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Asbestos / Lead Abatement and Demolition Management

Asbestos-containing materials and lead-based paint are major concerns for building owners when planning a facility renovation or demolition. OSHA standards and EPA regulations have placed management constraints on building owners in order to protect building occupants and general construction workers.

CP Environmental Group (CPEG) provides cost-effective abatement solutions for our clients that limit liability and ensure compliance with these standards and regulations. Our work force is trained following the EPA’s Model Accreditation Plan and is licensed in multiple states. CPEG’s abatement management services include:

  • Asbestos inspection and hazardous materials surveys.
  • Project scoping and budgeting services.
  • Abatement options including removal, repair, and encapsulation.
  • Disposal of asbestos-containing materials and lead-based paint waste at licensed and approved landfills.
  • Project consultation and interface with regulatory agencies.
  • Daily air monitoring in accordance with OSHA requirements during abatement activities.
  • Minor demolition services to access hidden materials or for ease of project management

Following the abatement of asbestos containing materials and lead-based paint, as needed, CP Environmental group provides demolition management and contracting to efficiently carry out our clients' pre-construction site preparation needs.

In summary, CPEG's variety of project experience enables us to effectively deal with regulatory issues and challenges that arise during site renovations/demolitions.

Asbestos Inspection, Lead Inspection and HazMat Surveys

CP Environmental Group (CPEG) provides United States Environmental Protection Agency (U.S. EPA) certified and State-licensed asbestos building inspector(s) to conduct National Emission Standards for Hazardous Air Pollutants (NESHAP) asbestos surveys to identify suspect asbestos-containing materials (ACM). The inspector collects bulk samples of suspect ACMs for laboratory analysis. If requested by our clients, our limited NESHAP asbestos surveys are non-destructive and do not include selective demolition of finishes or structural components to gain access to concealed materials. The inspector(s) record the approximate measurements, location, and hazard assessment of each suspect ACM, and collects samples of accessible materials.

Bulk samples are transported to a laboratory with accreditations from the National Institute of Standards and Technology (NIST) and the American Industrial Hygiene Association (AIHA) for analysis of asbestos fibers content, in accordance with the U.S. EPA Method and the guidelines of the National Voluntary Laboratory Accreditation Program administered by NIST. Sample analytical results are provided for each distinct layer of each sample submitted per the U.S. EPA “Method for the Determination of Asbestos in Bulk Building Materials”. CPEG then prepares a NESHAP Asbestos Survey Report. The report includes laboratory results, material descriptions, locations and approximate quantities of each ACM, and the associated hazard assessment.

CPEG also provides Pennsylvania-licensed lead-based paint inspectors and risk-assessors for performing lead-based paint inspections, clearance wipe tests and risk assessments.  Soil and dust samples may be collected for laboratory analysis of lead as part of the risk assessment.  CPEG personnel emphasize proper inspection techniques including use of XRF instrumentation for real-time data complimented by laboratory samples collected.  A thorough inspection and/or risk assessment report is then prepared which includes the reporting elements required by EPA and HUD.

At our client’s request, CPEG can also perform Hazardous Materials Screening Surveys for materials other than asbestos during the same inspection event, including polychlorinated biphenyls (PCBs), lead-based paint, mercury vapor, and radon gas. These screening surveys give our clients a better perspective on what existing building materials may need to be addressed when planning future occupancy or proper demolition procedures. After receipt of the analytical data for samples collected as briefly described below, CPEG prepares a HazMat Screening Survey Report, including material descriptions, locations, and approximate quantities.

Polychlorinated biphenyls (PCBs)

The CPEG surveyor looks for possible PCB-containing electrical equipment, noting the presence and quantity of fluorescent light ballasts and/or transformers. The equipment labeling, where accessible, is evaluated for indication of PCB content. In the absence of definitive non-PCB labeling, the equipment is assumed PCB-containing or may be sampled, at the client’s option.

Lead-Based Paint

Paint chip samples are collected by the CPEG surveyor for laboratory analysis of lead content. The samples are analyzed by a laboratory accredited under the Environmental lead Laboratory Accreditation Program, which is administered by the American Industrial Hygiene Association. The results are tabulated in the final report as a percentage of lead by weight.

Mercury Vapor

Fluorescent lighting equipment may contain mercury vapor bulbs. The CPEG surveyor visually notes the presence of fluorescent lighting equipment and estimates the number of tubes.

Radon Gas

A radon screening is performed at sites where an existing basement or other sub-grade, normally-occupied space is planned for renovation. The screening is conducted by placing activated charcoal canisters for a period of one to four days. The canisters are collected and submitted to a State-certified radon laboratory for analysis.

Brownfield Management / Act 2 Site Closure

CP Environmental Group (CPEG) specializes in working with clients during renovations, acquisitions, and divestitures of environmentally impaired sites (brownfields). We have contributed to the success of hundreds of redevelopment projects for our industrial, commercial, and municipal clients by providing a combination of technical excellence, practical experience, and responsiveness. We have obtained closure or are currently in the brownfields closure process for sites located in Illinois, Indiana, New Jersey, New York, Ohio, Pennsylvania, and West Virginia.

CPEG associates began working on Pennsylvania Land Recycling Program (Act 2) projects before the final guidelines for implementing the Act were published by the Pennsylvania Department of Environmental Protection (DEP). The key to identifying optimum solutions for our clients then was developing good working relationships with DEP case managers so that we could learn and help guide their individual interpretations of the Act. Since that time, CPEG has worked on a variety of projects within the Act 2 framework, including over 60 projects directly within the Chapter 250 guidelines, and over 80 projects within the Chapter 245 UST site guidelines. As such, we have developed extensive experience on projects requiring knowledge of Act 2 and the ever-changing new developments within the associated DEP guidance and interpretation of the Act. The good working relationship we developed with DEP early in the Act 2 history continues to help CPEG succeed in this arena.

The CPEG team has safely addressed separate-phase liquids and a variety of hazardous and non-hazardous contaminants within the brownfields framework, including petroleum products, volatile organic compounds (VOCs), chlorinated solvents, semi-volatile organic compounds (SVOCs), metals, polychlorinated biphenols (PCBs), asbestos, and ammonia. Our expertise within the browfields framework includes site investigation and characterization; risk assessment and ecological screening; fate-and-transport modeling, including groundwater-to-surface-water discharge modeling; remedial strategy evaluation, selection, and implementation; and demonstration of attainment using background, state-wide health, non-use aquifer, and site-specific standards. This expertise is complimented by the professional licenses of our associates. Our clients rely on CPEG associates and their brownfields expertise to develop and safely implement superior solutions to even their most complex environmental issues in Pennsylvania.

Due Diligence (Phase I/II/III Environmental Site Assessments, Remediation & Site Closure)

CP Environmental Group provides value-added site development solutions on a single, multiple services, or turnkey basis so we can meet the specific needs of our valued clients. CPEG commits to being a trusted partner to make our client's project goals a reality in the most economical manner possible. We self-perform and manage the due diligence, environmental management, and remediation activities that are the foundation of site development packages.

All Phase I Environmental Site Assessments (ESA) are not created equal. Individuals or organizations lured by a low price and lulled by the apparent security of generic procedures risk significant liability if the assessments they accept are not up to industry standards.

A CPEG Phase I ESA supplies in-depth environmental information about a site, thus minimizing the associated liability and the risk of owning or financing an environmentally impaired site, according to the standard of the American Society for Testing & Materials (ASTM). There is no cost efficiency in skimping on a Phase I ESA.

The purpose of a Phase I ESA is to evaluate the pre-purchase environmental condition of a site, identify recognized environmental conditions, and to comply with the due diligence property inspection requirements of the Innocent Landowner Defense under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) of 1980 and subsequent amendments. CPEG Phase I ESA services include:

  • ASTM Standard (ASTM E-1527)
  • Transaction Screen (ASTM E-1528)
  • Customized assessments

Conclusions and recommendations are drawn based on the observations and information collected by CPEG. The findings, including conclusions and recommendations, as warranted, are summarized in a written report. If the potential for contamination is discovered in the Phase I ESA, a Phase II Environmental Site Assessment may be recommended

A variety of investigation methods are available for performing a Phase II ESA. These methods may include performing geophysical surveys to search for buried metallic objects; collecting and analyzing soil and/or groundwater samples; performing hydrogeological investigations to determine groundwater flow and aquifer properties; performing asbestos, mold, and lead-based paint surveys; and other methods appropriate to respond to the results of the Phase I ESA.

If contamination is discovered, CPEG can continue the investigation to determine the extent of the impact (Phase III ESA), and develop and implement a plan to address the impacts, keeping in mind the environmental regulations and their application to the planned use for the site. CPEG solutions are described on “ Remediation Engineering , System Installation, Operation and Maintenance”, Business Solutions” and “ Management Strategies” pages.

CPEG associates have a solid history of determining the best business solution (cost-effective, time-sensitive) for environmentally-impaired properties identified during the due diligence process. By assisting with our clients' profitable growth through site development excellence, we achieve our vision... to be the preferred and trusted partner of our clients and associates.

Environmental Compliance Plans / Monitoring

The CP Environmental Group (CPEG) team has prepared multiple environmental permit applications and compliance plans as well as performing the subsequent compliance monitoring and reporting required to maintain these plans/permits. The proper application and analysis of the resulting data using a business solutions mindset saves our clients time, frustration, and money.

Environmental Compliance Plans and Permits

Various types of environmental compliance plans and permit applications have been successfully prepared by the CPEG team including Spill Prevention, Control and Countermeasures (SPCC) plans; National Pollutant Discharge and Elimination System (NPDES) permits; Encroachment permits; Quality Assurance Project Plans (QAPP); Work Plans; Municipal Waste Landfill Permits, including minor and major modifications; Beneficial Reuse permits; Preparedness, Prevention and Contingency (PPC) plans; Storm Water Pollution Prevention (SWPP) plans; Spill Prevention Response (SPR) plans; and the One Plan (combination of SPCC, PPC, SWPP, SPR, and emergency response plan) for operating facilities.

Sampling

The proper collection of soil, groundwater and waste materials (leachate, spoil piles, etc.) is the foundation of any site investigation or compliance monitoring activity and is, therefore, of the utmost importance. CP Environmental Group (CPEG) associates are thoroughly trained in appropriate sampling procedures for environmental media as outlined in the CPEG Field Standard Operating Procedures (FSOP) Manual. These FSOPs are designed to establish internal procedural consistency at CPEG. Client specific procedures, requirements, and scopes of work are also maintained. Additionally, CPEG has a comprehensive health and safety policy manual that must be used in conjunction with the implementation of any FSOPs, as applicable. Our team ensures that adequate control and documentation procedures are utilized from initiation to completion of the sampling activities so that the data collected are of the highest quality and representative of actual site conditions.

QA/QC, Statistics and Reporting

During field activities, the field data (including Daily Activity Logs, Soil Boring Logs, Monitoring Well Construction Diagrams, Water Sampling Summary Logs, Chain-of- Custody Records, and other field data) are submitted on a minimum of a weekly basis to the CPEG Project Manager for initial review. Aquifer testing data is downloaded to a personal computer and input into an aquifer testing program, as applicable. After completion of the initial review and data evaluation, including statistical analysis as applicable, a project manager will begin report preparation. After completion of the report and compiling data, the report is peer-reviewed. After completion of the review process, the report is submitted to the client program director/CPEG principle for final review, data evaluation, and approval. During the final review process, remedial options or recommendations are evaluated, as applicable.

Compliance Monitoring Services

CPEG associates offer cost-effective compliance monitoring services, as outlined below.

  • Performing operating facility compliance monitoring, evaluation and regulatory reporting per agency requirements including sample collection, engineering liaison and laboratory subcontractor management / liaison with client-contracted laboratories.
  • Groundwater monitoring data evaluation using various statistical methods including combined Shewhart-CUSUM control charts, qualitative trend plots, Dixon's test for outliers, analysis of variance (ANOVA), Student's t-tests, and trilinear diagrams.
  • Performing site hydrogeologic characterization and engineering studies and coordinating wetlands, archaeological, socioeconomic and transportation studies in support of permitting.
  • Performing hydrogeological evaluation, facility investigation and statistical analysis to disprove erroneous laboratory reporting and/or identify solutions to non-representative sample analysis.
  • Acting as liaison with environmental agencies for permitting, construction and compliance activities.
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