calculate hydraulic conductivity (seet:/Forms/Field Forms/slug test calc template.xls).

Please note that it is very important to have a quality electronic water probe to measurethe change in water level over time. Our curent probe is not ideal. There is also alearning curve involved. Depending on the soil conditions, the water level can changerapidly making it difficult to take measurements in short intervals.

Plan on using two field staff over 8 hours to perform a slug test. P ADEP usually issatisfied with conducting slug tests on only a couple of a site s wells , but to get a morereliable hydraulic conductivity, slug tests should be performed on as many wells aspossible.

Calculating Hydraulic Conductivity

The simplest interpretation of piezometer recovery is that ofHvorslev. The analysisassumes a homogenous , isotropic medium in which soil and water are incompressible.Hvorslev s expression for hydraulic conductivity (K) is:

K = r ln(L/R)2LTo

K can be calculated easily using the Slug Test.xls spreadsheet. Once the gray cells arefilled in, the hydraulic conductivity of the well is computed.

G. May, 51702

floor tile containin asbestos. doc

HOW SHOULD ROOFING MATERIAL AND FLOOR TILECONTAINING ASBESTOS BE HANDLED IN A DEMOLITION PROJECT?

This document sumarizes how non-friable asbestos materials such as roofing material and floor tileshould be handled during a demolition project. The regulatory standards to be observed wil differdepending on whether the project is located in or outside of the City of Philadelphia. The City hasespecially strngent requirements for handling roofing material and floor tile that are not generallyrequired in other parts of the countr. Accordingly, demolition costs in the City will be higher due toincreased costs for managing asbestos.

Section 1.0 of this document sumarizes the general practice followed outside the City; Section 2.addresses City requirements. Some local jurisdictions (e. , Allegheny County, New York City) havetheir own specific regulations that must be followed. If your project is located in one of thesejurisdictions, you should determe the specific requirements by contacting the appropriate regulatoryentity within the jursdiction.

0 Demolition Projects Outside Philadelphia

Category I non-frable ACM includes resilient floor covering and asphalt roofmg product that containmore than 1 % asbestos. Category I non-frable ACM must be inspected and tested for friability if it is inpoor condition! before demolition to determne whether or not it is subject to the Asbestos NESHA.Asbestos-containing resilent floor coverings and asphalt roofing materials must be removed beforedemolition only if they are in poor condition and are friable. (Source: EP A -ht1:/ /www.epa. gov/region4/air/asbestos/asbmat1.htm

In addition, according to EPA (htq://ww.eDa.gov/region04/air/asbestos/demolish.htm itis difficult to

make non-friable Category I material friable during demolition:

The use of cranes during the razing process does not cause Category I non-frable ACM to becomeRegulated ACM (RACM); therefore, Category I materials which are not in poor condition and notfrable may remain in the building during such demolition.

The razing ofa building using heavy machinery does not cause Category I non-friable ACM to becomeRACM.

Normal implosion techniques do not cause non-friable materials to become RACM. The asbestosNESHA does not require the removal of Category I non-frable ACM that is not in poor conditionand not friable prior to building implosions.

Regarding landflling of demolition waste containing ACM roofmg, a specific reference forPennsylvania landfills could not be found, but in Colorado, demolition debris containig non-friableroofmg materiaVVinyl asbestos tile can be disposed of as a non-asbestos containing waste.htt:/ /www.cdDhe.state.co.us/ap/ downaspolicv .PDF

In Massachusetts, the same applies. htt://www.state.ma.us/dep/bwp/asbestos/96-012.htm

Also , EP A states that "if the asbestos-containing roofing material is not in poor condition and is notfriable. . .. , it may be disposed of in a landfill which accepts ordinary demolition waste.

I "Friability" and "poor condition" are key definitions that must be answered during the asbestos survey. "Friable" material canbe crumbled, pulveried, or reduced to powder by hand pressure. Answers to the following questions will help define if thematerial is in "poor condition : Is the binding of the ACM losing its integrty? Is the ACM peeling, cracking, or crumbling?

e Lester - Roofin floor tile containin asbestos. doc Pa e

http://www.epa.gov/region04/air/asbestos/demolish.htm

Accordingly, it is likely that a Pennsylvania-permtted landfill can take demolition debris that containsnon-friable roofingN AT, as long as it remains non-friable. Some landfills may opt not to take it, eventhough they could (e. htt://iyp.uswestdex.comirecoveryllPage4.html

Bottom line: As a general rule, ACM roofingN AT that are not in poor condition and frable can be:

Left in place prior to demolition

Remain mixed with the other building debris after demolition

Disposed of in landflls that accept ordinary demolition waste

0 Demolition Project Within the City of Philadelphia

Urban s Mike Dostillo spoke with Jerr Junod (215685-9082) of the City of Philadelphia on March 142002 regarding asbestos roofmg and floor tile. Here is a summary of the conversation:

1 Asbestos Roofing Material

Reroofing:

If a roof is to be removed and replaced with a new roof, and the roof is removed by non-mechanicalmeans (by hand methods, such as an axe), the roof may be removed by a licensed roofmg contractor (isnot required to be an asbestos contractor). The roofmg may be disposed of at a landfill which permtted to accept non frable Category I asbestos waste (most landfill can accept this waste - thelandfll must be made aware that the material is an asbestos containing material so it does not render thematerial frable though recycling, etc.

Based on the size of the roof, the contractor may want to speed up the process by using a roof saw orequivalent. If the roof is greater that 2 790 square feet, and a roof saw is to be used, the project must betreated as a major asbestos abatement project. If it is less than 2 790 feet, it can be treated as a minorasbestos abatement project. Either way, the sawing portion of the project is regulated, the City ofPhiladelphia Asbestos Control Regulations must be followed, and the sawing must be completed by alicensed asbestos abatement contractor under appropriate provisions listed under the City asbestoscontrol regulations. The asbestos abatement portion of the project only involves the saw cuttg. Oncethe saw cuts are made, the roofing may be removed by a licensed roofmg contractor (does not have to belicensed asbestos contractor) if the material is not rendered friable (manual means are used). Thematerial must be disposed of at a landfll that is permtted to accept non-frable Category I asbestoswaste.

Demolition:

If the roof is removed prior to demolition, the rules regarding reroofmg apply. The remaining demolitiondebris (non-asbestos) may then be recycled or used as fill if applicable, or disposed as normalconstrction waste.

If the building is demolished with the roof material in place, the roofing material must be segregatedafter demolition and disposed of at a landfill which is permtted to accept non friable Category I asbestoswaste. Typically, a City of Philadelphia Asbestos Investigator is on-site during segregation of thematerial to ensure the roofing is disposed properly. If roof framing or other components are attached to

ve Lester - Roofin floor tile containin asbestos. doc

the roofing material, the roofmg material and constrction material associated with the roofing can notbe recycled or used as fill - it must be disposed at a landfill permtted to accept non friable Category Iasbestos waste.

Regarding costs for demolishing a building with the roof material in place vs. abating the roof anddemolishing the building: Jerr believed that under certain circumstances, an argument could be madefor either method. Contractors must weigh the benefit of recycling certain materials or using material asfill. If money can be made in either area, roof removal would be the preferred method. However, eachsituation must be evaluated on a case by case basis , tyically by a contractor, to determne whether it iscost effective to remove the roofing material prior to demolition or leave it intact.

2 Asbestos Containing Floor Tile

When dealing with asbestos floor tile in the City, the City of Philadelphia Air Management Servicesenforces the NESHAP (federal) regulations. It does, however, enforce its interpretation of the NESHAPregulation.

Building Renovation

As part of a renovation project, any asbestos floor tile removal must adhere to the City of PhiladelphiaAsbestos Control Regulations. Floor tile removal is considered a regulated project requirng certifiedasbestos abatement contractors and air monitoring services. The quantity of material to be abated wildictate the procedures to be followed.

Building Demolition

According to the federal NESHA, asbestos containing floor tile may be left in place durig demolitionas log as it does not become friable. The City Air Management Services determes friability and arevery strct with the interpretation of the term. If you choose to demolish a building with asbestos floortile left in place, the City wil follow the project though and if they determne that any floor tile has beenrendered frable (tiles breaking up), they will stop the job and require the floor tile to be properly abatedas per the City regulations. In addition, after demolition, floor tile must be treated similar to roofmgmaterial. It must be segregated from other wastes and disposed of at a facility permtted to acceptCategory I non-frable asbestos waste. It must not be used as fill or recycled in any way.

Jerr indicated that the NESHAP allows floor tile to be left in place during implosions. He added that hewould never approve this within the City limts.

Interpretation: Working with non-friable asbestos containing materials within the City of Philadelphiayou must tread cautiously. Rendering a material friable is subject to interpretation by the City AirManagement Services. The best way to approach a demolition project involving asbestos floor tile orroofing material is to get the City Air Management Services involved from the start, getting theirapproval if you wish to leave this Category I material in place. The more involved you get AMS, themore willng it wil be to help/cooperate. Get a clear definition on what AMS feels would render thematerial in question "friable . AMS staff will visit the site and inspect the demolition. If the material isnot being treated as originally agreed, AMS will hand out fines.

a. URBAn.




Project: 76 Schuvlkill Expresswav. 1-676 Vine Street Expresswav Urban Project No. 8425 and 8638



Record Drawings

As-Built Infonnation

Existing Conditions

Individuals with experience on this topic: Tom Kerins , Leo Leonetti , Joe McAtee , BrianStover, Jeff Wendel


Client: PennDOT

Narative: When developing a design, very limited reliance should be made upon any fonn ofowner information related to as-built drawings or record drawings if the new design is to tie in toexisting facilities or conditions. The designer should field verify such conditions prior to thecompletion of design. An alternative to this would be to specify a requirement that thecontractor verify field conditions for accuracy prior to constructing new work which will tie toexisting. Also , if this alternate is used, it should be a requirement that the contractor perform thiswork and furnish necessary survey data to the engineer a specified number of days in advance offollow-on activities , prepared by a licensed surveyor, to avoid project delays. The projects thisissue have been associated with are various international airport projects , 1-76 SchuylkillExpressway, 1-676 Vine Street.


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Project: 76 Schuvlkill Expresswav and Lackawanna Vallev Industrial HiehwavUrban Project No. 8425 and 9318



Super Elevation. asymmetrical concrete barrer

Individuals with experience on this topic: Tom Kerins , Joe McAtee, Al Pizzi , Brian StoverJeff Wendel


Client: PennDOT

Narrative: On rehabilitation work, very often super elevation rates are increased above thosewhich were established when the original road was constructed. This sometimes results inhigher elevation differences in the median areas making the normal concrete barer shapedifficult to use if maintaining the minimum/maximum reveal at the gutter lines. Often thisrequires an asymmetrical barrer to be established. While this is possible to construct, cost issuesmust be considered as well as construction phase productivity issues as they relate to theschedule. Often slip form operations for concrete barrer are difficult with the asymmetricalshapes. Further this type of barrer and the increased super elevation buildup often requirespecial detailing for resetting inlet castings located in the median areas. Details of inlet structureshould be provided in the design drawings to avoid difficulties during construction determningthe appropriate structural method to reset the inlet castings.


a. URBAn.




Project: 76 Schuvlkill Expresswav Urban Project No. 8425



Public Information Systems , Telephone Hotline, Information BrochuresDocumentary Film, Mailing List, Press Conferences

Individuals with experience on this topic: Al Alberts , Joe McAtee, Brian Stover, Jeff Wendel


Client: PennDOT

Narative: The 1-76 Schuylkill Expressway CM program was the first to utilize a CM consultantto provide public information system strategies during construction which are identified in thenoted key words. The strategies were as follows:

Public Information Systems: PennDOT had organized a community task force of variousstakeholders related to the communities throughout the 21-mile expressway corrdor. Routinemeetings were held during the design phase and continued during the construction phase. TheCM was tasked with developing a mailing list and using a mailing subconsultant to providenewsletters and updates regarding the program throughout the course of construction. Inaddition to the mailing list, the CM assisted in the organization of press conferences forPennDOT. This organization assistance included the issuance of various newsletters andannouncements through the mailing list consultant together with arranging for handout materialsin coordination with PennDOT. A special sub was also used to provide a "multi-box" devicewhich was used by the various news agencies to plug in their microphones during the speakersannouncements. Information brochures were prepared by a graphics subconsultant retained bythe CM and developed in coordination with the PennDOT Press Secretary. These brochureswere issued during the six-year course of this project, and involved the printing of approximatelyone and one-half million brochures for the various stages of the work. Contracting of thebrochure production as well as distribution of the brochures on a wide basis was performed bythe CM working in conjunction with PennDOT' s guidance.

The CM team subcontracted the operation; of the telephone hotline. This hotline was manned byten operators at its maximum use period, and handled up to 2000 calls per day. The hotline wasin place from 1985 to 1988. The CM worked with a minority subconsultant who was awardedthe hotline contract and arranged for the procurement of all hotline telephone hardware, operatorselection and training operations together with monitoring the performance of the telephoneoperators service during the course of expressway construction. Hotline operators handled callsfrom the public or route information, data related to traffic restrictions , together with mailing outbrochures and PennDOT maps when requested by callers. The service was provided eight to tenhours per day, sometimes six days per week with answering machines operational in off-peakhours.

The operation was conducted in a temporary trailer with all necessary costs to be billed as adirect cost to the minority goals of the contract and procured by the minority subconsultant.Importantly, as a non-professional service, this service was bid and awarded to the low bidderthus saving the Deparment the burden of a professional consultant' s FAR overhead burden on aper hour cost basis.

A docum ntary film was required by PennDOT and was procured under the CM contract. TheCM team competitively selected a film production company and ultimately prepared a 20 minutedocumentary of the expressway design and construction process for public utilization. Alsoprovided were 20 second public service announcements (PSA' s) on audio tape for radio stationuse and video tape for television use. These PSA' s were used prior to each major traffic switchto encourage expressway users to use alternate means of transportation and seek alternate routes.Copies of these are available in Urban s files.


a. URBAn.



lessons learned Input

Project: 76 Schuvlkill Exuresswav and 1-676 Vine Street Exuresswav Urban Project No. 8425 and 8638

Prepared by: Joseuh P. McAtee Client: PENNOT


Congestion Management

Work Zone MPT Strategies

Individuals with experience on this topic: Al Alberts , Joe McAtee , Brian Stover, Jeff Wendel


Narative: Both projects utilized a contract requirement for an "expressway service vehicle" andtowing" pay items. These items involved the provision of an expressway service vehicle purely

dedicated to assisting the public as they passed through the work zone. A special specificationwas developed, using a general model developed after discussions with illinois DOT, based ontheir successful use of this general strategy on the Dan Ryan Expressway in the mid-80' s. Theexpressway service vehicle was available and on-site with a driver 24 hours per day during thecourse of traffic restrictions.

The towing pay items were specified for two classes of tow trucks , one for passenger cars andvans , and the other for heavier trucks. There was much activity on many sections of the 1-projects using towing pay items with a diminished amount of activity on 1-676.

Both of these items were recognized as being "state of the art" traffic congestion managementstrategies in the work zone when they were implemented from 1985 through 1991. Howeverwhile they were highly favored in the design/development phase, and recognized as goodinitiatives , the towing pay items were somewhat problematic during construction. Controlling ofthe tow pay items for authenticity was difficult due to the 24 hour per day performancerequirement, together with competition from independent tow drivers. This led to some disputeswith the public, who expected that all tows would be free and at the expense of the DOT. Thiswas the intention of the towing pay items , but clearly was not the intention of the independenttow truck drivers. The emergency service vehicle generally worked well witho\lt constructiondifficulties.

Pictures of the Expressway service vehicle are available from Urban s archives.

URBA.


404- 1 F 1 Project Close-Out Check List 7/3/03 Executive VP 20f2


Project: Urban Project No.

Prepared by:

Jos ph P McAtee


Borrow material for earhwork operations

Regarding highways and other site work projects

Describe Lessons Learned for each key work topic. Use additional pages as required.

When a project is designed which requires earthwork operations, the designer must detennnewhether there is sufficient excavated material on site for any required embankment activities. there is not, then borrow material is typically required as an item or covered as a statement if theproject is a lump-sum project. Care should be given on projects where there is a need for borrowmaterial when there is any amount of construction phasing required. Often, due to the constructionphasing, material which would normally be available from excavation may not be available at thetime needed by the contractor for the construction of embankents. This often results in a claim foradditional compensation. This claim situation can be avoided by either providing guidance in theform of the specifications of the contractor as to how he is to proceed, or by providing an item foraddition borrow material due to the lack of available material in the phases required.

Individuals having knowledge of this: . Kerin , Leo Leonetti, Joe McAtee,Erian Stover, Jeff Wendel

Original to Project NotebookCopy to Knowledge Urban

- 08/1112004

URBA.


404-1 F1 Project Close-Out Check List 7/3/03 Executive VP 2of2



Prepared by:

Toseph P McAtee


Issue: Review of sub consultants design work


When work is performed by a subconsultant for design of any type of facility as a sub to UrbanEngineers , it is imperative that that work be reviewed by the Urban Project Manager periodically.Should that PM determne that he is not a suitable reviewer based on the type of design that is beingperfonned, he must obtain a suitable reviewer to assure that the sub' s design is proceeding in amanner that is in general conformance with engineering practice. In some cases , this may meanretaining an additional sub for designs which may be of such specialty that they are typically notperfonned by Urban.

Projects Related to this Issue: Fort Washington Parking Lot Design, performed under the SEPTAGEC in 2001 , Blue Route , Section 300 roadway design, specifically dealing with large reinforcedconcrete pipe facilities.

People having knowledge of this issue: Joseph McAtee, Jim Charles, Jeff May, Drew Scott, JeffWendel

Original to Project NotebookCopy to Knowledge (f Urban

08/11/2004

a. -1:;URBAn.







Erosion Control

Pump Stations

Special Fabrication Items

Staff with Knowledge of Lesson: Tom Kerins , Jeff Wendel , Rick Kreck, Joe McAtee


Lesson A: The coordination of erosion, sedimentation control plans with construction staging

Narrative: Many times designers developing a project's drainage system incorporate stormwater management basins into the design. It is sometimes presumed that these basins may serveas erosion and sedimentation control features during the construction. However, constructionstaging sometimes makes this difficult, if not impossible, depending on the construction stagesand general topography. The lesson is to carefully consider the construction staging of a givenproject during the course of developing erosion and sedimentation control plans along withconstruction staging by consulting professionals who have had prior experience on projectswhere this had become a significant problem.

Lesson B: Contractual acceptance of a pump station facility

Staff with Knowledge of Lesson: Joe McAtee

Narative: Projects that include the construction of a pump station must closely address whetheror not the pump station may be used during construction or whether it must be preservedwithout use, until the project is finally accepted. This has to do with initiation of the waranty,together with whether or not the contractor can rely on the pump station to function during theconstruction period, or whether he has to provide additional temporary pumping at his ownexpense. Failure to clarify this point often leads to claims and disputes.

Lesson C: Recognizing Long-Lead Procurement Issues

Staff with Knowledge of Lesson: Brian Stover, Leo Leonetti , Joe McAtee

Narative: Two of Urban s projects have had situations arise where the designer specified itemswith exceptionally long lead times for fabrication and delivery. One was the University CityRail Station , Job 9316 , in which the architect specified a special fiberglass enclosure which wasmade only by limited amount of vendors and required more time or delivery than the scheduleallowed. The other project was the Vine Expressway which required the construction of a 20inch water main which was found to have a pipe thickness that could be manufactured by onlyone shop in the country. When that show went on strike , the entire project was adverselyaffected. This lesson deals with advance investigation by the design team or their CM to assessthe availability of key elements of a project to assure schedule delays are not encountered duringconstruction.


URBAn.


404- 1 F 1 Project Close-Out Check List 7/3/03 Executive VP 2 of2



Prepared by:

Tos :rh P McAtee


key word: Piles , Pile load tests

Project Generic projects requiring a significant number of piles to be installed

People having this knowledge: Joe McAtee , Burt Kohlman, Al Alberts , Jeff Wendel


Narative: On projects where high numbers of piles are to be installed below a structureconsideration must be given to the time at which a pile load test is performed. On projects wherethe pile installation is not critical to the schedule, and the ultimate length of the piles to be used willnot be materially affected by the results of the tests, it may be acceptable to conduct a test duringthe construction phase, as is typically the case.

However, on projects where the length of the pile is difficult to ascertain and changes in theestimated pile length may materially require a significant change in the length of piles used alongwith related cost changes, consideration should be given to conducting the tests during the designphase. Further, should the project be a fast- track project with a progressive schedule with the pilesfalling on or near the critical path, the tests should be performed in the design phase to limit anychance that changes in pile length or any other aspect of the pile installation results in eitheradditional costs or critical project delays.

Original to Project NotebookCopy to Knowledge

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Urban08/11/2004

It is noted that performng a pile load test in the design phase is unusual in the market as of theyear 2000; however, it may be prudent to perform such tests then for the reasons noted above. is also very important, from a consultant's viewpoint , if information obtained from a pile loadtest could materially change the cost for the schedule of a project that consideration be given toperformng it in the design phase. From a risk-sharing viewpoint, a discussion along these linesshould be held with the client and the consultant should make a firm recommendation to performsuch tests in the design phase to limit the client's potential for delays and costs as well as theconsultant's. It has been observed that, on previous projects , clients have required consultants topay for additional costs related to changes in pile installation which were not fully foreseeableduring the design phase. It has been found that had pile load tests been run on at least one majorproject. the firm potentially could have saved well over $100 000 in which resulted in an ownerclaim that failure to see the actual pile conditions resulted in additional costs to the contractwhich they held the consultant responsible for. At the decision to conduct a pile load test in thedesign phase been proposed and conducted, it is possible the additional costs wouldll not havematerialized, but would have been properly budgeted for. Further, had the decision to conduct apile load test during the design phase been rejected by the client, the consultant' s position wouldhave been strengthened by the fact that the client did not go along with their recommendation tofurther identify potential pile insulation conditions that ultimately materialized.

As a matter of information , Urban has conducted a pile load test during the design phase of theSchuylkill Expressway, 1- , Section 420 construction. This involved Urban s preparing a bidpackage to conduct two pile load tests in the Vine Interchange with 1-76. The bid package wasadvertised by Urban , with Urban running the advertisement, conducting the pre-bid meeting,receiving and opening bids in Urban s offices , with PennDOT approval. The work was managedunder the 1-76 CM contract, and paid for as a direct cost under the contract by PennDOT. Thetest was conducted in 1988 and performed by the successful low bidder, Terry Pile Company.The results of the test identified the pile section to be used in design together with a clear pictureof what the estimated pile tip would be for the H piles which were to be bearng piles togetherwith important hammer information, which was all used by the design team in preparng thespecifications. Conducting this test basically limited any chance that the contractor wouldencounter delays in either the ordering or the installation of the piles for a large pile-supportedslab , requiring over 2000 piles to be installed close to the critical path of this Expressway projectwhich had an incentive/disincentive clause of $30 000 per day without a cap. The design phaseinformation regarding the piles allowed the contractor to place a very early order for pilematerials and deliver them to the site rapidly. Ultimately, the contractor, who was lA/BuckleyJoint Venture , finished the overall project early and won a large incentive reward.

URBA.


404-1 F1 Project Close-Out Check List 7/3/03 Executive VP 2of2



Prepared by:

Jos ph P McAtee


Key word Existing electrical ducts

People having this knowledge: Joe McAtee, Brian Stover, Jeff Wendel , Leo Leonetti, Al AlbertsJack Henderson

All infrastructure projects using existing electrical ducts


Many times on infrastructure projects , designers require new power and/or communication cables toreplace existing electrical ducts below city streets , parking areas, etc. Prior to requiring this in thedesign, the designer must confirm that it is permissible to do so by obtaining permission from theowner of the duct bank. Also , the designer should verify with the owner of the duct bank whichducts may be used for the new cable facilities.

The designer must also be aware that there is no guarantee that spare ducts are clear of obstructions.Very often, at the time of installation of power or communication wire , obstructions areencountered. Sometimes these obstructions are significant and require a significant amount ofclearing with a mandrill or other special device, and sometimes , it involves street excavation toascertain what is causing the blockage. Typically, when blockages are encountered in constructionit involves a change order to the contract resulting in additional costs , together with potential delays.Depending on the criticality of the cable installation, it may be prudent to verify that ducts are clear


08/1112004

Regarding the issues of blockages in ducts , it would be useful for the designers to consult withthe client prior to construction , advising him of the risks of using existing duct banks which maynot have been verified as being clear. This information is important to the owner so that heunderstands that there is an element of risk in the installation of cables which may result inadditional costs due to the unforeseen nature of the situation. Also , at that time, the owner mayelect to request the utility company to verify that the spare ducts are clear, thus identifying thistype of problem prior to construction when it can be corrected without project delays.

URBA.


404-1 F1 Project Close-Out Check List 7/3/03 Executive VP 20f2



Prepared by:

Joseph P McAtee


Key words Shop Drawings

Generic - All projects requiring shop drawings

Individuals with experience on this topic: Tom Kerins, Joe McAtee, Brian Stover,Jeff Wendel

2. Describe Lessons Learned for each key work topic. Use additional pages as required.

Turnaround time on shop drawings should be clearly stated in the specifications. Designers shouldbe aware that contractors use delays in shop drawing turnaround to their advantage when seeking toprove entitlement for delay costs or, simply overruns , sometimes related to the contractormanagement. Owners , owners ' dispute review commttees , and courts have generally sympathizedwith contractors who can present a case that indicates that design turnaround times have beenexcessive and potentially have delayed contractors ' performance. Accordingly, it is important thatthe designers maintain a shop drawing log during the design phase, or collaborate with a contractoron the shop drawing log and be well aware that continued delays in turnaround time may result inliability to the designer in the form of owners ' requesting the consultants to pay any related delaycosts as a professional liability issue.


08/1112004

On fast track projects, and possibly other projects that are not fast tract, consideration should begiven to specifying that the contractors transmit the shop drawings directly to the reviewing partywith a copy of the transmittal to the resident engineer and any other party that has a need toknow. Also, the resident engineer may also have a need for a copy of the shop drawings just forgeneral review purposes. However, to streamline the turnaround of a shop drawing, it isimportant that it get into the hands of the reviewer rapidly. The system used on all thirteenSchuylkill Expressway projects comprising over $180 million worth of construction work, wasto specify a seven-day turnaround on critical path shop drawings, with the contractor transmittingthem directly to the designer, with necessary coordination copies to the CM. Shop drawingspecification also required that the contractor submit his schedule of proposed submissions at thepre-construction conference together with an indication of which submissions were to be treatedon a priority basis and affected the critical path. All critical path submissions were dealt withwithin a seven day turnaround over the course of the six year project, with very few exceptions.Further, all submissions went directly to the designers during this period, with virtually noproblems arising. Another specification requirement that proved to be quite useful and cost-effective was to require the contractor to maintain a shop drawing log and review it at every jobmeeting, as well as distibute it to the CM, the designer, and the owner s staff. In managing theshop drawing log in this manner, only one individual prepared it, and others simply reviewed it.When this is not specified, it is not unusual to see the contractor have his own shop drawing log,with another one being kept by the resident engineer, and yet another one by the designer.

In summary, consider specifying the following:

The contractor must stagger his submissions to recognize limitations in the designer s workforce.

The contractor will maintain and distribute a shop drawing log to required parties on a weekly orbi-weekly basis.

State that shop drawings affecting the critical path will have a seven-day turnaround for review(all shop drawings could have this review if necessary or state that non-critical path submissionswill have a 14 or 21 day review.

Require direct submission of shop drawings to the reviewer, who is typically the design projectmanager, with necessary copies of transmittal slips to parties having a need to know status ofsubmissions.

URBA.


404- 1 F 1 Project Close-Out Check List 7/3/03 Executive VP 2of2


Project; Urban Project No.

Prepared by:

Toseph P McAtee


TopicExcavation , suitable and unsuitable

Individuals with experience on this topic: Tom Kerins , Joe McAtee, Drew Scot t,Jeff Wendel


It is important to develop specifications for excavation and embankent on a project which clearlyidentifies which on-site excavation materials will be suitable for embankment. Some agencies , suchas PENNDOT, have a broad range of acceptable materials which are suitable. Generally speaking,this agency allows almost all excavated materials that are not organic content to be deemed suitable.Other agencies are more restrictive in their classification of soils. The issue of suitability inexcavated materials is of significant importance on projects where on-site materials are relied uponto construct embankents on the project. Should this not be carefully reviewed by the engineer inthe design phase , it may result in a claim for borrow excavation , should there be an excess ofunsuitable material encountered which does not allow for the construction of on-siteembankments.

Original to Project NotebookCopy to Knowledge

(j

Urban08/11/2004

On these types ofprojects, it is common to consider introducing into the bid documents an itemfor additional excavation beyond the excavation limits required for the project in the case thesetypes of materials are encountered. This additional excavation item may include providing thenecessary material for back fill, depending on the earthwork balance on the project.

URBA.

Form No. Form Name Revision Rev Owner PageNo. Date: Cou nt

404-1 F1 Project Close-Out Check List 7/3/03 Executive VP 20f2



Prepared by:

Tos ph P McAtee


Topic(s)Borrow MaterialEmbankment ConstructionPhasing

Individuals with experience on this topic: Brian Stover, Leo Leonetti , Tom Kerins , Jeff Wendel,Joe McAtee


On projects where earth work operations are part of the construction program, it is important toascertain whether there will be an earth work balance , earth work will be wasted, or there will beadditional material needed to complete the embankments. When additional material is needed tocomplete the embankments , this is commonly known as borrow excavation in that it is excavated toanother source and brought to the project. On your price projects , it is important to analyze theearthwork balance and provide necessary unit price items to accommodate the need for any borrowthat may be required, as well as for on-site excavation. On projects where there are phasingrequirements , it is important to ascertain whether the on-site excavated materials will be available inthe phase where they will be needed to construct any embankments. In the event there may be aninability of the contractor to obtain access to excavated material for embankents , due to phasing, aspecial item of borrow excavation may be provided. This item is commonly termed "foreignborrow excavation." This allows a unit price to be identified in the bid documents which will allowa contractor to bring in foreign borrow material to complete embankments due to the inaccessibilityof materials on the job which will not be available until a future phase.


08/11/2004

a. .l:)URBAn.




Project: 76 Schuylkill Expresswav and Lackawanna Valley Industrial Hie:hwav Urban Project No. 8425 and 9318



Water Main Testing, Domestic and High Pressure, and Acceptance

Individuals with experience on this topic: Burt Kohlman, Brian Stover, Joe McAtee


Client: PennDOT

Narrative: When specifying acceptance criteria for water main facilities , it is important to be surethat the test criteria is reasonable and able to be performed and verified as specified. On theVine Expressway project, a high pressure water main was specified to be constructed and testedto 300 psi. The joints of the specified water main were not flanged mechanical joints , but a newtype of "mega-lug" joint, fabricated by U.S. Pipe.

It was found that the specified pressure for the pipe line could not be achieved by the mega-lugpipe joint design. It had to be modified in the field. This caused project delays , additional costsand allegations of design errors between PennDOT' s designers and the Philadelphia WaterDeparment. Ultimately, the pipe joints were accepted at a lower working pressure which wasfound to be well in excess of the operating pressure and acceptable to the Water Department.The lesson is that when new materials are subject to an old methodology, the testingrequirements are not necessarily transferable and should be verified between the designers andthe manufacturers.

ame of Site Lesson Learned.doc

Lesson Learned

Name of Site

Angelo issued the following e-mail on 9/4/02

Project names may seem trivial , but are in fact an important element of the P ADEPreview process. We recently submitted a report to PADEP under a particular address.Shortly after, the client informed us that the street address (project name) needed to bechanged. This seemingly simple task caused hours of report and appendix revisions aswell as several resubmissions.

I guess the moral is to clarify up-front (kick off meeting) the project name and inform theclient the importance of its consistency throughout the life of the project.

Angelo

Additional thoughts by TGM: Consider naming the site by its former user s name ratherthan a street address (street addresses in Philadelphia can sometimes be confusing; asingle property my be know by two or more addresses if it is a comer property).Example: "Celotex Site.

..............

tgm

ve Lester - Limitations of Geoma netic & GPR Surve s - 09 09 02.doc

Limitations of Geomagnetic / GPR Surveys

Prepared by Spencer Finch and Thorn May - 09/09/2002

Caveat: It is important to note that geomagnetic and ground-penetrating radar (GPR) surveys can befallible; the survey results should not be interpreted as conclusive proof that subsurface strctures do (or donot) exist at the site. In other words, some anomalies detected by the surveys may turn out to be nothing,while an UST might go undetected. This occurs because the surveys are tyically subjected tointerferences. Field interferences include surface debris and the presence of metal strctures such asfences, railroad tracks, junk and trash (e. , car wheels), and even parked vehicles. Subsurfaceinterferences include the presence of abandoned foundations, rebar within concrete, atyical geologicconditions , and subsurface voids. Developed urban areas are especially prone to interferences, bothbecause of the history of site use and because of the potential presence of significant electromagneticfields. Finally, the surveys tyically have a range of up to 8 or 10 feet below ground surface - deeperanomalies might go undetected.

ad in Groundwater total vs dissolved.doc Pa e

LESSON LEARNED

LEAD IN GROUNDWATER (Total vs. Dissolved)

Be aware that Act 2 standards for lead in groundwater are based on dissolved lead, nottotal lead. This may be critical when groundwater lead exceeds the Act 2 standard. It ispossible that total lead may exceed the standard while the dissolved lead would not. If nofiltering is done , the lab results will probably err in the side of caution since the total leadresults will also include the lead that has sorbed onto soil particles.

PADEP recommends that, when testing for lead, the groundwater sample be field-filteredwith a 40-micron filter. When that is not possible , the lab can do the filtering. NJDEPon the other hand, mandates that filtering of groundwater samples be done prior to testingfor lead.

Urban generally doesn t do filtering in P A (since it is only recommended). However, weshould perform filtering in P A (i. , asking the lab to do it) in cases where the lead levelsare close to the standard. In New Jersey, all groundwater samples should be filtered priorto lead testing.

Prepared by Thorn May based on information developed by Spencer Finch, Augut 28 2001

The following note was received subsequently in a August 28 2001 e-mail from Korin Giles:

Urban of Erie has made it standard practice to filter groundwater for lead analysis in PA since theinception of Act 2. This is not difficult at all. We use an " in-line" macropore filter which attaches tothe tubing used to obtain the sample from the well. Using peristaltic pressure, it is quite easy tofilter the sample right into the sample container as it is being obtained from the well. This methodis much easier than using filter paper.

Macropore filters can be obtained from any lab supply Company. Or you can get them direct fromSevern-Trent/QED Environmental Systems, Inc. headquartered in Ann Arbor, Mich. (QED haspatented the in- line macropore filter-- if you buy it from a middleman you usually wil pay more.

Filters are available in 0.45 micron , 1.0 micron and 5.0 micron. Sometimes if your sample is veryturbid, you must either filter the sample more than once; or, use a larger pore size. When doingthis remember that the final lab container wil be preserved with nitric acid...so you must first filterthe sample into an unpreserved (sterile) container and then re-filter the sample into the finalpreserved container. Your final sample should be perfectly clear.

Filters are cheaper when purchased in bulk from QED--costs start at about $13.00/per. QED canbe reached at 1 (800) 624-2026 or ask your lab supplier.

In general , sending unfilered samples to the lab and asking the lab to filter them can invalidateyour results as the unfiltered container wil not be preserved and the lead can plate out on thesides of the sampling container. *** If you do use this method and wish the lab to filter your sampleremember to use a (sterile) plastic container as glass will cause the metal to plate out much morerapidly.

ster - Calculation of# of Sam les er Soil Volume - 02 06 2002.xls

CALCULATE THE # OF SOIL SAMPLES NEEDED FOR CHARACTERIZATION

ExcavationLength Width Depth

PLUG- IN

For Attainment at Petroleum Sites:(PADEP Guidance)

Biased Sampling Number of Samples:

Volumecu ft cu dm

5 for 1st 250 cu yd =

1 for ea addl100 cu yd =

TOTAL =

For Statistical Demonstration of Attainment:(Pennsylvania Code - Title 25. Environmental Protection - Chapter 250. Administration of Land Recycling Program - Section 250.703. Gener

Random or Grid Sampling Number of Samples: 8 for up to 125 cu yds =

12 for up to 3 000 cu yds =

12 for ea addl increment up to 3 000 cu yds

TOTAL =

r - Calculation of# of Sam les er Soil Volume - 02 06 2002.xls

cu m cu yd

cu yds

( 0 ) increments

Steve Lester - Calculation of# of Sam les er Soil Volume - 02 06 2002.xls

JIL SAMPLES TO BE COLLECTED AT A SITE:ate: February 6 , 2002

See next page for a table. Below is an example of how it should be done, according to the latest PADEP regulations and gui

Example:An embankment is proposed for excavation and removal.

Length Width Depthft ft 750.00 60.00 12.

It has the following dimensions:Volumecu ft cu d m

540 000.00 15,290 640.

For Attainment at Petroleum Sites:

Biased Sampling Number of Samples: 5 for 1st 250 cu yd =

1 for ea addl100 cu yd =

TOTAL =

For Statistical Demonstration of Attainment:(Pennsylvania Code - Title 25. Environmental Protection - Chapter 250. Administration of Land Recycling Program - Section 250.703. General Attainmel

Random or Grid Sampling Number of Samples: 8 for up to 125 cu yds =

12 for up to 3 000 cu yds =

12 for ea addl increment up to 3 000 cu yds =

TOTAL =

r - Calculation of# of Sam les er Soil Volume - 02 06 2002.xls

cu m15,290.

cu yd000.

20,000

197

202

cu yds

samples

samples

( 6 ) increments

ve Lester - Calculation of# of Sam les er Soil Volume - 02 06 2002.xls

) TO BE COLLECTED AT A SITE:)oil to be Screened

Ies for Attain.Lengtt Width Depth Volume

PETRO STATcu ft cudm cu m cuyd SITES ATTAIN200 5663

5000 141580 142 185100 100 20000 566320 566 741

125 3540

250 7079

750 21237

1000 28316

1875 53093

2250 63711

3500 99106 1304000 113264 113 148

5625 159278 159 2086250 176975 177 231

12500 353950 354 463100 12500 353950 354 463100 25000 707900 708 926100 25000 707900 708 926100 50000 1415800 1416 852250 62500 1769750 1770 315250 125000 3539500 3540 630500 125000 3539500 3540 630500 187500 5309250 5309 944500 250000 7079000 7079 259

1000 250000 7079000 7079 2591000 500000 14158000 14158 519 1875000 100 2500000 70790000 70790 593 9285000 100 5000000 141580000 141580 185 187 18540000 100 5000000 141580000 141580 185 187 1854

10000 100 10000000 283160000 283160 370,373 37061000 1000 15000000 424740000 424740 555 560 5558

ve Lester - Calculation of# of Sam les er Soil Volume - 0206 2002.xls

Petro Petro StatII

16 20 43 43 66 90 90 182 923 1849 1849 3701 5553

Stat Stat

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ard M. D'Alba Les'sons ' Lea

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Edward M. D'AlbaKestner, JustinLessons Learned - Waterway Opening Guidelines (unofficial guidelines)

JustinThe info you have offered to K(gU precisely responds to the need to share knowledge amongst engineersand clients. The fact that new "criteria" emerges after the design has been approved can lead to a budgetdifficulties if the client does not recognize the added cost of the redesign. (you are to be commended forobtaining a supplement for the added work) Having this info on K(gU just might prevent that type ofproblem from occurring. It also is a good lesson in general in formerly asking ALL clients if they have anyother standards or criteria in which they expect us to design to , beyond what is spelled out in our contract.Thank you Justin for sharing this very worthwhile lesson. EMD

cc:Mike

Executive Committee; Leinheiser, Dan; Mebane , Kennan; Mundorf, Bruce; Wetzel

Urban Engineers, Inc.

MemoTo: Ed D' Alba

From: Justin Kestner

Date: March 14 , 2003

Re: Lesson Learned - Waterway Opening Guidelines

This concerns a document known as BUP-H01: Waterway Opening Guidelines. Developed in April 1999, thisinternal PENN DOT guideline addresses waterway opening requirements and guidelines. This 10-pagedocument is being used by the SR 6202 design review consultal1t (DRC), and its criteria has twice led toissues on the project in the past year. Highlights include:

1. Recommend not lowering existing bottom of beam elevations more than 6 inches (150mm) forreplacement projects without approval of District Bridge Engineer (p. 2)2. Recommend minimum 2 ft (600mm) freeboard for the design flood (p. 5)

We first became aware of this document in April 2002. We had just submitted the revised TS&L of aculvert for approval. This structure replaced a smaller, existing culvert. As a result a wider but shallowerbox culvert was designed. The Hydrologic and Hydraulic (H&H) report had been approved prior to TS&Lsubmissions.

Following the final TS&L submission , we received a comment from the DRC directing us not to lower the bottomchord elevation more than 150mm from the existing structure. The DRC referenced BUP-H01 and forwardedthis document to us. The net result: we revised the H&H and subsequent TS&L to adhere to this guideline. (Ofcourse we received the appropriate number of supplemental hours to offset this effort.

The second instance where BUP-H01 came into play concerned minimum freeboard. Neither Dm-4 nor DM-has established criteria for required freeboard. Designers have commonly used 1 ft (300mm) of minimumfreeboard above the design flood. For this project, we used 300mm above the 1 OO-year flood. This was statedin each of the three H&H reports we submitted without comment.

We had a severely skewed (32 ) bridge with a 42.2m span over a waterway. The structure depth had beenminimized due to various project constraints. When the BUP criteria of 600mm above the design flood wereraised, we had a potential problem. If we provided 600mm of freeboard above the 100-year flood , we wouldviolate minimum span-to-depth criteria. Similarly, by meeting span-to-depth criteria we would not be able toprovide 600mm of freeboard above the 1 OO-year flood , though we would be able to provide 300mm. Thankfully,after a thorough investigation, we determined for this drainage area we were only required to use a 50-yeardesign flood versus a 1 OO-year storm. This enabled us to provide 600mm of freeboard while satisfying span-to-depth criteria. But the potential for significant project impacts were there.

1i9mjIpiI )6. UP:BPJ' neither aweli-known nor an official documentiflowever, there are several

Ocjivi9ualswithinJ?ENNDOT-and-with.other.consulting firms who do use this as a guideline. I would advise all

e$rgners to adhere to these guidelines whenever possible. Even if the engineers reviewing your designs arenot aware of these guidelines , at least you would have some documentation on which to base your designs.

I have attached a copy of this document, and recommend it be uploaded to K

-- -.

BUP-HOl WATERWAY

OPENING GUIDELINES

CONTAINS PENNDOT GUIDELINES FOR.FREEBOAR FOR NEW AND REPLACEMENT

CULVERTS & BRIDGES

'--

APR. 18.20 1: 1eA BAK ENIRONTAL INC NO. tjl t". l/U:J

BUP-HOl WATERWAY OPENIG GUIELIs

". .

The priar pwpose of the Hydrologic and Hydric Reprt is to prvide necs8I informon to the Penlvaa Dearen of Trrton (Pen and the PenlvanaDearent ofFJvinment8 Prtecon (pEP) to jus the proposed Waterway Openig. AWareal Op is defied by the no clea $pan and the tnwn unereace abvestreabed thfore the individua prepar the H&H rert should prt the nonn cleaspan and the minum 1Ddereace abov stbed elevon ver disy on the BridgePlan Elevation view. For multiple span bridges the nonnaI clea spn lengt of ea spanshould be provided. Pernent inonnaton concerng the horinta span and the vercaundereace of a bridge is as follows: A.. BRIGE SKEW:

To propely lec the skew of a bridge over a stea chmmcI, one should always plot thetop of ban lines and grund contour in the out-of-ban area, becuse the edge-of-strea lines do not always repreent the chanel alignent of flow direction durg aflood. Strct ' tht ar not properly aligned with the flow dion under flooingConditions 'are more suceptible to scour when flood conditions exst at the site. Consderboth the ch8Del alignent and the contour diron in the out-ofiban ar whenpickig bridge skews becuse the flow diretion durg f1oodg is usually based on oneof theSe two. conditions. HORIONTAL SPAN INORMTION:

RecornendedDesign Manual Par 2 (DM-2) design floods are for highwayprojecs on new alignents (i.e_:. S.R. 6220 R. 62 I 9, S.R. 6522 etc.) and theyar considered to be "the ideal design flOos for bridge replace ent project.However, replaceent bridges do not have to pass the remmended DM-2 .design floods.

2... History of floodinJj is e key piece of information used to evaluate existgbridges to be repIa.ce.

If the existing bridge has a history of flooding or signficat scour

prob1ems, we should increae the wateray opening as much as praCtcal.Try to get abutments at or beyond the-top of ban so they ar out of

- .

themaincbanel.

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BA ENlROR- INC 1't . tj r. c./ .Jt:

If stng abutents ar locate with the mai chanel nea the edge-of-str, we should move the abutments at lea hatfway up the chelside slopes to get them awa &om the noma! flo\V of the chel. Weshou1d do this even when ther is DO hiory of floo at the site.

NOTE: See DM-2,1 Chapter 10, Division 2;, Page 10.63 whichsays "tbe bridge abutents or approach embanen should not, in gener, encroach upon the ma chanels ofth sts. ;Q"

,-

f'tr f. 1r11Wr H.I IJI/v P 11t' ,

DEP' s Tide 25, Chapter 105 Reglatons reqir our stctu to bedesigned to pass flood flows that wer deterned with reonableconsidertion of deve10pment which may alter the ruoff charristcs ofthe wateed durg the anticipated life of the strcte. ReferenceSeCton 105. 161 (Hydrc Capacity).

VERTICA UNDERCLEARCE INORMTION:

" 1. The guidelines in the atted Stre-ff.l tter conceng Bridge Freboardshould be considered.

Compare both the existing and proposed underleaces based on theunderlea!X you woQ)d have nom the bottm of the b down to theproposed chanel grade line so we ar compar appleS and apples. See the attached stream profile sheet and the attChed elevation view of a tyicalproposed bridge openmg. Underclearance:

~~~~~

QQUQ.nAof.hleationmoreX.-- Without apprval fim the Disct Bridge Unit when workigon bridge or supertrcte replaceent projects. The Deparent win check tomak sur that the Bi-AIUuaI Bridge Inpection Report and other FloodInspecon Reprt do not indicate problems with debris lodging on the xistigSUpertrctre. '

NOTE It is not easy for the Deparent to defend itself in COur if theproposed bottom of beam elevation is lowere more than 6" below the bottom ofbeam elevation of the existing bridge and Deparent records indicate that there is8 history of debris probl s with the existing strcture. " In general

:!

Deparent should not approve lowerg the proposed bottm of beam elevatiofor Stctures that do not passihe reon:ended Deign Maua Par 2 designflood with , 5 feet of freeoard for small and medium bridges aT with 3.5 feet offrard for larer stct.

. " . , . " . .

2 of 10 04/30/99

APR. 18. 2002 1: 11PM

. (BA ENIROTAL INC NU. tjl t". U::J

CahDration: Hydrlogic and Hydrc Modls (B-sbouJd be caDrated to assu th the water surface elevation ar reneble andth the Q 100, et. floo elevatons preente in the HEC.2 or HERASHydrulic ModeJ output shee are consisent with the hi offJooginonnafion at the site. The USGS offce across the stte should be consulte todeterne what fruency stann a parcula flood was for a parcu site. Forexample, the USGS informed Rober Hei th the Janwu 1996 floo Was alOOyea stnn event acrss all six (6). counes in Distct 9 ; therre Dict9-0 cabrates HEC- IIHEC-RAS models to be consitent with the Januar 1996 .flood elevons.

NOTE:

OTHR PERTI INFORMTION CONCEG THE PROPOSEDWATERWAY OPENING:

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h_,! In 8encr Jb!;_Q J tq: fty j$ shou1d ngt show the prpo$Cbac"kater '- elevation to De higJeil1ai fh existig Q 100 backater eJeYJon -w.hqi. 8. 9iect

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is in a detailed PEM Flood Study ar Oteise, We ca incre the Q I 00' - oackiiter elevation up to 1.0 foot (UseJO" or Illt max. bjeo to approval byloca mUncipalties. See attcbed shee frm. DEP's Title 25, Chpte 105 Reguations (Seenon .105.161). The detaled FEMA flood study must be revised if the Q 100 Floodelevations ar incred above thse published in Table 2 of the Floo Inurce Study (PIS). Refeence the inonation in DM..Chpter 10 conceing detled FBMA Flood Stuy Ar.

Constrct elevated floodplais thugh proposed bridges pe DM- , PagelO. 121 , to maintai the upstr )ow.flo hanel width the upstr flowdepth and the upstr velocity thugh the bridge. The elevate Floodplain hassevera purses:

It maxiz the wateray openg for a given span and itmimizes velocity increaes/scour durg perods of flooding.

It is a st improvement which is provided to maintain theupstr norm flow depth and assurs fish passage thugh thebridge.

c. It 'mai in tbe upstea chan ) velocity thugh the bridgeunder nonnal flow and prevents sedimentation problems which

era1)y occ over dur ow conditions; thereforethe elevated floodlai mini the nee to do chanel cleanr;g

. and it helps to keep the chanel bottoIn' cJea so that fish ca better

. .

3 of 10 04/30/99

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BAER ENVIRONTAL INC

NOTE:

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Both DEP an the P A Fish an Boat haverequested tht We depre the rock prtecon for the. abutments 1 foot (min.) below the prposed cle1 grdeline whenever the abutment rock proteon exte oUt. beyond the edge-f-s line/elevated t100Iai into theproposed low flow chanel, as indicate on the ttachedsketch. Th wi allow the chanel bott at the bridge tosilt..in ove( tie 8nd

provide nat chanel bottm forfish life simlar to a cuver witb depsed bott.Depresing the rock proteon wil al reuce loca SCOurdepth and allevate an problem with blockage tht mightocc $bo d the ovcrl chanel reach in the an of thebridge experence degdation. PenOT sugges thatdesgner dep the rock protetion in the low lIowchane1I. fot mimum to 2.0 foot maxmum based onthe Q 100 contrcton scour estiate to better comply withthe HEC-18 guidees.

4 of I 0 04/30/99

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a... ot Doip c. Y:ilatcodUon: III Q8Detd. freeboar .ia dofi.J. -P8 at'..rtical dilt&1 bet...n tb 1.Y8 of vata

1.C8 ua..l1 corr.8PG to tb de8iVh flowan . po1!t of tnt.c..L audl .. . bcldy.

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.1 treebrd I. the -.rt t C81 . di .tanc.betweea tJ i:aiga flow 811.8UOI bE1dOe tJ..tJttOl .18"&tlae.

laJ.e r8Go.cd II.. W'1tal fut1oD th8 8at8P8to .01 u. 1a1d. ft- lIoar ...t bePf1d8 "low tM bcld9 tor rl' 1. (t

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tC' .te.1 .1I iC8 8h w1UautcaUl", uar di,. to bridge.

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"1' ..t'betV88f 2' An 3. rJ1 Gf en t=h8 alae of tr... bridge aD tJ r:tatJ.l foE' fee 88 de!:!A8 "r t. I'&'al Aid I'UCJ .ide (SRticm 1-116 Du10n8taar.2 .tr d. .ball be proYicl. ..&' Jl8ct1081. tCloteet t! brJdq. "eructur 'r08 1c 8I ac: relat:ed d..O'...

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Tide 25. EOrironmeDtal ResurcDcenr of EnviJ"oDmmw RcsUlce

Cbapt 105. Da Saety d Wateray Muqaaczu

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r. J.t:/

Unexpected Events During Geotechnical Work

When driling and collecting samples for geotechnical work, you should always keep your eyes open forany indicia of environmental contamination. These indicia include:

Extraneous odorsDiscolorated soilPresence of liquids (especially black, viscous liquids) in the drilling mud

Special precautions should always be taken, such as always wearing proper protection (latex gloves are aminimum) and always having proper sampling equipment and tools handy in case contamination isencountered.

It is cheaper to collect a sample when the opportnity is available (even if the sample is never used) than tohave to come back later and spend a considerable effort to collect the sample.

Lester - Publication of PADEP Notices.doc

Publication ofP ADEP Notices

When remediating a site under the P ADEP Act2 Program, there are opportunities forsaving the client money and saving Urban some effort.

For example , when remediating a site according to Site-Specific Standards , the guidelinesrequire that you publish the Notice of Intent to Remediate in the beginning of the projectas well as other notices every time a report is delivered to PADEP. However, it isacceptable to P ADEP that you publish only one notice if two or more events that requirea notice will occur within a short period of time.

For example, in the Celotex project Urban had to perform under a tight schedule to meetfinancial deadlines for redevelopment of the site. Accordingly, the project got off to aquick start and the remedial investigation was completed even before the publication ofthe Notice of Intent to Remediate (in many other cases , the NI is placed on hold untilthe remedial investigation can identify the standard that would apply for each site - thesame publication procedures would also apply under these situations). Urban publishedthe NI, only to have to come back and duplicate its cost and effort to publish a separatenotice for the publication of the Remedial Investigation Report. A single notice wouldhave sufficed in this case, if it contained both the language necessary for the "Intent" partas well as a summary of the conclusions of the remedial investigation. A 30-daycomment period would still be present between the time the NI was officially receivedby P ADEP and the date when it could start analyzing the RIR. However, in this case , thecost of publication would be cut in half, and P ADEP would be ready to start work as soonas the comment period expired. In other works , you would have saved some money,some time, and some red tape.

ve Lester - PAUSTREG.doc Pa e

Lesson Learned - UST Removal Certification (PA DEP)

I called P A DEP to detennine certification the requirements for UST removal in Pennsylvania.Specifically, I needed to know ifP A DEP has a "third-party" requirement. In short, the answer is

PA DEP requirements are met if there is a certified UST remover (with UM certification) onsite and the company he/she is working for is also certified. The person with the certification can be an employee of the contractor or the consultant.

12/23/98t: \lessn _Ie.am \paustreg.doc

Steve Lester - New Jerse Groundwater Cleanu Standards. doc

New Jersey Groundwater Cleanup Standards

NJDEP has established "new" MCLs that are not widely known, unless you deal with the agency on aregular basis. The state s groundwater quality criteria are governed by several regulations and standardsbut DEP has decided to rely on the MCLs published in the NJ Register on November 18 , 1996 whichchanged 6 existing MCLs and added 4 new MCLs. These changes are significant - for example, xylenecleanup criteria was previously 40 ppb but is now 1 000 ppb (note that this is stil very stringent comparedto the federal MCL of 10 000 ppb).

The "new" standards are not readily available on the Internet, nor have we found widely distributedpublication of these new limits. The new MCLs for 11 compounds were documented in an internal NJDEPmemo from Rich Gimello , Assistant Commissioner, to the agency s Site Remediation staff (February 51997).

Jack Serwik has a copy of this memo. Anyone dealing with NJDEP groundwater cleanups should obtainthis memo from Jack and use the new MCLs in any analysis of groundwater contamination.

Jack is also trying to obtain more recent internal NJDEP documentation on soil contamination cleanuplevels and wil make this information available when he receives it.

r - Labs.doc Pa e

Lessons Learned - Laboratory Confusion

We recently had a problem with the groundwater analysis performed by a laboratory. The chain of custody(which is submitted to the laboratory with the samples) indicated which samples were to be analyzed forone or more of the following:

1. P A DEP Storage Tank Requirements for used motor oil2. volatiles (Method 8260)3. semivolatiles (Method 8270)

The lab then made the following assumptions:

1. Since some of the samples were to be analyzed for PA DEP Storage Tank Requirements for used motor oilall samples should be analyzed for Method 525.2 not Method 8270. (The PA DEP DocumentClosure Requirements for Underground Storage Tank Systems" states that for USTs containing used

motor oil, Method 525.2 must be run, but only for three compounds.2. Urban would like a library search of tentatively identified chemicals under 8260, not quantities

(concentrations).

Both assumptions were incorrect. The first assumption was wrong because the site has tanks in addition tothe used motor oil tanks. On the opposite side of the site there is a coal tar tank. The PA DEP DocumentClosure Requirements for Underground Storage Tank Systems" does not specify the tests to be run for a

coal tar tank. I was relying on Methods 8260 and 8270 to quantify volatile and semivolatile compounds inthe groundwater samples, as required by Act 2.

The second assumption was wrong because I wanted concentrations of chemicals in the samples so that Icould compare them with Act 2 standards. The lab gave me a list of "tentatively identified compoundswithout concentrations.

As you can see , I now have a large lab report that is worthless to me. I'm currently discussing ways tocorrect this problem with the lab. The lab feels that they have adequate data to quantify the compoundsthat were previously detected on site. If they can successfully do that, we wil have reached a reasonablecompromise.

I (and hopefully the lab) learned a lot on this one. I hope the lab leared to follow the chain of custody,and not assume that they know what methods have to be run. I also wish they had read the note on thebottom of the chain of custody that said "Call Dave Lamontagne at (215) 922-8081 ext. 1383 if you haveany questions

I learned the following:

1. When submitting samples to a lab for analysis, discuss in detail what the lab deliverable wil include.2. When listing a method to be run, make sure that the list of compounds to quantify is noted on the chain of

custody. The default list would either be the "Method Parameter List" or the "Target Compound List"When a list is given, the lab wil give the concentration of compounds on the list.

3. Always indicate the regulations pertinent to your samples. The lab has said that if I had told them that8260 and 8270 were being requested to determine compliance with Act 2 , they would run the analysisproperly (they wouldn t have assumed used motor oil tanks).

Hopefully, we can all learn from this incident.

Lester - Haz info.doc

Hazardous Waste Sampling and Cleanup Information

The following information is suggested for use in Urban s haz mat work. In particularthe web site described below is a wealth of information that should prove useful.

Hazardous Waste Clean-up Information Web Site: This EPA site providesinformation about proper sampling protocols , regulatory updates , and innovativetreatment technologies. It describes programs , organizations , publications and other toolsfor federal and state personnel, consulting engineers , technology developers and vendorsremediation contractors , researchers, community groups , and individual citizens.http:clu-in.org/

Selection of Analytical Parameters for Testing: How does one know what to samplefor when developing a sampling plan for a brownfields site? One approach is to reviewthe prior use of the site and tentatively selects parameters based upon the attached table(Guide to Contaminants Found at Typical Brownfields Sites). The list can then bemodified, if needed, by site visit observations , interviews , and review of the Fact Sheetsdescribed below.

Industry Profile Fact Sheets: These EP A-developed fact sheets provide a generaldescription of typical site conditions and contaminants for about 30 industries such asprint shops , salvage yards , and electroplating. The Fact Sheets generally includeinformation on the following:

IntroductionIndustry and Process DescriptionCharacteristic Raw MaterialsWaste Streams and Potentially Affected Environmental MediaSampling StrategiesSuggested AnalYtical Parameters

The Industry Profile Fact Sheets can be accessed as html files on the t: drive att:\lssn le.arn \Idust - FS.html.

ster - Haz info. doc

Guide to Contaminants Found at Typical Brownfields Sites

Past Activities Typically Typical Contaminants and Typical SourcesConducted at Brownfields Sites

Automotive refinishing and repair Some metals and metal dust; various organic compounds;solvents; paint and paint sludges; scraD metal; waste oils

Batterv recycling and disposal Lead; cadmium; acidsChi oro-alkali manufacturing Chlorine compounds; mercuryCoal gasification Polynuclear aromatic hydrocarbons (P AH)Cosmetics manufacturing Heavy metals; dusts; solvents; acidsDry cleaning activities VOCs such as chloroform and tetrachloroethane; various solvents;

spot removers; fluorocarbon 113

Electroplating operations Various metals such as cadmium, chromium, cyanide, copper, andnickel

Glass manufacturing Arsenic; leadHerbicide manufacturing and use Dioxin; metals; herbicidesHospitals Formaldehyde; radionuclides; photographic chemicals; solvents;

mercury; ethylene oxide; chemotheraDv chemicalsIncinerators Dioxin; various municipal and industrial wasteLandfills-municipal and industrial Metals; VOCs; polychlorinated biphenyl (PCB); amonia;

methane; household products and cleaners; pesticides; variouswastes

Leather manufacturing Toluene; benzeneMachine shops/metal fabrication Metals; VOCs; dioxin; beryllium; degreasing agents; solvents;

waste oilsMarne maintenance industr Solvents; paints; cyanide; acids; VOC emissions; heavy metal

sludges; degreasersMunitions manufacturing Lead; explosives; copper; antimonyPaint/ink manufacturing Metals (such as chromium, cadmium, lead, and zinc); VOCs;

chloroform; ethyl benzene; solvents; Daints; inksPesticide manufacturing VOCs; arsenic; copper; pesticides; insecticides; herbicides;

fungicides; xylene; chlorinated organic compounds; solventsPetroleum refining and reuse Petroleum hydrocarbons; benzene, toluene, ethylbenzene, xylene

(BTEX); fuels; oil and greasePharmaceutical manufacturing Lead; various organic chemicals; organic solventsPhotographic manufacturing and uses Silver bromide; methylene chloride; solvents; photographic

productsPlastics manufacturing Polymers; phthalates; cadmium; solvents; resins; chemical

additives; VOCsPrinting industry Silver; solvents; acids; waste oils; inks and dyes; photographic

chemicalsRailroad yards Petroleum hydrocarbons; VOCs; BTEX; solvents; fuels; oil and

grease; lead; PCBsResearch and educational institutions Inorganic acids; organic solvents; metals and metal dust;

photographic waste; waste oil; paint; heavy metals; pesticidesScrap metal operations Various metals (such as lead and nickel); PCBs; dioxin;

transformersSmelter operations Metals (such as lead, copper, and arsenic)Semiconductor manufacturing Metals; VOCs; carbon tetrachloride; de greasing agents; solventsWood pulp and paper manufacturing Chlorinated organic compounds; dioxin; furans; chloroform; resin

acids

Lester - Haz info.doc

I Wood preservingCreosote; pentachlorophenol (PCP); arsenic; chromium; copper;

PCB; P AHs; beryllum; dioxin; wood preservatives

ster - UST $. DOC

UST Unit Costs - Circa 1998

Following costs are guides for estimating costs in Pennsylvania. New Jersey costs wil probably behigher. The costs below should be used for preliminary estimates

--

more accurate costs can beobtained by contacting tank contractors, labs, etc. and getting quotes on a project-specifc basis.

Cost for Removal:

Size of Tank (gal)550000000

Gasoline Tank500500000

Consulting fees are in addition to the above estimates

Fuel Oil Tank400300000

Cost of Disposal:

Contaminated soil-- $40 per ton.... $250 for fIrst dr, $150 per drm thereafter

Contaminated water/sludge -- $1.00 per gal (gasoline-contamiated water) - 350 gal minimum$0.65 per gal (fuel oil-contaminated water) - 350 gal miimum

Lab testig of soil prior to disposal-- $500 per 1 000 tons of soil

Cost of Excavation and Backfll:

Over-excavation of contamiated soil -- $1 000 per day

Backfll material-- $20 per ton (note: a recent bid by Miniscalco showed $40/Ton for clean fIll)

Paving -- $25 per sq yd

Cost of New Tanks (installed):

Size UST AST000 gal tank with 50 feet of piping $30 000 - $35 000 $24 000

000 gal tank with 50 feet of piping $70 000 - $80 000 $60 000

Above tank cost assumes minimal dewaterng and no exceptional costs for repaving, ground restoration, etc.

t:/projects/ust doc (revised 11/3/98)

Steve Lester - Act 2 Chan es 2002 - PADEP Worksho 05 13&14 2002.doc

lessons learned

Updates to Act 2 PADEP Workshop - May 13 and 14, 2002

In addition to Spencer Finch, the following Urban personnel- Thorn May, Vlad Ivensky,Mike Dostillio, and Angelo Waters attended the PADEP Act 2 Workshop at the RadissonValley Forge on May 13 and 14 2002. A departmental meeting was then held on May

, to summarize all the sessions attended during this Workshop and to point out itemsthat we should keep in mind. The following items were considered significant enough tobe included in this Lesson Leared:

Plots of contaminant plumes onsite are essential for each Site Characterization Report.In addition, the isopleth of the PQL level should be included in each plot(concentrations outside this isopleth would basically be "Non-Detect"

Preferential Pathways (sewers , other utility lines , building foundations , even monitoringwells) should be considered in the evaluation of the potential for migration ofcontaminants

When the Non-Used Aquifer Standard is used, be reminded that even though Non-UsedAquifer levels must be met inside the site, Used Aquifer levels still have to be met

000 feet downgradient from the property line

When performing sampling and testing of soil, have the lab test for Porosity andFraction of Organic Carbon (these values could then be used when performing aFate and Transport Analysis , rather than relying on the text book values - check tosee what value is most appropriate for your modeling)

Fate and Transport Analysis: if a stream is affected, use the PENTOXSD model isrequired to calculate the impact of contaminant mixing and dilution within a stream

When TCE, PCE, or other chlorinated solvents are present, Quick Domenico cannot beused - use Biochlor instead

In many cases SWLOAD can be used directly to calculate the input concentrations to beused in the PENTOXSD model. In some cases , it may be necessary to use acombination: first Quick Domenico (or Biochlor) and then SWLOAD

Review PADEP' s Database of Engineering and Institutional Controls when performing aPhase I Assessment. Also , make sure that engineering and institutional controls(and operation and maintenance of controls) for your site are adequate since they willbe included in the database and in P ADEP compliance checks from now on

I The database tracks all deed restrictions, other institutional controls, and engineering controls specified incompleted Act 2 projects. Currently - as of May 2002 - the database is stil incomplete, but over timeP ADEP plans to have all projects included.

r - Act 2 Chan es 2002 - PADEP Worksho 05 13&14 2002.doc

The 75% / 10 X Rule can only be used for what is officially selected as your "Site" - inmany cases this means the area contained within the PQL Isopleth (the "PQL Plume

Be aware that the selection of the area that will be labeled "Site" for regulatory and legalpurposes is left to the owner s discretion. However, a site too small will not interestthe client/developer; might leave other contaminated areas of a propert unaddressed;and might raise concerns with P ADEP. A site too big may require a level ofexpenditures (with additional sampling points, for example) that would make the siteun-redevelopable; and again might raise questions with P ADEP , especially inattempts to use this extra area in statistical attainment efforts.

For UST Program closures , the results of lab tests must be reported to P ADEP and thewell owner within 5 days of receipt from the lab

Prepared by Spencer Finch, May 16, 2002

r - SPLP v TCLP .doc

SPLP versus TCLPLesson Learned prepared by Spencer Finch - April 17, 2002

Lesson Learned: The correct procedure to use when doing a leachate test forPADEP' s Act 2 is the SPLP, not the TCLP.

Discussion

As part of the Act 2 process, Urban has used the TCLP test many times in the past tocheck if soil contaminants would pose a concern to groundwater underneath a site. other words , by doing a leachate test such as the TCLP, the site specific conditions tell uswhat the real potential is of a soil contaminant would be of reaching groundwater, insteadof estimating the potential by using the generic number built-in to the P ADEP Soil-to-Groundwater Statewide Health Standard. Many times , the site-specific or sample-specific result obtained from the leachate procedure will meet the groundwater standardthus reaching attainment for the site by Act 2 rules.

However, the procedure required by PADEP is the SPLP, not the TCLP. For moreinformation, see:

Section 250.308 in the uBlue Book" (Section 250.308

, "

Soil to Groundwater PathwayNumeric Values" in Pennsylvania s Title 25 , Chapter 250

, "

Administration of LandRecycling ProgramPart B of the Act Technical Guidance Manual (specifically, Part B , page 11-section B. b.i

, "

Choosing the Soil-to-Groundwater Numeric Value" inPennsylvania s Land Recycling Manual (Guidance for Chapter 250) )

A little more background on the two methods is useful to see why the SPLP is used:

TCLP: The TCLP is utilized primarily for measuring landfillleachates. Thus , it istyically associated with RCRA corrective actions , where samples are taken frommaterials to be landfilled to determine:

1) If the material is hazardous2) What leachate quality could be expected

The procedure was designed to mimic mildly acidic rain water leaching metals from asample and potentially migrating into ground water. In addition to profiling industrialwaste materials destined for land disposal, the TCLP is also used in other areas , such as:

guiding the disposal of food processing residualscharacterizing leachates from lead-based paint, where the TCLP is sometimes used ratherthan the SPLP

r - SPLP v TCLP.doc Pa e

The TCLP is listed as a method endorsed by the EP A * (EP A Method 1311), and can beviewed online at: htt://www.eva. gov/evaoswerlhazwaste/test/1311.vdf.

SPLP: The SPLP is utilized primarily during site characterizations. Thus , it is tyicallyassociated with CERCLA (Superfund) and state voluntary cleanup efforts. The procedureis nearly identical to the TCLP in methodology, and differs by the nature of the extractionfluid utilized. It is generally used to more closely simulate actual groundwater leachingeffects, rather than landfillleachates.

The SPLP is listed as a method endorsed by the EPA* (BPA Method 1312), and can beviewed online at: htt://ww.eva. !!ov/eoaoswerlhazwaste/testl1312.vdf.

As a general rule, TCLP leachate will produce higher contaminant concentrations thanSPLP. For example, lead concentrations can be 5 to 100 times higher in a TCLP test vs.SPLP (htt://www.rangeinfo.org/NSRS/4%20Policv%20Track/Testin!!Range.vdf) However this isnot always the case - depending on the material being leached and the contaminants ofconcern being tested, the SPLP could produce higher concentrations (seehttp://hvoer.fit.edu/rcwu/finalrevort.htm

Conclusion

The choice of which procedure to use depends on the specific conditions of your project.The TCLP will tyically be used for industrial waste disposal and for some leadinvestigations; while the SPLP will be used for site characterizations. The procedurefor site characterization required by P ADEP's Act 2 is the SPLP, not the TCLP.

. As part of the SW-846 Physical/Chemical Test Methods for Evaluating Solid Waste.

Steve Lester - Small Diameter Geo robe Wells vs.doc

Small Diameter Geoprobe Wells vs. Permanent Monitoring Wells

Lesson Learned

Based on several site characterizations we have noticed that samples collected from smalldiameter geoprobe wells or with geoprobe sampling probes have a tendency to reporthigher concentrations of chemicals in groundwater then in adjacent samples collectedfrom permanent monitoring wells. It appears that sampling results obtained from small-diameter geoprobe wells could not be used to properly quantify contamination. Suchsampling data could be, however, utilized for screening purposes and for preliminarycharacterization.

P A Guideline on This Issue

PA DEP Groundwater Monitoring Guidance Manual, Februar 1996 (page 15)recommends in-situ sampling probes (such as hydropunch) as valuable reconnaissancetools for preliminary site characterizations or for determining the locations of permanentmonitoring wells. It is pointed out, however, that in situ sampling probes can missLNAPL on the water table, and may have problems penetrating coarse materials , slow filltimes in clayey sediments and significant capture of fines in the sample.

Our Field Experience

We have noticed that:

Water samples collected from %" - 1 y." geoprobe wells (piezometers) may indicateconcentrations of chemicals in groundwater up to 30 percent higher than in 2"wells and up to 40 percent higher than in 4"OD wellsThickness of free product is higher in geoprobe wells than in monitoring wells (forexample, 3' in a geoprobe well vs. 0. 5' in and adjacent 4" OD monitoring well)

Probable Explanations

1. Geoprobe wells are not purged; thus sampling data represent a discrete randompoint in the plume. Monitoring wells are purged; thus sampling datarepresents average concentration of well' s area of influence and, thereforebetter describes the existing conditions in the plume.

2. The small diameter of geoprobe well can possibly act as a point of concentration(trap, capillary, etc.) causing flow of contaminants , especially, LNAPLstowards the well.

3. The GW sampling technique (hydropunch with Tygon tubing) used by geoprobeoperators can possibly act as a point of concentration. .. see above.

e Lester - Safe Fill Summa 2 28 02.doc Pa e

Safe Fil" Requirements Updated 4/9/02

Part 1 - Pennsylvania Safe Fil regulations (proposed)

Part 2 - NJ soil reuse requirements

Part 1 - Pennsylvania Safe Fil regulations (proposed)

In an April 8 , 2002 web-based newsletter, the Pennsylvania Chamber of Business and Industry presented agood introduction to the proposed regulations:

On Februar 2, 2002 , the Pennsylvania Environmental Quality Board ("EQB") published proposedamendments to Pennsylvania s municipal and residual waste regulations in the Pennsylvania BulletinThese proposed regulatory amendments are commonly referred to as the "safe fill regulations" and aredesigned to replace the Clean Fil Policy that the Pennsylvania Departent of EnvironmentalProtection (DEP) issued on February 29 , 1996.

Few if any guidance documents issued by DEP have had broader ramifications for the regulatedcommunity than the Clean Fil Policy. The Clean Fil Policy in practical terms establishes the dividingline between soils and other materials which are deemed suffciently "clean" to be insulated fromregulation as wastes under the Solid Waste Management Act (SWMA) and those that instead aresubject to the complex requirements imposed by the SWMA. As such, the Clean Fil Policy hasrelevance to virtally every construction and remediation project in Pennsylvania, ranging from theconstrction of sewer lines and roads to the redevelopment of industrial sites and "brown fields.Indeed, virtally all earthmoving activities in Pennsylvania are potentially affected by the Clean FilPolicy. The proposed safe fill regulations cover the same expanse of activities and therefore havemassive economic ramifications for the Commonwealth and its citizens.

The Chamber believes that the proposed safe fill regulations represent marked progress in rectifyingthe problems created by the Clean Fil Policy. However, substantial additional changes to the proposedsafe fill regulations are necessary in order to avoid regulating under the Pennsylvania Solid WasteManagement Act ("SWMA") enormous amounts of soils and other materials that can be beneficiallyused as fill with no adverse impact to either public health or the environment.

In addition, the Chamber submitted extensive comments to the proposal (seehtt://www. vachamber.orglbaiRegulatorv/Comments/Safe%20Fil%20Comments%204- 02.doc )

E-mail sent by tgm 2/28/02 to Practice Leaders, w/ cc to Envir and Marine:

A summary of the Pennsylvania safe fil regulation proposed on 2/2102 is attached. These regulationsmay change somewhat during the comment process, but the final version (expected in the summer of2002) will probably be close to the proposed.

The regulation wil have a huge impact on any demolition or earth-moving project. PADEPestimates that 50% of the soil/material moved in Pennsylvania wil qualify as safe fill or fall under oneof the permit-by-rule provisions. Currently, this amount of soil is allegedly being disposed of inlandfills; when the new regulation goes into effect, that material can be reused as onsite or offsiteconstruction fill instead - saving $500,000,000 per year, according to PADEP. The agency alsoestimates that sampling and analysis costs associated with the regulation will increase by almost

000 000.

Those involved with construction and demolition projects in Pennsylvania should review the attachedsummary, since the proposal wil have significant impacts on our clients. We should be in a position toprovide them with good advice. Those interested in reviewing the proposed regulation can find it at

ster - Safe Fil Summa 2 28 02.doc

htto://ww. oabulletin.com/secure/data/voI32/32-5/172. html. The regulation is complex and difficult tounderstand. Accordingly, we may sponsor a brown bag, if there is enough interest.

Note: Do not give the attached to a client yet, as we are running it by PADEP to make sure ourinterpretation is absolutely correct.

Regards , Thom May

In addition , a good summary of the proposed PA safe fil regs was prepared by RT Environmental forits website. Excerpts of the web article follow:

PENNSYLVANIA DEP SAFE FILL PROPOSED REGULATIONS

The Safe Fill program is aimed at determining what excavated materials , need to be managed aswaste. Back in 1996 , the DEP issued a "Clean-fill Guidance Document" , which set numeric limits toolow , such that it was impossible to distinguish what materials were "contaminated" as the levels wereset below background levels in many instances. The DEP attempted twice to modify the "clean fil"proposal , but, extensive comments by the regulated community were submitted saying that such arulemaking package had to have the force of full regulations, and not be done by "guidance . The DEPhas worked with industry groups over the last several years , and now is proposing a formal rulemakingpackage.

Key elements of the Safe Fil Regulations as now proposed include:

o The Safe Fill limits are integrated with the Statewide Health Standards (SWHS) used in the Act 2 of1995 Land Recycling Program.

o There are basically three types of limits:A generic set of "Safe Fill" limits.Several sets of "Permit by Rule" limits.A set of stringent "Waters of the Commonwealth: limits, which are generally set at 10% of the Safe FilLimits.

o If materials have concentrations of constituents above Permit by Rule limits, materials wil have to bemanaged as residual waste. These upper limits are generally set using the Non-Residential Act 2SWHS.

o There are a limited number of "exceptions , but "cap" concentrations (the non-residential maximumlimits) above which materials must be managed as waste still apply.

Advance due diligence is the first step, prior to determining what analysis should be run on soils andother materials , to be excavated at each individual site. Due Diligence is expected to follow the sameformat as a Phase I Environmental Site Assessment for the property. DEP has worked out a series ofcomposite and discrete sampling schemes, using the EPA SW-846 and the Sampling Guidance in theAct 2 Regulations. As many projects occur in urban areas , or, near roadways, or are in agriculturalareas , due diligence reviews and testing for RCRA-8 metals and "Table 3 List" will be needed , at mostexcavation sites.

Permit by Rule options available under the program will include:

o A Permit by Rule for soils historically impacted by herbicides and pesticides , on agriculturalproperties.o Soils impacted as a result of urbanization (including emissions from coal burning and vehicle traffic).o Soils impacted by recent releases (including sites under the Act 2 Program).o Sites where dredged materials wil be used.o Certain demolition sites.

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It should be noted that Pennt by Rule materials , in many instances , cannot be placed within a 100 year floodplain. Some in the regulated community are concerned that the " 10% Waters of Commonwealth Limits , wouldcause a reduction in markets for current beneficial use materials , including steel slag, and some otherconstruction products. Such materials would potentially have to be managed as waste in the future, ifthey are re-excavated.

The Safe Fil Program also has important new provisions, related to the management of constructionmaterials at demolition sites. These include:

o Segregated construction materials at residential and commercial demolition sites, can be managedas Safe Fill.o Materials from industrial sites would have to be managed as waste, regardless of whethersegregation is or is not practiced.o Segregation wil mean the proper removal of asbestos and lead paint materials , electrical switchesPCB ballasts, etc. Expanded segregation practices are expected to now occur on residential andcommercial projects in the future, to allow maximum Safe Fil recycling of construction materials.

The DEP has generally been responsive to construction industry association comments , in preparingthe Safe Fill rulemaking package. Although the overall Safe Fill Program has taken approximately fiveyears to craft in its current form, the current package appears workable , although advance duediligence and testing wil be necessary, increasing the cost of most construction projects. As there willnow be a uniform set of state standards , contractors will no longer face the threat of litigation , as aresult of removing materials offsite, which are considered to be "contaminated" , so long as they followthe regulations. Litigation has occurred throughout the state, costing many contractors dearly.

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SUMMAY OF SELECTED PARTS OF PROPOSED SAFE FILL REGULATIONSPennsylvania Bulletin, Vol. 32 , No. , February 2 , 2002

Definition of Safe Fil

Materials meeting the following conditions are not regulated as waste when used as fill on land!No permt is needed when handling the material.

Uncontaminated material:soilrockstonedredged materialused asphaltsegregated brick, block, or concrete from residential or commercial properties

Contaminated material:moved within the R-O- Wmoved offsite from residential propert5moved within a propert

Contaminated soil moved from a fruit orchard and meeting safe fill constraints cited in(iii)(A) and (B) of the safe fill defmition

Contaminated dredged material placed on land adjacent to the dredging operation and meetingsafe fill constraints cited in (iv)(A) and (B) of the safe fill defmition

Historic fill (i. , historically contamiated material placed prior to 1988) less than 125 cu ydper excavation location (about 5 dump trcks) provided there is no knowledge of a releaseand there is no visible staining or odors

1 If the materials (no mattr how clean) are to be placed into or along surface waters, P ADEP approval is required andthe conditions cited in (vi)(A) and (B) of the safe fill definition must be met. These subsections contain ver strngentcontamination limits - for example, contaminants must be less than 10 percent of the limits specified for fill on land.2 Uncontaminated materal is defined as "safe fill" if a) it meets numerc stadards in Appendix A tables, b) there is noknowledge of a release (after doing due diligence), and c) there is no visible staining or odors. Determning if numercstandards are met may be based on one of the following methods:

detailed sampling and comparng to numeric values in Tables I (metals) and 2 (organcs);limited sampling (justified by a Phase I ESA) and comparing to Tables 1 and 3 (Table 3 is a much shorter list

of organc contaminants than Table 2 , consisting of petroleum, pesticide and TCE-tye contanants); andno sampling (justified by a Phase I ESA).

3 Brick, block and concrete from industrial propertes cannot be classified as safe fill.

4 Contaminated material can exceed the safe fill numeric stadards in Appendix A tables (based on residential MSCs)but cannot exceed Act 2 non-residential MSCs.5 Residential propert is defined as a) curently developed as residential propert, or b) zoned residential and neverused for non-residential purposes. Note that this defiition provides a loophole for properes that are not zoned (couldoccur in more rural municipalities), are currently used for residential purposes, but previously were farmed or used forcommerciaVindustral purposes.6 These sections specify that the fill site must be used for commerciaVindustral purposes, or that the soil is blended

with uncontanated soil so that the resulting blend complies with the numeric limits established in Appendix ATables I , 2 , and 3.

Steve Lester - Safe Fil Summa 2 28 02.doc

Permits

If material does not meet the safe fill defmition, it is considered a waste -- a permt is requiredfor the management of the waste. There are two tyes of permts:

Standard municipal waste or residual waste permt - these permts are issued by PADEP' s LandRecycling and Waste Management Bureau.

Permt by Rule - the PBR provisions of the safe fill regulations allow uses to be "permtted" aslong as stipulated conditions are complied with. No formal permit is applied for or issued.

The original regulations contain several PBR provisions. The proposed safe fill regulations addseveral new PBR provisions as sumarized below:

Municipal waste (Chapter 271)

Section 271. 103 specifies the constraints applicable to two new municipal waste PBR items:

Mechanical processing facilty - PBR is applicable if rock, stone, gravel, brick, block, andconcrete are separate from other waste and contamiants and operator notifies P ADEP of thefacility operation. There are other provisions that need to be met, but this PBR is not ofparticular relevance to most of Urban s work. See 271. 103(g) for particulars.

Brick, block, or concrete -- The filling of segregated BBC from industrial facilities orsegregated, contamiated BBC from commercial or residential facilities qualifies for a PBR ifthe following conditions are met:

Subsections 271. 103(a) - (c) of the original muncipal waste regulations are met!

The waste material must comply with the numeric limts (based on Act 2 residential MSCs)specified in Appendix A, Tables 5 and 6

The material is placed on properties that are zoned and exclusively used for industrial orcommercial purposes

The material is not placed into or along surface waters uness P ADEP approval is given and theconditions cited in 271. 103(i)(4)(i) and (ii) are met (these subsections contain very strngentcontamination limits - for example, contamiants must be less than 10 percent of the limitsspecified for fill on land)

Other conditions are met, such as an erosion and sediment control plan, prohibition of hazardouswaste, notification to PADEP, record keeping, etc. (see 271.103(5)-(14) for particulars)

I These subsections require the following:

The facility or activity complies with Chapter 285 relating to storage, collection and trnsporttion of waste.The facility or activity has the other necessary perts under the applicable environmental protection acts

and is complying with the permts' ter and conditions.A copy of a Preparedness, Prevention and Contingency (pPC) Plan is retained onsite.Daily records of waste volumes, disposal methods, etc. are retained onsite.The person or municipality is not in compliance with the conditions of the permt-by-rule or is conducting an

activity that threatens to harm the health, safety or welfare of the people or the environment.

2 28 02.doc Pa e 6

Residual waste (Chapter 287)

The four new residual waste PBR cases are as follows:

Contaminated soil from agricultual practices

Contaminated soil, dredged material or used asphalt

Historic fill

Contaminated soil placed at an Act 2 remediation site

The contamiant levels allowed in soil subject to the PBR are sumaried on the following page(Exhbit 1).

For the four new residual waste PBR cases cited above:

1. Filing is allowed on industrial and commercial properties only except for the PBR for Act 2remediation sites

2. Several standard conditions apply for these PBRs as follows (see regulations for details):

a) Site restrctions; b) prohibitions on the placement of material in waters of thisCommonwealth; c) implementation of erosion and sedientation control planrequirements; d) prohibitions on the use of hazardous waste; e) obligations to providewrtten notice to the Departent of the person beneficially using the material, the amountof material used at a site and the locations of use; and f) obligations to maintain records ofany analytcal evaluations.

3. Subsection 287. 102(a) of the original residual waste regulations must be met. These provisionsare similar to the requirements listed in the footnote on the previous page.

4. Very specific procedures are stipulated for sampling and analysis of the soil to determne if thesoil meets the specified limts. Composite testing is allowed for non- VOCs to save onanalytical testing costs. The number of samples required for determing contamiant levelsare shown in Exhibit 2. Section 287. 11 should be reviewed in detail to learn of othersampling details.

5. Wastes that are placed in accordance with these PBR permts wil cease to be waste as long asthe material remains in place

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EXIBIT 1 - PERMT BY RULE CONTAMNATION LEVELS FOR RESIDUAL WASTES

Permit By Rule Contaminants Limits Leachate Other RequirementsSee Appendix A Analysis See text on previous page (items 2 a th Tables in the reg. for general requirements

Contaminated soil from Lead, arsenic (and Table 4 (based on Direct contact pathways are promptly eliminated atagrcultual practices pesticides if orchard once nonresidential stds) fill sites

existed on the soil)

Contaminated soil, dredged Complete suite of organic Tables 5 and 6 (based TCLP ormaterial or used asphalt and inorganic on residential stds) SPLP

contaminants

Historic fill Complete suite of organic Optional* Optional* Direct contact pathways are promptly eliminated atand inorganic Tables 5 and 6 (based TCLP or fill sites, if soil-to-gw pathway std is not protective ofcontaminants on residential std) SPLP direct contact exposure

Contaminated soil placed at an Complete suite of organic Statewide Health Stds Optional The Notice of Intent (NO!) to remediate must cite theAct 2 remediation site and inorganic (residential or per Act 2 Statewide Health Std. (SHS) as the remediation std.

contaminants nonresidentialNote: sites being remediated to depending on site use) SHS must be based on used aquifers, less than 2 500site-specific standards are not ppm TDS, even if aquifer is classified as non-used.eligible for PBR

Contaminated soil brought to site cannot containcontaminants not already at site (i. , if site s soil hasKepone as non-detect and the imported soil hasKepone ofO. t mg/g, then a PBR does not apply).

Deed notice is required if nonresidential statewidehealth standards are used.

Limits for TCLP (Toxicity Characteristic Leaching Procedure) are set in 288.623(a)

Limts for SPLP (Synthetic Precipitation Leaching Procedure) are set in Appendix A , Tables 5 and 6

* For Historic Fil, there are two options for determning whether contaminants meet the PBR nwnericallimits:Use residential soil-to-groundwaterpathway standards listed in Tables 5 and 6If the soil-to-groundwater standard is violated, use leachate procedure. Ifleachate test passes, then PBR is still allowable.

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EXHIBIT 2 - SAMPLING REQUIREMENTS FORSAFE FILL DETERMINATION

Soil Volume No. ofVOC Samples

Less than 125 cu yd 2 composites of 4 2 discrete samples from Non- VOCs: Conc. -csamples each highest PID readings half of values listed

in Appendix ATables 1 , and 3.

VOCs: Conc. values listed inTables 1 , and 3.

125 to 3 000 cu yd 3 composites of 4 3 discrete samples fromsam les each hi hest PID readin s

Each add' l 3 000 cu yd 3 composites of 4 3 discrete samples fromsam les each hi hest PID readin s

Less than 125 cu yd 8 discrete samples 2 discrete samples from Both VOCs andhighest PID readings Non-VOCs:

. 75% of values Tables 1 , 2 , and 3

. Noone value;: twotimes Tables 1 , 2and 3

125 to 3 000 cu yd 12 discrete samples 3 discrete samples fromhi hest PID readin s

Each add' l 3 000 cu yd 12 discrete samples 3 discrete samples fromhi hest PID readi s

Steve Lester - Safe Fill Summa 2 28 02.doc

Part 2 - NJ soil reuse requirements

The following is an excerpt from the NJ regs that mention the requirements for submitting a SoilReuse plan as part of a Remedial Action W orkplan. In addition, see the following lin for moreguidance: htt://ww.state.nl.us/dep/ sIp/regs/ soihmide/ s gd5 3-66. pdf.

(b) If contaminated soil wil be reused at a site, an evaluation pursuant to N. 7:26E-6.4(d) shall be conducted and a soil reuse proposal shall be submitted to theDepartment as part of the remedial action workplan. The soil reuse proposal may alsobe submitted at any time during the remediation process , as appropriate. At a minimumthe soil reuse proposal shall include:

1. A description of the originating site or area of concern by the submission of aremedial investigation report or, as applicable, a remedial action report for thecontaminated soil. If the reports were previously submitted to the Department , asummary of the report may be submitted;842. A determination in accordance with N. C. 7:26G- 1 as to the waste classificationof the soil , including any supporting data requested by the Department; and3. A detailed description of the proposed reuse and conditions at the site of reuseincluding:

i.The location of the site including state , county, municipality, block and lot numbers;ii. The volume of soil to be reused;iii. Identification of the specific location on the site where the reuse wil be conducted ona scaled map(s) pursuant to N. 7:26E- 2(a)3i through iii;iv. The depth to ground water on the receiving site , including the method ofdeterm ination;v. The receiving site use;vi. A discussion of the performance , effectiveness and reliability of the proposed reuseand any potential negative impacts to human health , safety or the environment as aresult of the reuse; andvii. All other applicable data and information required pursuant to (a)8 through 15 above.

(c) If historic fil material wil not be treated or removed from the site , engineering andinstitutional controls shall be proposed in accordance with the Department's proceduresin effect at the time of proposal , provided that the information is pursuant to N.7:26E- 8(c)14 and the following documentation is presented in the remedial actionworkplan:

1. A statement that all other areas of concern located in the historic fill material areahave been addressed as separate areas of concern. Remedies for any such areas, notmeeting the definition of historic fill material , shall be selected pursuant to N.7:26E-

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Lesson Learned - Public Outreach forNJDOT Categorical Exclusion Document

On 1/31/02 , Angelo Waters wrote the following e-mail to Joe, Thorn and Jennifer:

In receiving comments back on the Rt. 44 CED it has come to my attention that inaddition to the general public

, "

interested parties" should also be contacted as part of thepublic outreach portion of the CED.

David Mudge of NJDOT said this can often be as simple as a documented telephone call.For larger projects a certified letter or meeting should be considered. This process is notlisted as one of CED checklist items and is often overlooked.

David supplied me with a sample list of contacts and a brief wrte-up of Section 106 ofthe Historic Preservation Act (public outreach). Let me know if you would be interestedin obtaining a copy.

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a.

URBAn.

Urban Engineers, Inc.530 Walnut Street, 14th FloorPhiladelphia, P A 19106(215) 922-8080 Fax:(215)922-8082E-mail: tgmay(furbanengineers.com

October 5 , 2001

To: Environmental Staff

From: Thomas G. May

Subject: PPC Plan

In conducting a task order for PennOT under the TLI SEMP contract, Joe Musil developed inormationon PPC plans that may come in handy if we need to prepare one for PennOT or another public orprivate client.

A PPC plan needs to contain the following elements:

A. Description of Facility

B. Description of How Plan is Implemented by Organiation

C. Spill Leak Prevention and Response

D. Countermeasures

E. Emergency Spil Control Network

F. Storm Water Management Practices

G. Sediment and Erosion Prevention

H. Additional Requirements for EPCRA, Section 313 Facilities

1. Certification Requirements for Non-Storm Water Discharges

1. Signatory Requirements

A template for preparing a PPC plan (obtained from Penn Tech service) is presented in the followingpages. Additional guidance is provided in Guidelines for the Development and Implementation Environmental Emergency Response (December 1997) and is available on the following DEP web site:httD://ww.deD.state. Da. us/deD/subiect/all final technical auidance/bwam/362-2200-001.Ddf

This memo and attached template is being saved on the t drive s Lessons Learned directory (PPCPlan. doc).

Steve Lester - PPC Plan.doc

Preparedness, Prevention and Contingency Plan

for

Inc. is a

. Many of s products / servicesactivities include

I. Overview Background

1. Facilty and Industrial Activity Description

s facilties consist of buildings and . Thesebuildings are identified on the attached sketch as structures A, B & C. Structure A is used primarily asfinished good storage and staging for shipping. A small manufacturing area is located at the one end ofthe building. It consists of jigs for precisely drillng holes for pieces that are to be assembled on-site.Assembly is performed here as well. At the other end of Structure A is the company s offces. Accounting,sales, purchasing and general management work out of these offces. An unpaved parking area forvisitors and employees is located nearby.

Structures B & C are located across the road and at a higher elevation from Structure A. Structure B is themain manufacturing facilty. This facilty houses a number of millng machines , a raw material staging area,a finished product staging area and work in process staging area. Structure C is a three sided storagestructure for storing raw materials (hardwood lumber). A 250 gal. gasoline storage tank for powering

s fork trucks is located on the West end of this building.

This facility is located in Township, County near the community . It is situated on _acres along Rd. Its location is further

identified by _

-.'

West latitude and _0 -

' -.'

North longitude. It is marked on the attachedUSGS map, 15' Quadrangle.

2. Existing Emergency Response Plans

To date , there have been no emergency response plans. The purpose of this plan is to comply with PPCplan requirements in the stormwater regulations.

3. Material and Waste Inventory

performs the following operations: Note inwhat buildings what operations are preformed. Note where hazardous materials and petroleum productsare stored. State what else might be important from an emergency planning / preparedness perspective.

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The following chemicals are used on-site:

Common Name Trade NameManufacturer

Gasoline

Material Safety Data Sheets of the chemicals are attached (Appendix I) and are incorporated byreference.

a. Processes

Note processes that could have an environmental impact.

b. Wastewater

wastewater is generated on-site.

c. Stormwater

Stormwater comes from building roofs and parking areas. The downspouts from each roof areshown on the attached sketch of the propert and buildings. Drainage from the parking area isnegligible as the lot is not paved. Its composition is course gravel.

The manufacturing processes conducted by do / do not utilze hazardousmaterials. The only hazardous material used or stored on-site is gasoline for powering theforktrucks. Contamination of stormwater is only possible if gasoline escapes the tank duringfueling of the forktrucks or tank refillng

Except for extreme rainfall conditions, it is likely that there is no stormwater created from theparking lot. It typically evaporates or becomes groundwater. Stormwater leaves the roofs by oneof the downspouts (see sketch) and runs off into the swale, from there into theCreek and finally into the River. Oil leaking from cars in the parking lot andgasoline from the forktruck operation are the only two potential sources of pollution on-site.

d. Waste Materials

Scrap hardwood , sawdust and steel banding are the waste materials generated on-site. Most ofthe scrap wood is removed by local residents for use as kindling. The remainder is burned on-site.The sawdust is used by nearby farmers as animal bedding. The steel banding from shipping thelumber to the site is cut up into 4-6 inch strips and shipped to a scrap dealer for recycling.

e. Pollution Prevention

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No wastewater is generated at the facilty. No pollutants are generated on-site. Gasoline is storedand used on-site, posing the only threat to the environment. Pollution prevention measuresinvolve proper storage and handling of the gasoline , care in fueling the forktrucks and training ofemployees.

4. Pollution Incident History

No pollution incidents have occurred to date.

5. Implementation Schedule

New provisions will be implemented upon acceptance of the plan.

II. PPC Plan Implementation

1. Organizational Structure

In the event of the need for emergency response, Milworks ' President , Brad Lauver, wilassume the duties of Emergency Response Coordinator. Plant personnel shall inform the coordinator atonce of a hazardous or potentially hazardous situation.

The coordinator will direct company employees to perform the tasks identified below. He wil determine theneed for outside assistance and request it or direct others to request it when he determines that it isrequired. Since this is a small plant, since there are few hazardous materials stored on-site and since theyare all in moderate quantities , an extensive emergency organization is not required.

The Emergency Response Coordinator has the authority and responsibility to prepare and implement thePPC Plan. In the event of an emergency, the coordinator wil direct company employees to perform thetasks identified below. He wil determine the need for outside assistance and request that assistance ordirect others to do so. Since gasoline is the only hazardous material stored on-site, a more extensiveemergency organization is not required.

The coordinator shall:Maintain a materials inventory,Maintain up-to-date records of materials used and wastes generated and the Material Safety Data(MSD) Sheets for each materialIdentify potential spil sources and minimize each source s potential to cause a pollution incident(risk assessment and risk control),Receive all communications about hazards and potential hazards from plant personnel,Establish training programs for plant personnel and implement training.

2. Emergency Coordinators

will be the emergency coordinator. He can be reached at:

e Lester - PPC Plan.doc Pa e 5

-work Ph:

ext.

home

3. Duties and Responsibilties of Emergency Coordinators

The Emergency Response Coordinator shall become and remain intimately familar with the planimplement the plan or assist in its implementation. Included in its implementation is: 1) its review andmodification as warranted, 2) employee training, 3) notification of local emergency agencies including thefire company, emergency medical services, emergency management agency, police, hospital and certainstate agencies and 4) revise the plan when warranted (e.g. when the facilty is modified significantly, theoperation and materials used has changed or when the plan has been used and portions are found to beinadequate). The coordinator shall provide all agencies that request one with a copy of this plan.

In the event of a spil , the emergency coordinator will direct plant employees to contain the spil usingappropriate materials (straw bales, sand bags , etc. ). When contained , an action plan wil be developed toclean up the spil. If emergency personnel are called in from outside, they wil be in charge of the clean-upwith input provided by the emergency coordinator.

In the event of a fire, the coordinator wil call the fire company and turn emergency response over to thefire chief. The coordinator shall remain nearby to assist with information or other personal assistance asrequired by the fire chief. Until the fire company arrives on-site, the emergency coordinator wil direct plantpersonnel to take appropriate action.

In the event of a stormwater emergency, the emergency coordinator wil direct plant employees to takeappropriate action using the best available materials (straw bales, sand bags, etc.). If the plant is indanger of flooding, call emergency personnel to assist in protecting plant assets and in evacuating thearea to prevent injury or loss of life. The coordinator shall also contact all emergency agencies on the localand state level and the National Response Center if appropriate. When placing the call, the followinginformation shall be provided:

a. Name of the person reporting the incidentb. Name and location of the person reporting the incidentc. Phone number where the person reporting the incident can be reachedd. Date, time and location of the incidente. A brief description of the incident, nature of the materials and/or wastes involved, extent of

any injuries , and possible hazards to human health or the environmentf. The estimated quantities of materials spiled , andg. The extent of contamination of land, water, and/or air.

During an emergency, the emergency coordinator must take all reasonable measures necessary toensure that fire , explosion , emission or discharge do not occur, reoccur or spread to other materials orwastes at the facilty. These measures shall include , where applicable, stopping manufacturing processesand operations, collecting and containing released materials or wastes, and removing or isolatingcontainers.

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When the situation has been stabilized , the emergency coordinator wil develop an action plan to clean upthe emergency s aftermath , have wastes, contaminated materials and/or contaminated soils removedtreated or disposed of. If emergency personnel are called in from outside , they wil , at their option , developthe plan with the input of the coordinator and wil be in charge of the clean-up.

Before resuming plant operations, the emergency coordinator must insure that no material or wasteincompatible with the emitted or discharged residues is processed, stored, treated or disposed of untilclean-up procedures are completed.

Within 15 days after the incident, the installation must submit a written report on the incident to PA DEP.The report shall include the following:

a. Name, address and telephone number of the person reporting the incidentb. Name address and telephone number of the facilty,c. Date, time and location of the incidentd. A brief description of the incident and the its cause,e. A description and estimated quantity of contaminants and how they affected the environmentf. A description and estimated quantity of recovered wastes generated as a result of the incident

andg. A description of the actions the facility intends to take to prevent a similar occurrence in the future.

4. Chain of Command

All employees wil report to the emergency coordinator. In the event that work teams are formed , each wilbe appointed a leader for the purposes of completing the assigned tasks. That leader wil report to theemergency coordinator. If outside emergency response is called in , the response team leader (e.g. firechief) wil be in charge with the emergency coordinator reporting directly to that individual. When theemergency is ended , the usual plant organizational structure wil be returned.

II. Spil/Leak Prevention and Response

1. Pre-release Planning

Planning involves reviewing activities conducted on-site, anticipating all possible occurrences of accidentsspils , overflows , storms , floods or fire , anyone of which could cause a pollution incident. Planninginvolves taking all of the requisite steps to avoid an emergency and to prepare for one. Having evaluatedall of these things, the following procedures have been developed and shall be followed to avoid anemergency:

1. Handle hazardous materials and wastes in a safe manner2. Close all hazardous material containers tightly when not fillng, emptying or using materials out of

them3. Transport drums , buckets or other movable containers with their lids firmly in place and tightly

sealed,4. Use care in transferring material from one container to another5. Do not pump flammable materials without a ground strap,6. Use care in using hazardous materials; avoid the potential for spills.7. Store drums in secured areas; locate storage tanks in dyked areas,

e Lester - PPC Plan.doc

8. Do not store hazardous materials or wastes outside where they could contaminate stormwater9. Store empty drums in a secure area; do not store outside with the lid off or bung open (residual

materials may be washed out onto the ground causing pollution),10. Maintain appropriate levels of inventory; do not maintain excessive levels,11. Do not store incompatible materials in the same area; have a separate storage area for each12. Do not store raw materials and wastes in the same area; have a separate storage area for each13. Do not store incompatible wastes in the same area; have a separate storage area for each14. Inspect all areas where hazardous materials or wastes are used or stored at least daily; keep a

log of activities and observations15. Take corrective action immediately upon determining that a pollution threatening condition exists,16. In the event that you observe a pollution threatening act, show the individual the proper procedure

and ask him/her to do it that way in the future. Observe him/her doing it correctly to insure thathe/she knows the proper way,

17. Assess the potential for stormwater contamination when evaluating plant procedures (truckloading/unloading, manufacturing, storage, etc.

18. Store salt for deicing indoors or if outdoors, in enclosed and covered areas except when adding orremoving material from the pile (compliance date October, 1995 or sooner).

2. Material Compatibilty

uses no incompatible materials. In the event incompatible materials are used in the futurethey wil be used and stored safely and in separate areas so as to virtually eliminate chemical reactions.

3. Inspection and Monitoring Program

The procedures listed in Section 1 above (Pre-release Planning) shall be followed. Areas wherehazardous materials or wastes are used or stored shall be inspected at least daily. Corrective action shallbe taken immediately upon determining that a pollution threatening condition exists. In the event that apollution threatening act is observed, the individual shall be shown the proper procedure and he/she shallbe asked to follow that procedure in the future. Observe him/her doing it correctly to insure that he/she haslearned the correct method.

At least annually, review all operations to ensure that no changes have occurred that threaten or couldthreaten the environment. Pollution or potential contamination of stormwater originating on-site or passingthrough the site shall be evaluated. In the event any of these evaluations show pollution or potentialpollution , plant operations and this plan wil be evaluated to determine if revisions are required. Allchanges must be implemented within 90 days.

Evaluations shall be properly documented including date, procedure, observations, areas of non-compliance , qualitative and quantitative data , recommendations and conclusions. If non-compliance isobserved , an action plan shall be immediately formulated and implemented. When compliance is believedto have been attained, the facility shall be re-evaluated and compliance documented. All reports shall bedated and signed by the individual conducting the evaluation.

4. Preventive Maintenance

Normal preventive maintenance is performed on s equipment. This has little bearing on

ve Lester - PPC Plan.doc Pa e 8

pollution prevention, as the only equipment operates , the failure of which would or couldpotentially cause a pollution incident, is forktrucks. Other than gasoline, no liquids are used on-site. Nowastewater is generated. No wastewater or stormwater treatment is done on-site. Stormwatercontamination is only possible if there is a gasoline spill.

5. Housekeeping

maintains a clean operation. Sawdust and mil shavings are swept up routinely and aresent off-site for animal bedding. Lumber, work in process and finished products are stored neatly. Noliquids are used in the manufacturing process. Other than gasoline , no hazardous materials are used thatcould contaminate stormwater or groundwater. Housekeeping procedures have little bearing on pollutionprevention.

6. Security

Security is only an issue with regard to vandalism , robbery and fire protection. It is not an issue related topollution prevention or emergency response. Security precautions include locked entrances and nightlighting.

7. External Factor Planning

The following external factors are taken into consideration in this plan:

Flood-In the event of a flood, precautions wil be taken to minimize the chance of injury or loss of life.The buildings wil be evacuated. Employees shall be directed to a safe area and asked to stay there. Ifthere is adequate warning, all appropriate preliminary measures shall be taken. These measures includeshutting down the operation , turning off the power at the main panel , giving instructions to employeesremoving threatened vehicles from the parking lot and securing the buildings. No pollution incident ispossible. No special procedures are required to prevent one.Power Outage-A power outage wil halt production operations , but wil not cause or contribute to apollution incident. No special planning is required.Strike-In the unlikely event of a strike , no actions by employees or others would cause a pollutionincident. No special planning is required.Snowstorm-A snowstorm could prevent employees from getting to work , cause power outages , causelost production and lowered efficiency or structural damage to buildings. It wil not cause a pollutionincident. No special planning is required.

8. Employee Training Program

Employees are routinely trained in their job responsibilties and the specific tasks required to do their jobwell. Included is the proper procedure for fueling forktrucks. In the event that a fuel tank were overfloweda pollution incident could result. Training to react promptly to a fuel spil is provided , proper notificationprocedures are conveyed to all plant personnel and response training is also provided.

IV. Countermeasures

1. Countermeasures to be Undertaken by

Steve Lester - PPC Plan.doc Pa e

In the event there is a spill would respond by

If this action is ineffective , a container wil be used to collect the leaking fuel. Every effort wil be made toprevent or minimize soil , groundwater or surface water contamination.

Were fuel to leak , spill or flow onto the ground , it would first be contained, then cleaned up. (With 250gallons being the maximum stored at anyone time , the chance for a major pollution incident is remote.Containment would be accomplished with straw, commercial absorbent materials (OiIDry, Kitt Littervermiculie, etc.) or temporary dykes. Upon achieving containment, clean-up shall commence. Clean-up islikely to be accomplished with shovels and drums, placing the contaminated material or soil in drums foroff-site disposal.

2. Countermeasures to be Undertaken by Contractors

No countermeasures are assigned to contractors. In the event contaminated soil were collected for off-sitedisposal , a contractor would be utilzed.

3. Internal and External Communications and Alarm Systems

In the event of an emergency or pollution incident, the emergency coordinator shall be notifiedimmediately. The emergency coordinator shall make an immediate determination as to the need to call inemergency response organizations/personnel.

If the emergency coordinator is on-site , communication wil be verbal and in person. If the coordinator isoff-site, communication wil be by telephone. If off-site personnel are to be contacted, this will be done byphone. On-site communications by emergency response personnel wil be by walkie-talkie. There are noalarm systems on-site.

4. Evacuation Plan for Facilty Personnel

In the event of an emergency requiring evacuation of personnel , evacuation shall be done in an orderlymanner. Personnel shall proceed to the nearest unobstructed exit, pass through it and congregate at asafe distance from the buildings and from the source of the emergency. In the event of injury, fellowemployees shall assist the injured person to the exit and arrange for medical attention.

5. Emergency Equipment Available for Response

The following emergency equipment is available on-site:Absorbent materials,Emergency first aid kitsExhaust fansFire extinguishersFlashlights,Forklift

Fuel supply,

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LaddersSubmersible pump,Toolbox/tools.

If used , fire extinguishers shall be refiled or replaced within 3 working days. First aid kits wil be refiledperiodically.

V. Emergency Spil Control Network

1. Arrangements with Local Response Agencies

has invited representatives from the local volunteer fire company and ambulanceassociation to tour its facilties. Each has reviewed s ' operations , has become familar withthe facilty, where people would normally be working, emergency exits, potential emergency responseneeds and facilty documentation.

The emergency agencies and contacts are listed in the following section.

2. Notification List

In the event of an emergency, one or more of the following individuals or agencies wil be notified:

Individual/AaencvEmergency Coordinator

Location Phone

-work800-

ext.

home717-

717-Volunteer Fire Co.

717-Ambulance Assn.

717-Police

Hospital 717-

County Emergency 717-

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Management AgencyPOC:

County Health DepartmentCo.

717-

POC:

PA DEP Regional OfficeOffice Ans. Service 717-

If no answer: 800-

or 717-POC:

PA EmergencyManagement Agency

717-

PA Fish Commission 717-

National Response Center 800-

3. Downstream Notification Requirement for Storage Tanks

has no product or waste storage tanks. The fuel tank is less than 275 gallons. Nodownstream notification is required.

VI. Stormwater Management Practices

1. Stormwater Management

Since all operations are dry (no effuent) and are conducted indoors, no special stormwater managementpractices are required and none provided. There is no contact between stormwater and industrialactivities. The only potential contact with hazardous materials is from the fueling of forktrucks and therefillng of the on-site fuel tank. In the event of a spil during either operation , the emergency response planwould be initiated with appropriate action to first, stop the source of the pollution , second, contain the spiland finally, to clean it up. See section IV- entitled Countermeasures-Countermeasures to beUndertaken by for details.

2. Management Practices

Swales have been constructed on-site to control the stormwater and to direct it to theCreek. This measure minimizes the tendency for flooding, contact with hazardous materials, surface andgroundwater pollution , soil contamination and propert damage.

The countermeasures described above are also part of these practices.

3. Testing Certification

Steve Lester - PPC Plan.doc

Certification that stormwater testing has been conducted is not possible as stormwater testing is notfeasible. Site topography does not lend itself to sampling, representative sampling would not be easy toachieve and, most importantly, there are no pollutants to test for as none are utilzed in the manufacturingprocess.

Instead , a certification is provided that no hazardous materials are utilzed in the manufacturing process,that no hazardous wastes are generated and that the only hazardous material stored and used on-site isgasoline and that it is properly managed, employees are properly trained in the fueling process andappropriate response measures are in place in the event of a pollution incident.

VII. Sediment and Erosion Prevention

The propert is located on an uneven terrain near the Creek. In the event of aheavy rain , significant run-off can occur. The run-off enters the swales and from there enters the creek.

The slopes have been planted in grass and other erosion resistant vegetation to minimize erosion. Theswales have rocky bottoms for the same purpose. The grading done during building construction directsstormwater that would otherwise run onto the propert and toward the buildings away from them andtoward one of the swales. Stormwater from the buildings ' roofs is directed away in the same manner.

VII. Additional Requirements

does not use or manufacture any toxic materials as defined in Section 313 of TheSuperfund Amendments and Reauthorization Act of 1986 (SARA). No additional requirements apply underthis section.

IX. Certification for Non-Stormwater Discharges

Certification that stormwater testing has been conducted is not possible as stormwater testing is notfeasible. Site topography does not lend itself to sampling, representative sampling would not be easy toachieve and , most importantly, there are no pollutants to test for as none are utilzed in the manufacturingprocess.

Instead, the following certification is provided:

As an offcer of Inc. , I certify that no hazardous materials are utilzed inthe manufacturing process, that no hazardous wastes are generated and that the only hazardousmaterial stored and used on-site is gasoline and that it is properly managed employees areproperly trained in the fueling process and appropriate response measures are in place and wilbe used in the event of a pollution incident.

As an officer of , Inc. , I certify that the representations made herein arecomplete and accurate to the best of my knowledge.

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- President

Date

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Appendix A

US Geologic Survey Map

Quadrangle

, Inc.

ID#-None issued to date

USGS 15' Quadrangle0 -

-.'

West latitude,0 -

-.' North longitude

Township, Co.

Storage Tanks-

Surface drainage-swale(s) toCreek to River

Groundwater Sources / Wells-

Downstream Surface water Intakes-