The Removal of Regulated Wastes March 2000 Office of Construction Administration An Equal Opportunity Employer

Handbook for The Removal of Regulated Wastes March 2000 Ohio DEPARTMENT OF TRANSPORTATION Office of Construction Administration An Equal Opportunity Employer

Foreword This handbook is devoted to the proper inspection and contract administration of the disposal and/or remediation of regulated wastes and underground storage tanks during construction projects. This handbook also covers other wastes such as construction and demolition debris, landscape waste(buried or burned on site), slag, scrap tires, rail road ties, and asbestos pipe. Other wastes such as fly ash, bottom ash, foundry sand petroleum contaminated soil glass and tires may be used as a recycled materials in fills in the near future. It is to serve as a guide to the Project Engineers and the Project Inspectors in the performance of their duties in administering the contract for the Department. Personnel assigned to the inspection should have a thorough knowledge of the applicable specifications and regulations pertaining to the above. This handbook does not include any information regarding the handling or removal of paint waste, asbestos or other regulated items on bridges or any other removals on bridges. These processes are covered by the under the Structures Engineer. The instructions herein are not intended to alter or replace the specifications or laws but to supplement them and to serve as a reference to fulfill the requirements for the inspection of the work. This handbook should be used in conjunction with the Hazardous Waste Management Program Manual(HWMPM) and the handouts and manuals received in the 24 or 40 hour Hazardous Waste Operations and Emergency Response (HAZWOPER) training or the 8 hour HAZWOPER refresher courses. The old Bureau of Construction had interim guidelines that dealt with hazardous waste removal on construction sites. Those guidelines primarily dealt with the discovery of unknown contamination on ODOT construction projects. Several other I.O.C.s were written to clarify different issues surrounding this work. Since the time of the original guidelines, detailed plan notes have been developed to help the projects remove known contaminated materials on construction projects. This handbook combines and updates all of these documents and incorporates the new De-Centralized ODOT organization herein. Randall E. Morris, P.E. Construction Soils and Drainage Engineer Office of Construction Administration 614-644-6638 file W: hazard\handbook2000pdf 1

Introduction The Department has experienced problems administrating regulated waste and underground storage tank removal projects. The main cause of these problems are the lack of understanding of the regulations that govern these materials and the infrequency that these items are included in highway contracts. The improper disposal and management of regulated materials can create substantial construction delay problems and potential future liability for the Department. The Ohio Department of Transportation will always first seek to avoid any major contamination sites during the preliminary development process. This is accomplished by preliminary project screening followed by an environmental site assessment. Avoidance is not always possible and many projects will have the regulated waste and/or UST s included in the normal construction project contract documents. In other cases regulated wastes or UST s may be discovered during construction. The Department has about 90 projects in design or sold that will require the disposal or remediation of regulated wastes; such as hazardous wastes, solid waste or petroleum contaminated soil. A list of these projects are shown in Appendix B. The projects listed in appendix B projects contain mostly regulated material(such as solid wastes) but rarely contain hazardous material removals. These projects are labeled under 4 categories; Nonregulated, Petroleum Contaminated Soils, Solid Waste and Hazardous Waste. As the data indicates it would be a rare occasion that hazardous waste would be removed on our construction projects. Regulated wastes for the purposes of this handbook will be defined as a hazardous waste, solid waste, petroleum contaminated soil or any other regulated material. For further explanation about hazardous waste classifications, types and characteristics see the Hazardous Waste Management Program Manual or your Hazardous Waste Training Manuals. This handbook does not expand on the technical environmental details or issues explained in these other manuals. This handbook should be used as a reference to other manuals or methods used to obtain expertise in the technical environmental details and issues. This handbook is devoted to the proper contract administration and inspection of the removal, disposal or remediation of regulated waste and underground storage tanks on highway construction projects. 2

Table of Contents Chapter Description Page Forward 1 Introduction 2 100 Responsibility 4 200 Training 6 300 Site Specific Health and Safety Plan Requirements 8 400 Regulated Wastes Designated for Removal in the Contract Documents 10 500 Regulated Wastes Found During Construction 14 600 Underground Storage Tanks 17 700 Other Wastes 21 800 Documentation Requirements 27 Appendix A Typical Plan Notes 31 Appendix B List of Regulated Waste Projects 42 Appendix C Non-Hazardous Manifest 44 Appendix D Division of State Fire Marshall BUSTR Fact Sheets 45 3

100 Responsibility 101 Project Engineer The person in charge of the work on the project is called the Project Engineer. A Supervisor or an Inspector may run the project on a daily basis depending on the district level of staffing for the project. The project engineer will at least check in on the project and make any engineering decisions on the project. 101.1 Administering the Contract The responsibility to effectively administer all aspects of the work on the construction project is the Project Engineer s. He/she will familiarize themselves with the specifications, the contract and this manual to perform their duties. The Project Engineer will make interpretations of the contract documents and this manual to the supervisors or project inspectors and insure that trained inspectors are inspecting the work. 101.2 Reporting of Significant Changes The Project Engineer is responsible for reporting any significant deviations in the contract documents to the District Construction Engineer or the County Manager. The Project Engineer has the authority to order the Contractor s personnel and the environmental consultant to perform as directed work in all situations within the contract limits. This authority is tempered with a great deal of responsibility for their actions. If the Project Engineer orders work contrary to the recommendations of the environmental specialist or the environmental contractor, then the Project Engineer may become personally liable for their actions. The Project Engineer must be sure that their instructions are not contrary to any laws or regulations that govern the work before making any final decision. 101.3 Health and Safety Responsibilities The Project Engineer is responsible for the health and safety of the inspection forces. Additional health and safety responsibilities are listed below: Ensures that inspections are being performed on the project with adequate personnel, equipment, or resources to complete the inspections safely. Ensures that telephone communications between the department inspectors and emergency response personnel is maintained. 4

Ensures that all inspectors are adequately trained and qualified to work at the site. Reviews the Contractors Site Specific Health and Safety Plan (SSHSP), as it pertains to the Department inspection forces. Provides oversight of the Contractor s operations as it pertains to the Contractor s SSHSP. Reviews the SSHSP with the inspectors. When there is a concern about the integrity of the SSHSP, the Project Engineer should consult the Construction Engineer or the Construction Soils and Drainage Engineer. The project may elect to have the SSHSP reviewed by an environmental consultant by third party billing through the contractor or by the District Task Order Contract. Serves as the primary contact to review health and safety matters that may arise on the project as it pertains to the department inspection forces. Informs the inspectors of revised or new safety protocols for the field operations. Informs the inspectors of revisions to the SSHSP. Reviews accident reports and the results of the inspections. 102 Project Inspector The Project Inspector is responsible for the detailed inspection of the work and to follow the directions given by the Project Engineer and the SSHSP. 103 Contractor s Responsibilities The Contractor is responsible for prosecuting the work in accordance with the plans and specifications and for the safety of the his or her crews. 104 Construction Soils and Drainage Engineer The Construction Soils and Drainage Engineer in the Office of Construction Administration is responsible for giving technical contract administration advise to district construction personnel, updating this manual and performing QAR s. 5

200 Training 201 General Where the disposal of regulated wastes is necessary during construction, it is required for the District Construction staff to have some knowledge beyond the plan note requirements in order to make appropriate and legally correct decisions when facing actual field mandated changes in the plans. Training regarding the federal law known as the Resource Conservation and Recovery Act (RCRA), the federal law which lists the requirements for most regulated wastes, is available through the Office of Facilities Management in Central Office(614-644-8178), Bureau of Workman Compensation, Division of Safety and Hygiene(800-644-6292) or through a variety of private training sources. The private training may be charged against the project on third party billing through the Contractor. Nothing in this handbook requires ODOT project personnel to enter a hazardous waste site without the consent of the employee. All of the regulated waste removal work is performed by the Contractor and no ODOT personnel should actively participate in this work. The majority of the regulated waste removal operations on highway construction projects consists of the removal of solid waste or petroleum contaminated soil. The minimum training requirements listed below should be observed for all regulated waste or underground storage tank removal projects. 202 Project Engineers If the Project Engineer is in the contamination zone for prolonged periods or on a daily basis, then the 40 hour HAZWOPER training is required. If the Project Engineer is not participating in the actual hazardous waste work or only occasionally visits the contamination zone, then 24 hour Hazardous Waste Operations and Emergency Response (HAZWOPER) training is required. A yearly 8 hour annual refresher course is required for both 24 hour and 40 hour HAZWOPER trained personnel. 203 Project Inspector All personnel who regularly participates or inspects regulated waste operations must be 40 hour HAZWOPER trained. A yearly 8 hour annual refresher course is required. The project inspector for the removal of an underground storage tanks should be an Underground Storage Tank Inspector certified by the Bureau of Underground Storage 6

Tank Regulations(BUSTR). These inspectors have a photo identification, with a list of responsibilities and an expiration date. The project should check this identification. 204 Specialized Inspection Additional or specialized inspection may also be employed by hiring environmental consultant inspectors through the Environmental Site Assessment Task Order Contract. The District's Office of Planning and /or Environmental staff can help the project obtain these services. The procedure is further explained in this handbook in the section 504, Regulated Wastes Found during Construction. 205 Medical Monitoring Medical monitoring is required for employees working on hazardous waste projects who are exposed to contaminants above the permissible exposure limits (PEL) for more than 30 days per year, wear a respirator for 30 days or more per year or employees who are injured or become ill due to exposure to hazardous substances. OSHA 29 CFR 1910.120 covers this requirement. The SSHSP, the District Safety Representative or District Hazardous Waste Coordinator should be consulted to determine the need for medical monitoring of an employee. Medical monitoring is rarely needed due to the type of the contaminates(solid wastes) normally encountered on highway construction projects. 206 Changes to the Training Requirements The SSHSP may alter the above requirements because of the particular contaminates on the project. Review Chapter 3 of this Handbook and the project SSHSP. 207 Training and Medical Records All training and medical records shall be kept in accordance with sections 1105 and 1106 in the Hazardous Waste Program manual (HWMPM). 208 Confined Space Training Confined Space and Trenching and Excavation Safety training can be arranged through the District Training Staff. This training is free through the Bureau of Workman Compensation at 614-466-5563. See the on line training under Pipe Construction on the Construction Administration area on ODOT s Web site. 7

300 Site Specific Health and Safety Plan Requirements The Contractor is required by OSHA and the contract documents to have a Site Specific Health and Safety Plan (SSHSP) when working within the exclusion or contamination zones of a construction project. Depending on the material contents of an underground storage tank, these exclusion zones may include the areas around underground storage tank removal operations. The Contractor is responsible for the health and safety of their forces. The Contractor is required to have the SSHSP available at the project site for inspection. In no case will the Department accept or approve a Contractor s SSHSP. Under CMS 105.11, the Contractor is responsible to provide access to the work to perform the inspections. The Contractor cannot restrict the inspection of the work when the inspection forces meet minium training requirements of the SSHSP. The Project Engineer is responsible the health and safety of the inspection forces ( See section 101.3 of this handbook). The Project Engineer shall review the Contractors SSHSP to note how it affects the inspection of the work. Based on this review the Project Engineer will determine whether department forces or consultant forces will inspect the work. If consultant inspectors are used the consultant will be responsible for the health and safety it s own employees. Note: When there is a concern about the integrity of the Contractor s SSHSP, the Project Engineer should consult the Construction Engineer or the Construction Soils and Drainage Engineer. The project may elect to have the SSHSP reviewed or a new SSHSP made by a qualified environmental consultant by using third party billing through the contractor or by the District Task Order Contract. 301 Minimum Contents of the SSHSP The SSHSP will contain the following information: 1) Safety and Health Risk or Hazard Analysis. 2) Employee Training Assignments. 3) Personal Protective Equipments Requirements. 4) Medical Surveillance Requirements. 8

5) Frequency and Types of Air Monitoring. 6) Site Control Measures. 7) Decontamination Procedures. 8) An Emergency Response Plan. 9) Confine Space Entry Procedures. 10) Spill Containment Program. 302 Obeying the SSHSP Requirements All construction personnel, including ODOT project personnel will work under and obey the requirements of this SSHSP when inspecting the work. The project personnel should thoroughly review the SSHSP to become familiar with all the aspects of this document. All ODOT personnel entering the contamination zone must wear the personal protective equipment(ppe) listed in the SSHSP. The training and equipment may be obtained from the District Safety Representative (See section 206 in the HWMPM). If the required equipment and training are not available to ODOT personnel, then this training can be paid for under third party billing through the contractor. 303 Absence of a SSHSP In the absence of a project SSHSP, the Project Engineer should contact the Construction Engineer to determine the need for a SSHSP. There will be instances where SSHSP will not be required. Some solid waste operations will generally not require a SSHSP. 9

400 Regulated Waste Designated for Removal in the Contract 401 General Through environmental site assessment in the preliminary development process, most hazardous waste sites can hopefully be avoided. When this is not the case, there will be plans or notes in the contract to instruct the project personnel how to safely remove, cap or remediate the contaminated material. Some typical plan notes are attached in Appendix A. Projects involving the removal of regulated material quickly become complicated from an administrative perspective. The District Planning and Production staffs should coordinate the plan notes and specialized requirements for each project with the District Construction staff to ensure that the construction inspection staff, including the Project Engineer, understands why the special notes are in the plans and what special administrative requirements are necessary. Time should be allotted to develop contracts for outside environmental inspectors if necessary and to determine if specific training is needed for ODOT inspectors. Construction projects which involve complicated remediation work that requires a major amount of specific equipment, project staff or time should be separated from the highway construction project to avoid overly complicating the project. Proper management and disposal or remediation of regulated waste and UST s are essential to prevent future liability for the Department. The Contractor is responsible for the safe removal of the regulated waste. The project personnel are responsible to control the Contractor s work in accordance with the contract documents and the applicable laws and regulations. 402 Reference Material for Regulation Requirements The Hazardous Waste Program Manual is an excellent reference to help the project personnel to familiarize themselves with the regulation requirements and the wastes types, characteristics and generation requirements. The 40 hour or 24 hour HAZWOPER training manuals should also be consulted when dealing with these regulated wastes. 403 Plan Notes The plan notes and/or the environmental site assessment reports are available to the project construction personnel to help familiarize themselves with the type of 10

contamination to be encountered on the project. These reports should be available through the district planning or production or through the office of environmental services in central office. The specialized plan notes may require department or consultant environmental inspectors to field screen samples, and analyze soils excavated from areas of environmental concern. Contractors may be required to stockpile, containerize or dispose of contaminated soils. The plan notes should allow the project to efficiently manage the disposal of the regulated wastes and/or UST s encountered on the project. The plan notes will outline who is responsible for what operation on the project. The Project Engineer should review the plan notes before the Contractor starts work. The following is a general outline of responsibilities. 404 Pre-Excavation Checks The regulated wastes are usually located on the plans. Work can begin in these areas once the Project Engineer is satisfied that all of the following are complete; The SSHSP is present on the project. The Department has appropriate environmental inspectors. The Contractor has the appropriate work force to prosecute the work. The Contractor has set up the appropriate zoning as noted in the SSHSP. The zoning should include but is not be limited to all of the following; Contamination Zone, Decontamination Zone and the Safe Zone. These areas are required to be secured at all times. These zones are usually separated by construction fence. 405 Excavation The contamination areas are some times marked in zones designated as hazardous, solid or other waste classifications. This gives the project an insight into the general classification of the material in the contamination zones. This classification is generally not used for final disposal. The environmental inspector may field screen the regulated material prior to the stock piling but all materials are stockpiled and tested prior to the final disposal of the material. In some cases, and with the permission of the regulatory agency and the district level environmental personnel or as allowed by the plan notes, the material may be allowed to 11

be excavated and directly placed in trucks for disposed to the landfill. This may require the additional testing of the excavation area. Substantial savings can be obtained when changing to this method on the project. Note: The plans generally call for the removal of enough material to build the highway. Unless otherwise called for in the plans the Department does not clean up all the regulated material in the right of way. 406 Temporary Storage The contract documents will give general details about the temporary storage methods. The Project Engineer should review the Contractor s proposed storage method and determine if the proposed method meets the intent of the plans. The project should review the storage locations daily to ensure the work is progressing satisfactorily while the work is in progress. A sample inspection form is in the HWMPM in appendix k. When the work is not in progress all storage areas must be inspected weekly as per section 507 in the HWMPM. 407 Material Sampling The contract or plan may require the state s environmental consultant or Contractor s environmental specialist to test the regulated waste after the regulated waste is stock piled. The testing amount and location will be detailed in the plan or determined by the environmental consultant. No ODOT employee should be testing or sampling hazardous waste material. This should be done by an environmental consultant. Any other testing required by the landfill for disposal purposes is the responsibility of the Contractor. The Contractor is required to give all the testing results to the project. The testing results shall be kept in accordance with section 1105 in the HWMPM. 408 Evaluation Once the material is tested and the results are known, the material may be classified into a regulatory category such as; hazardous waste, solid wastes, petroleum contaminated waste, special or non regulated wastes. The material may be shipped to the appropriate landfill or onto other areas of the project if allowed. 409 Manifesting 12

The manifest documents must be filled out and completed prior to the disposal of any hazardous waste material. The manifest documents are prepared by the Contractor and the Project Engineer signs the documents for the Department. The Project Engineer receives one copy of the manifest and the remaining copies go out with the trucker. When the regulated material is disposed at the regulating facility, one copy of the manifest comes back to the project. The project needs to ensure that all copies and material quantities are accounted for in a timely manner. See section 603 in the Hazardous Waste Management Program Manual for information about action to be taken when a manifest does not come back to the project. Examples of Manifests and a full description are shown in the Hazardous Waste Management Program Manual (HWMPM) in section 602. Most of the regulated material removed from construction projects will be a solid waste. Manifesting is required but there will not be a RCRA generator number on the manifest. An example of one is in Appendix C. For more information regarding manifesting see sections 603 and appendix I of the HWMPM. 410 Pre-Transportation Requirements and Placarding The Hazardous Waste Management Program Manual(HWMPM) is an excellent resource to determine the pre-transportation and placarding requirements. A pre-transportation requirements and checklists are provided in sections 504, 605 and in appendix P of the HWMPM. The Contractor is required to provide all of the material and manpower to provided for the proper identification, transportation and disposal of the regulated waste. The project must ensure that the packaging, labeling, and placarding are in accordance with the regulations. 411 Records of the Disposal All documentation of the regulated waste operations should be recorded on CMS 1 or 2 and in the daily diaries. All records should be kept with the project files. If the regulated waste was classified as a hazardous waste, then all of the record keeping requirements listed in section 1101 in the HWMPM apply. 412 Weekly Project Inspections When the project is conducting hazardous waste removal operations, then the project will perform the weekly inspection requirements in 1107 in the HWMPM. 13

500 Regulated Wastes Found During Construction. 501 General Special procedures are to be followed when the Contractor encounters potential regulated materials that were not anticipated by the plans. Contractors and the Department personnel are made aware of these special procedures in CMS 203.04. 502 Limit Access to the Suspect Area It is essential that suspected regulated material be left in place until identified by a qualified specialist. This may require the temporary discontinuance of work in the area of the suspect materials. The area in question should be secured to prevent access. This can to be accomplished by cordoning off the area with rope or construction fence and posting a guard. On large projects, work may continue at locations sufficiently removed from the site in question. 503 Notification The Project Engineer shall to be notified immediately. The District may request specialized assistance from the Environmental personnel in the District or Central Office. The Department will evaluate the level of risk to workers and to the public and notify all responsible parties and regulatory agencies as required. The District will determine a course of action based on consultation with the appropriate environmental regulatory agencies and ODOT staff with specialized expertise in the hazardous waste field in the Office of Construction or the Office of Environmental Services. If it is determined that the area in question is or may be contaminated with environmentally regulated substances, the District will initiate the evaluation and remediation of the problem area as described below. In the event of a life threatening situation to human health outside the project, contact the Local Fire Department and the Local Police. Report the incident to the Construction Engineer and the Highway Manager to determine if local involvement is required. When local involvement is required notify the County Emergency Manager Director listed in the current version of the Incident Management System Responders Listing. In case of a release of reportable quantities call the Ohio Release Hotline at 800-282-9378 or 614-224-0946. The reportable release amount is between 1 and 500 pounds depending on the chemical involved. (Note: Reportable Quantities in Ohio Environmental Compliance Guide under releases and response, list of extremely hazardous substances.) 14

504 Obtaining Technical Advise or Inspection It is imperative that Action be taken to mitigate the problem in a timely manner. If required, the District may seek the consultation services through the district task order contract or third party billing through the Contractor of a qualified consultant specializing in the regulated waste assessment and remediation. The District Environmental Site Assessment Task Order Contract can be used to provide specific environmental expertise for the consultation, evaluation and testing in these situations. The District's Planning and/or Environmental staff can aid in developing a request for a proposal for these services when the Task Order Contract is used. This can be provided at no cost to the project. The specific consultation, testing or inspectors hired through the Task Order Contract or other contracts should specify the type of environmental expertise needed. For example, a project involving underground storage tanks or petroleum contamination soils requires knowledge of BUSTR rules and regulations, operation of organic vapor analyzers, and the ability to interpret laboratory data. A good minimum qualification for these projects would be a certificate indicating that the supplied inspector is a Certified Installer or Inspector under BUSTR s rules. Projects involving hazardous, solid wastes or other types of wastes will require the appropriate type of expertise. 505 Development of the Remediation or Disposal Plan The chosen environmental consultant will submit a sampling plan for the Department and OEPA( if applicable) for approval. Upon approval, the environmental consultant will perform the required sampling, testing, disposal(maybe) or mitigation. If it is determined that no contamination exists or the problem has been resolved on the site, the Contractor will be directed to return to work. If required, a removal or remediation plan will be developed jointly by the environmental consultant or contractor in consultation with ODOT and the OEPA or BUSTR as applicable. 506 Implementing the Plan Once the contamination is known and a plan to eliminate or mitigate the regulated material is determined, the Department may seek competitive bids from a qualified regulated waste disposal firm contractor to remove or mitigate the waste. 15

If it is decided that the time it would take for competitive bids cannot be tolerated, the Department may request of the Controlling Board a waiver of competitive bidding and award it to an approved qualified environmental firm via third order contract through the Contractor. Where treatment or disposal of the regulated material must be conducted concurrently with construction, it may be made a part of the construction contract. 507 Disposal and Remediation Once all the approvals are obtained, a remediation contract will be initiated. The environmental consultant, contractor or sub contractor will perform work in accordance with this manual and the approved remediation plan. Complete records in accordance with all applicable laws, rules and regulations of all activities performed in the treatment, removal, transport and disposal shall to be kept by the remediation Contractor. These records shall include a certificate of destruction or detoxification, where appropriate, and shall be furnished to ODOT at the completion of the remediation. These records will to be retained by ODOT at the project office. All of the disposal requirements of a regulated waste outlined in Chapter 4 still apply. A plan note similar to the ones in appendix A, an excavation plan and a SSHSP a should be developed before the work begins. 16

600 Underground Storage Tanks Underground storage tanks(usts) are one of the most common contamination problem encountered during construction. The section 202.062 of the Construction and Material Specifications (CMS) details the contract requirements for the UST removals. There are three types of UST listed in the specifications; 1) Tanks Regulated by The Bureau of Underground Storage Tank Regulation (BUSTR). 2) State Fire Marshall regulated tanks. 3) Ohio EPA regulated tanks. Note: The state fire marshal and OEPA generally follow BUSTR regulations. 601 Inspection Services It is highly recommended that the project hire a BUSTR Certified inspector or installer to help with the inspection and removal because of the complexity of the rules and the ever changing requirements. The project may need an environmental consultant to review the contractor s closure report or when a risk assessment or remedial action is required. These people may be hired by using the district environmental task order contract or by using third party billing through the Contractor. 602 Requirements of BUSTR The State Fire Marshals Office, Bureau of Underground Storage Tank Regulations (BUSTR) control the majority of the installations, uses and removals of underground storage tanks in Ohio. The type of tanks regulated by BUSTR are detailed in Appendix D on the Fact sheet What Type of Tanks does BUSTR Regulate. In the next section, a summary of the BUSTR and the specification requirements are discussed. The Bureau of Underground Storage Tank Regulations fact sheets are in appendix D and are referenced in this summary. The project needs to review the fact sheets and this summary to become familiar with the UST removals. The fact sheets in this handbook are the ones available in February of 2000. Contact BUSTR at 614-752-7938 if updates are needed. If an unknown underground storage tank is encountered, the Project Engineer should notify the local fire authority or BUSTR immediately. 17

The majority of the UST found in construction are in the plans for removal and provisions for their removal are made by the specifications or plan notes. 601.2 Specification and BUSTR Requirements 1) A Certified Installer is required for any removal of a UST regulated by BUSTR. The Certified Installers are required to have photo identification. The project should check for this identification. The requirements to become a Certified Installer or Inspector are detailed on the fact sheets in Appendix D. 2) All required permits, testing and closure reports are part of the work and are to be included in the bid item. 3) A general summary of the UST removal procedures follows: A Certified Installer must perform the work. A Certified Inspector must inspect the work. This inspector may be from the local fire department, BUSTR or a consultant who is a Certified Inspector. A permit must be applied for 30 days prior to the work. The project should obtain a copy for the project records. The local fire department or BUSTR may issue the permit. See Fact Sheet The BUSTR Permit Process. (Note: Permit forms in appendiix c in closure guidelines) Even though the permit may be issued by the local fire department, BUSTR must receive a copy of the permit application 30 days prior to the removal. If the tank is not registered then tank then registration may be required. See Fact Sheet Underground Storage Tank Registration (Performed By ODOT). ( Note :Registration forms in bustr folder) The local Division of Air Pollution Control of the Ohio EPA may need notified because of air pollution concerns. The actual removal is summarized in the Fact sheet Closure Guidelines. See the section on permanent removal and replacement. The Certified Inspector must sign the permit and the project should keep a copy for a permanent record. A closure assessment and report is required after the UST removal. The contractor should submit the report to BUSTR within 45 days of the closure. The project engineer should sign the closure report for the department. The project may elect 18

to have this closure report reviewed by an environmental consultant. forms in appendix d in the Closure Guidelines) ( Note: Closure Depending on the result of the closure assessment, a risk assessment and remedial action may be needed. If these two are required an Environmental Consultant will be needed to perform this work. The task order contract may be used to perform this work. See the fact sheets Risk Assessment, Remedial Action Plan Guidelines and Selecting an Environmental Consultant in appendix D. The specification requirements do not cover risk assessment, remedial action, environmental cleanup or the cleanup of the plum material beyond a few feet outside the UST. Any of the mentioned work should be considered extra work unless additional quantities or other work is described in the plans or proposal. 604 Other Governing Agencies For other UST s not regulated by BUSTR contact the local fire marshal. For UST containing hazardous waste contact the OEPA at 614-644-2917. 605 Releases When the tank is removed and 25 gallons or more of petroleum is released, or if the product reaches a body of water or travels off the project site; the following Agencies need contacted. 1) Immediate Notification: Local Fire Department. The Ohio EPA at 800-282-9378 or 614-224-0946. County Emergency Director listed in the Department s Incident Management Responders Listing if the material travels off site. 2) BUSTR Corrective action Hotline at 800-686-2878 or 614-752-7938 within 24 hours. 3) If a Hazardous chemical in excess of its reportable quantity is released all of the following need notified: 19

Local Fire Department The Ohio EPA at 800-282-9378 or 614-224-0946. County Emergency Director listed in the Department s Incident Management Responders Listing. Reportable chemical may be between 1 and 500 pounds depending on the chemical. (Note: Reportable Quantities in Ohio Environmental Compliance Guide under releases and response, list of extremely hazardous substances.) Note: A Fact Sheet on Emergency Response and Advise is in Appendix D. 20

700 Other Wastes 701 General There are other common waste materials that are important to dispose of properly. Construction and demolition debris, landscape waste(buried or burned on site), slag, scrap tires, rail road ties, and asbestos pipe. Other wastes such as fly ash, bottom ash, foundry sand petroleum contaminated soil glass and tires may be used as a recycled materials in fills in the near future. They are described or referenced below. 702 Construction Demolition Debris The EPA regulates materials that come from structure removal, pipe removal, clearing or grubbing, tree and brush removal operations. The EPA encourages the reuse of construction materials for positive uses. Clean hard fill material such as asphalt millings, concrete rubble or mixtures of these materials with other soils or rock may be used in fill operations on or off the site of construction. These materials can not be indiscriminately piled up and left. These materials must be placed in fill areas not in disposal piles. If the material is being used as fill off the site the OEPA or local board of health in the area of the filling operations need written notified seven days prior to the filling operation. These materials may be taken to a recycling operations such as aggregate crushing plants or asphalt plants. Debris filled with wood road metal, plaster in whole or part of clean hard fill must be used as fill on site or taken to an approved construction demolition debris site. This material is normally associated with building debris. These materials do not meet the 203 embankment specifications and should not be used in fill operations. 703 Landscape Wastes Ohio law regulates the disposal of landscape waste that result from roadway clearing and grubbing operations. These regulated wastes includes brush, trees, stumps, tree trimmings, branches, weeds, leaves, grass, shrubbery, yard trimmings, crop residue, and other plant matter, excluding soil and garbage. We may re-use these wastes by: 21

1. Constructing a wildlife habitat in accordance with published guidelines from the Ohio Division of Wildlife, U.S. fish and Wildlife Services, or Natural Resources Conservation Services, subject to local board of health or local OEPA approval; 2. Chipping waste into mulch and using or donating it for use on or off the site; 3. Selling or donating the waste for non-burial beneficial purposes; 4. Using the waste for any positive use or re-use approved by the local OEPA offices or the local board of health; or 5. Using as fill material on the site from which the waste was generated. Item 203 embankment does not allow these wastes in embankments or structural areas, but on-site burial is permitted in non-structural areas. Neither ODOT or its contractors may dispose of landscape wastes at any unregulated facility or property owned by others. This includes a restriction on borrow and waste areas outside the right-ofway. Note: OEPA guidance for on site means any location on the right of way. This can be outside the construction limits or even on other state owned properties. If large amounts of these wastes are to be generated then the designer may provide additional right-of way to dispose of these wastes. ODOT may dispose of these wastes by: 1. Open burning with permission from OEPA ( See Open Burning Guidelines Dated 4 AUG 98 or the next section); 2. Composting at an OEPA registered composting facility; or 3. Sending less than 4" material to a sanitary landfill and greater than 4" material to a construction and demolition debris landfill. A new proposal note should be part of the bid package to reflect the laws intent. 704 Open Burning The following are the updated guideline pertaining to open burning of landscape wastes. It is the Contractor s responsibility to obtain the permission to burn landscape wastes but the project personnel should understand the rules to properly administrate the contract. This description supersedes the open burning guidelines dated December 19, 1983 and is a retyping of the I. O. C. written on August 4, 1998. 22

Landscape waste is defined as any plant matter, except garbage, including trees, tree trimmings, branches, stumps, brush, weeds, leaves, grass, shrubbery, yard trimmings, and crop residues. Also, attached is a copy of current listing of Ohio Air Pollution Control Agencies and the geographic area of responsibility of each agency. OAC 3745-19 allows landscape wastes to be burned on construction sites if the Contractor has been issued a permit by the Local Air Pollution Control Agencies or the OEPA District Office. The entire OAC is available if requested. We understand in some instances EPA representatives are reluctant to give written permission, but are doing so verbally. Should this occur it should be so noted in the project records. 704.1 Open Burning Guidelines If a Contractor wishes to open burn landscape wastes, they must obtain written permission from the Ohio EPA and he must comply with the following conditions: 1. They must burn in an unrestricted area, as defined by Ohio EPA Regulations OAC- 3745-19-01 (I) & (J). Restricted areas include all municipalities, one thousand feet beyond the corporate limits of a municipality of population between 1,000 to 10,000 and one mile beyond boundaries of municipalities greater than 10,000 in population. 2. They must burn only when atmospheric conditions will readily dissipate contaminants. Generally, this means that burning conducted between 10 a.m. and 4 p.m. will benefit from convective mixing and dispersion of any smoke. 3. They must burn only when the fire will not create a visibility hazard on roads, railroad tracks, or airfields. 4. They must burn at a point on the premises no less than one thousand feet from any inhabited building not located on the premises. 5. They must use an air curtain destructor or other device or method determined by the Director of the OEPA to be at least as effective in curtailing release of air contaminants. 23

6. They must apply for permission in writing from the Ohio EPA or the local air pollution control agency at least 10 days before the burning. The Contractor s request must contain all required information listed in OAC 3745-19-05. Even when these conditions are complied with, the Contractor may not open burn landscape wastes under the following circumstances. 1. They must not burn in any area where an air alert, warning, or emergency is in effect. The existence of such conditions are usually highly publicized by the news media, but when in doubt, call the nearest OEPA district office or local air pollution agency which has jurisdiction. 2. They must not burn if the burning is forbidden by local ordinance, or by statutes or regulations administered by state agencies other than Ohio EPA. 705 Slag Usage on the Projects Air cooled blast furnace slag has been known to produce a green or black runoff and a rotten egg smell. To minimize this problem all air cooled blast furnace slag used for items 203.304,306,307,503,603,and SS-855 must pass the Sulfur Leachate Test under Supplemental Specification 907. Steel slag has been known to expand and clog up underdrains. All uses of steel slags for Items 203,304,306,307,410,411,617,503, or 603 must comply with Supplemental Specification 905. Using materials that comply with these two supplementals will minimize environmental and engineering concerns when using these materials. 705.1 Tuffa Removal Lime precipitant from slags used in the bases of older projects can create deposits to form on the side slopes. The deposited material will have a high ph. This material may be take to a solid waste landfill, if permitted. The material may be a hazardous waste if the ph is above 12. When projects notice these materials within the project limits the deposits should be tested and removed as follows. This material should be tested under the task order contract and the contractor should perform the removal by force account. Some projects may have special plan notes for the removal operations. 24

706 Scrap Tires Scrap Tires found on the project are transported under OAC 3745-27-56. The tires must be disposed of at a registered and permitted scrap tire facility as per OAC 3745-27-61 thru 65. Under these requirements the transportation company and the disposal facility are regulated by the OEPA. Shipping papers are required to ship the tires to and from the facility. The project engineer will sign the shipping papers for the Department. The records shall be kept for three years. 707 Rail Road Ties The EPA encourages the use of rail road ties as landscape materials or other uses. When they must be disposed of they are disposed of in a construction and demolition debris site or a solid waste facility. To date, creosote in rail road ties do not pose an environmental threat 708 Asbestos Pipe The majority of the asbestos pipe removals are handled when bridges are demolished. There requirements are not covered by this handbook or section. Old concrete pipe may be made of asbestos. When a pipe is suspected of containing asbestos the project should use the task order contract to hire an asbestos inspector. A licensed asbestos abatement contractor may be required to remove the pipe. Cutting and crushing is strictly forbidden. Follow the instructions of the asbestos inspector or contractor. The project may need to notify the local air quality authority and follow strict demolition and removal requirements of OSHA. Disposal forms need to be filled out by the project. 709 Recycled Materials In the near future Supplemental Specification 871 will allow the use of fly ash, bottom ash, 25

foundry sand, glass, petroleum contaminated soils and tires in fills. Petroleum contaminated soils is presently allowed as embankment material under Supplemental Specification 814. Basically, the materials are allowed in the interior sections of the fills. The approval on existing contracts will be on a case by case bases. 26

800 Documentation Requirements It is the intent of this section to recommend minimum documentation and inspection requirements for waste removal operations. All waste removal operations should have a project inspector present at all times to ensure that the work is proceeding in accordance with the specifications. All of the following documentation requirements need recorded in the project daily reports. References to appropriate laws, specifications, proposals and or plan notes or details for all the inspector reports are required. Specifications or other requirements waived by the project engineer shall be noted on the daily logs. The following outlines the documentation requirements: Chapter 1 Responsibility Report all significant changes Health and safety requirements Chapter 2 Training All training for the project engineers, project inspectors, consultant inspectors Medical monitoring needs Training changes based on the health and safety plan Records in accordance with sections 1105 and 1106 in the HWMPM Chapter 3 Site Specific Health and Safety Plan Obtain a copy of the health and safety plan Review of the health and safety plan Obtain a new health and safety plan if needed Chapter 4 Regulated Waste Designated for Removal in the Contract The review of the contract requirements in the plan, proposal or specifications The pre-excavation checks The excavation operations Temporary storage 27

The material sampling evaluation The manifesting The pre-transportation requirements and placarding Disposal records Keep a running lists of the weekly inspections Chapter 5 Regulated Wastes Found During Construction Who and when was notified? Who was hired to look at the wastes? Testing results The disposal plan Plan implementation Disposal Records Chapter 6 Under Ground Storage Tanks Who regulates the tank removal? Contractor and Inspectors qualifications Conversations with BUSTR or the fire department Daily inspections Obtain a copy of the Permit Contacts with the division of air pollution control Closure report Risk assessment and remedial action, if needed Who was notified during a release? What and in what quantity was released? What action was taken? Was a clean up and final report required? Chapter 7 Other Wastes 702 Construction and Demolition Debris Clean hard fill verses debris filled with wood, plaster etc. Quantities and locations of material leaving and filled on the site Seven day notice to the local board of health or OEPA Quantities going to the construction and demolition landfills 28

703 Landscape wastes Quantities and locations of materials leaving and buried on site Where and what type of positive uses were the materials used 704 Open Burning Obtain a copy of and document the permit requirements Smoke causing a hazard? Burning at appropriate times? Air Curtain used? Any fire hazards? 705 Slag Usage on the Project Material in compliance with the supplemental specifications? Tuffa removal operations(same as hazardous or solid wastes) 706 Scrap Tires Same as solid waste Keep records for three years 707 Rail Road Ties Same as construction and demolition debris Positive uses encouraged 708 Asbestos Pipe Who was notified? Qualifications of and recommendations of the asbestos inspector and contractor Remediation or demolition procedures Any contacts with the regulating community 29