Release Abatement Measure Plan Modification for Wynn Boston Harbor (TPD1611084)

To Whom It May Concern:

GZA GeoEnvironmental, Inc. (GZA), on behalf of Wynn MA, LLC (Wynn MA), has prepared this revised Release Abatement Measure Plan Modification (RAM Plan Modification) to describe Response Actions pursuant to the Massachusetts Contingency Plan (MCP) that will be completed during the construction of the Wynn Boston Harbor (formerly known as the Wynn Resort in Everett) at the former Everett Staging Yard Disposal Site (the Site). This RAM Plan Modification was necessitated by the recent detection of asbestos in soil associated with demolition debris excavated during construction activities on the Everett Staging Yard portion of the Site. At the request of MassDEP, this revised RAM Plan Modification has been revised to include the Non-Traditional Asbestos Abatement Work Plan (NT Plan) prepared by Environmental Health & Engineering, Inc. (EH&E) of Needham, Massachusetts. The NT Plan has been submitted to MassDEP’s Bureau of Air and Waste (BAW) under separate cover; however, for ease of reference, the text of the NT Plan has been included in a separate section below. In addition, this revised RAM Plan Modification includes details regarding the handling and disposal of on-Site groundwater treatment system wastes.

EXECUTIVE SUMMARY

Construction activities at the Site are being conducted following the provisions in the RAM Plan previously submitted to MassDEP on May 3, 2016 (the May 3 RAM Plan). The May 3 RAM Plan details the Site history, Site releases, Site conditions and surrounding receptors, and RAM implementation. The provisions of the May 3 RAM Plan will stay in effect during subsequent construction activities at the Site, but will be modified as described in this revised RAM Plan Modification to address asbestos in soil as encountered at the Site. Asbestos has been detected in less than 10% of the soil samples tested to date; in all but a few cases, the asbestos is present at trace (<1%) quantities.

The asbestos encountered sporadically in some Site soils is associated with demolition debris mixed into fill material in certain areas of the Site handling, bulk loading, transport, and off- Site disposal of soils identified as containing asbestos.

An Equal Opportunity Employer M/F/V/H

November 16, 2016

File No. 01.0171521.15

Massachusetts Department of Environmental Protection

Page | 2

a                      BACKGROUND

The Site is identified by the Massachusetts Department of Environmental Protection (MassDEP) as Release Tracking Number (RTN) 3-13341. A Site Locus Map is presented as Figure 1, and the RAM Project area that will be subject to the provisions of this revised RAM Plan Modification are shown on Figure 2.

This revised RAM Plan Modification has been prepared in accordance with 310 CMR 40.0444 of the MCP, and with the Limitations in Appendix A. The revised RAM Plan Modification will be submitted electronically through MassDEP eDEP online filing system. A copy of the RAM transmittal form (BWSC-106) is included in Appendix B.

Construction activities at the Site have been conducted following provisions in the May 3rd RAM Plan. The May 3rd RAM Plan details the Site history, description of releases, Site conditions and surrounding receptors, and RAM implementation. The provisions of the May 3rd RAM Plan will stay in effect during subsequent construction activities at the Site and will be modified as described in this revised RAM Plan Modification to address asbestos in soil as encountered at the Site.

The NT Plan has been prepared by EH&E and is included within this revised RAM Plan Modification. The NTP provides procedures and health and safety controls for bulk loading, transport, and off-Site disposal of soils identified as containing asbestos. In addition, some of the information contained herein is derived from direction issued by MassDEP via email on October 19, 2016, relative to sampling of soils for asbestos testing.

The Site is a Public Involvement Plan (PIP) site under the MCP. As the modifications listed below do not substantially alter or expand the May 3rd RAM Plan, this submittal is not subject to an additional comment period per Section 40.1405(6)(e)(2) of the MCP.

PERSON ASSUMING RESPONSIBILITY FOR RAM PLAN MODIFICATION

The entity assuming responsibility for this RAM Plan Modification is Wynn MA, LLC. Information for Wynn MA’s contact

person is provided below:

Mr. Robert DeSalvio President

Wynn MA, LLC

101 Station Landing, Suite 2200

Medford, Massachusetts 02155

Tel: 857-770-7801

RAM MODIFICATION IMPLEMENTATION

Objectives and Schedule

The objective of this revised RAM Plan Modification is to establish procedures that will be followed for sampling soil with visible demolition debris which could potentially contain asbestos and for managing, treating, and disposing of asbestos- impacted soil. The revised RAM Plan Modification also discusses air monitoring for asbestos that will be conducted around the perimeter of the Site and around work zones within the Site.

November 16, 2016

File No. 01.0171521.15

Massachusetts Department of Environmental Protection

Page | 3

a                      HEALTH AND SAFETY PROTOCOLS

Excavation work will be conducted by personnel trained to handle contaminated materials per Occupational Safety and Health Administration (OSHA) Regulation 29 CRF 1910.120. Procedures will be followed to protect the health and safety of all on-site workers and the community.

SOIL SAMPLING PROCEDURES

Cells where demolition debris is visible and could potentially contain asbestos will be sampled at a frequency of one four- point composite sample per 100 cubic yards of soil. In accordance with MassDEP’s email on October 19, 2016, soils that do not contain visible demolition debris will not be sampled. Soil samples will either be tested at an on-Site certified lab established by AEC laboratories (for real time analysis) and/or will be sent off-Site to AEC laboratories (located in Weymouth, MA), Proscience Laboratories (located in Woburn, MA), and CEI Laboratories (located in Cary, NC) or other MassDEP accredited asbestos testing laboratories.

Asbestos analyses will be forwarded to MassDEP within 7 days of GZA’s receipt. Analyses performed prior to Friday, October 21, 2016, were provided to MassDEP on Monday October 24, 2016, via email.

MANAGEMENT OF ASBESTOS-CONTAINING SOIL

In areas of the Site where asbestos is detected in the soil, the following management procedures will be implemented:

• During construction activities that have the potential to create dust, primarily excavation of soils identified as containing asbestos, the soil will be managed in such a way as to prevent the generation of visible dust and air monitoring will be performed as indicated in the Environmental Monitoring section below. If dust is being generated by a specific activity involving disturbance of soil, that activity will temporarily be halted until additional areas are wetted or misted with water. Temporary water lines or water trucks will be dedicated to each work area where soil with asbestos is disturbed.

• Excavated soil identified for off-Site disposal will either be live-loaded into tractor-trailers for off-Site disposal or will be stockpiled at the Stockpile and Soil Treatment Area (refer to Figures 2 and 3). To maintain constructability, soil may need to be temporarily stockpiled near the work area while waiting for truck transport to the stockpile location area or off-Site disposal. Stockpiles will be covered with GeoMatrix Permeable Fiber Mat or Gorilla-Snot™ for dust control. In addition, polyethylene sheeting may be used to cover stockpiles; this sheeting will consist of 10-mil thick material that is ballasted over the stockpile. Stockpiles will be kept continuously covered. Active faces of stockpiles being worked will be covered at the end of each work day. The stockpile area will be identified as containing asbestos by placement of placards at the stockpile area. Soils identified as containing asbestos that will be live loaded will be managed in accordance with the NT Plan.

• Equipment and wheels of vehicles that contact asbestos-impacted soil will be decontaminated as described below,

using a “wheel wash” prior to moving onto public streets.

• During on-Site truck transport of excavated soils identified as containing asbestos to the stockpile area, the truck loads will be dampened as necessary for transport. If this is not effective in preventing generation of dust, the trucks will be covered with tarps to minimize potential dust generation during on-Site transport.

Dust control will be performed by the Contractor during excavation, stockpiling, and all other earthwork operations at the Site. The Contractor will provide all required measures to control the generation of dust from Site activities and to prevent off-Site dust migration. Dust suppression techniques such as wetting, misting soil covering, ensuring the material is damp when excavated, loaded, and transported, strategic placement of wind barriers, and/or the application of temporary covering agents will be employed as necessary to reduce dust levels. Wetting techniques will be controlled so as not to cause runoff and soil erosion. Dust suppression techniques will be modified or enhanced if on-Site dust is visually observed or if monitoring indicates exceedances of maximum allowable dust levels in accordance with 310 CMR 6.00 or for the air- borne asbestos levels.

DECONTAMINATION OF EQUIPMENT AND VEHICLES

Vehicles and other equipment used during soil disturbance in areas where asbestos is detected in soil will be decontaminated prior to leaving the Site (exclusion zone). One or more decontamination (decon) facilities will be constructed utilizing two layers of 0.45 mil rubber roof membrane sufficient in length and width to accommodate the cleaning of all heavy equipment, trailers and dumpsters prior to their exiting identified asbestos work zone areas. The rubber membrane will be formed over haybales and secured to the ground to form a damming barrier so that all wash water can be effectively collected to be processed through a 5-micron filtering system, either at the individual decon facilities or in the on-Site treatment plant. Following filtering, this water will be infiltrated into the on-site soils using recharge pits. If necessary, the water (after filtration) may be pumped to the currently operating on-Site water treatment system for additional treatment prior to discharge. Refer to Figure 2 for the proposed layout of work zones and decontamination areas.

ENVIRONMENTAL MONITORING PLAN

Dust monitoring around the entire perimeter of the Project Area will continue as detailed in the May 3rd RAM Plan. In addition, air sampling stations for asbestos sampling will be established at the four perimeter stations and four interior locations as shown on Figure 3. Four sampling stations at each compass direction will also be established adjacent to each work location where asbestos-impacted soil will be disturbed.

Samples from the perimeter, interior and work locations will be collected and analyzed as follows:

• High flow pumps will be used to collect air samples with sufficient air volumes to achieve detection limits below 0.010 fibers per cubic centimeter (f/cc). During full workdays, two sets of samples will be collected around each location: one set for approximately half of the workday (morning) and a second set of the remainder of the workday (afternoon). These work zone air samples will be appropriately spaced and located proximate to each area where the above described activities are being performed.

• Samples will be analyzed for total airborne fibers, including but not specific to asbestos, using Phase Contrast Microscopy (PCM) on an immediate turn-around time basis. Results from the first set of samples will be available quickly enough so that corrective actions, if warranted, can be implemented the same workday. Results from the second set will be available such that corrective actions, if warranted, can be implemented by the morning of the next workday.

Any individual perimeter air sampling result that meets or exceeds 0.010 f/cc will result in the temporary stoppage of dust generating activities in the work area and the reevaluation and improvement of work practices, engineering controls, and dust/fibers suppression methods, as warranted.

at NERO.asbestos@state.ma.us. Notification will also be provided immediately to the MassDEP upon receipt of results

meeting or exceeding 0.010 f/cc.

Air samples will be collected by LBP Solutions or other acceptable companies. All samples will be analyzed via PCM on site by LBP personnel (or personnel with a similar acceptable company) or by a laboratory certified by the Massachusetts Department of Labor Standards (DLS), Division of Occupations Safety for PCM analysis.

During disturbance of asbestos-containing material, GZA will monitor for dust adjacent to the work area using a Thermo Scientific MIE pDR-1000 DataRam Dust Monitor (total dust meter) and a Thermo Scientific MIE pDR-1500 (PM10 dust meter). If dust or air-borne asbestos levels exceed the action level specified in the Contractor’s Health and Safety Plan, the Contractor will modify its dust-suppression techniques as necessary to maintain a permissible level of dust.

OFF-SITE SOIL DISPOSAL

Bulk loading, transportation, and off-Site disposal of soils identified as containing asbestos will be performed in accordance with the NT Plan.

The following facilities are currently proposed to receive soils identified as containing asbestos:

• Waste Management Crossroads Landfill, Norridgewock, Maine. This facility will be used for soils that do not require treatment for TCLP lead and/or arsenic and that contain asbestos at concentrations above 1%. Soils will be transported via tractor trailer to this facility.

• Waste Management Turnkey (TREE) Landfill, Rochester, New Hampshire. This facility will be used for soils that require treatment for TCLP lead and/or arsenic and that contain asbestos at concentrations both above and below 1%. Soils will be transported via tractor trailer to this facility.

• Waste Industries Taylor County Disposal Landfill, Georgia. This facility will be used for soils that do or do not require treatment for TCLP lead and/or arsenic and that contain less than 1% asbestos concentrations. Soils will be transported via railroad to this facility.

• Allied Niagara Landfill, Niagara Falls, New York. This facility will be used for soils that require treatment for TCLP lead and/or arsenic and that contain asbestos at concentrations equal to or greater than1%. These soils will be transported via tractor trailer.

Please note that soils transported via tractor-trailer or railroad will be placed inside sealable liner systems. Soils disposed of off-Site will be transported under a MassDEP form BWSC 112, Bill of Lading (BOL).

TREATMENT OF SOIL FOR TCLP EXCEEDANCES

Soil that precharacterization testing has shown to exceed TCLP levels for lead and arsenic is currently being treated on- Site to render it non-hazardous before it is shipped for off-Site disposal. If testing shows thatthe soil to be treated contains asbestos, it will be constantly wetted during the treatment process and it will be covered with GeoMatrix Permeable Fiber Mat or Gorilla-Snot™ when stored in the Stockpile and Treatment area before it is removed from the Site.

The treatment chemical being used to stabilize the TCLP soils is a liquid-based agent, the SDS for which is attached to this revised RAM Plan Modification in Appendix C. As described in Appendix E of the May 3rd RAM Plan, soils classified as

performed by uniform spray application of the treatment liquid.  A dedicated piece of earthmoving equipment will  work

within the treatment area and move soil during soil treatment. This equipment will be decontaminated in accordance with the procedures outlined herein prior to leaving the treatment area and/or handling soils that do not contain asbestos.

HANDLING AND DISPOSAL OF ON-SITE GROUNDWATER TREATMENT SYSTEM WASTES

As described in the May 3 RAM Plan, groundwater from excavation dewatering operations and runoff into the excavation are pumped through an on-Site treatment system and discharged under an RGP NOI filed on May 25, 2016. Waste sludge generated during the operation of the water treatment system (backwashing materials, etc.) will be pumped to a frac tank to allow for fines to settle. After settling, the water will be pumped from the frac tank back through the treatment system. Solid materials (sediment) within the frac tank will placed within a bermed area to allow for remaining water to exfiltrate from the sediment and infiltrate back into the Site. After exfiltration, the sediment will be added to the soils undergoing TCLP treatment and disposed of along with these soils under the provisions of the May 3 RAM Plan. Waste carbon from the treatment system will be transported off-site for regeneration and recycling or disposal. To date there has not been any carbon breakthrough. The carbon in the treatment system has been changed out once. Carbon in the primary filter was replaced on October 19, 2016; carbon from the secondary filter was replaced on October 20. Resin replacement has not been required.

Backwashing of the water treatment system’s carbon filters will be conducted when there is a pressure differential from the influent to the effluent in any of the media vessels of more than 10 PSI. This is currently occurring approximately once every 4 to 5 days of treatment plant operation. Backwashing is completed by reversing the flow direction at a rate of 1.25 times the maximum typical flowrate for 0.5-1 hour per vessel (or until the backwash water is clear). Backwashing will be conducted using a dedicated diesel pump and treated effluent water; the treated effluent is collected by redirecting the discharge flow from the water treatment system to a dedicated 21,000-gallon backwash storage tank. When a backwash event occurs, water will be pumped from the treated effluent storage tank through the targeted media vessel to one of two backwash frac tanks. Backwashing will continue as long as necessary or until storage capacity is no longer available. Backwash water will be allowed to settle and the decant from the frac tanks will be pumped back through the water treatment system. Sludge material removed from the backwash frac tanks will be treated with the TCLP soils as discussed above. Each carbon filter will be backwashed with approximately 15,000 gallons of water; less than 500 gallons of sludge is generated.

Within the next week, the treatment system will be augmented with a secondary treatment train capable of treating up to 100 gallons per minute that will be used for the treatment of water generated from Site activities other than water from the main garage excavation dewatering system. Wastewater from tieback operations will be pumped to the secondary system due to the high concentration of polymers in that waste water stream. The secondary system will allow the TSS in the tieback waste stream to settle out, be treated, and discharged. Refer to the attached treatment system information in Appendix E that was provided by the Contractor for more details on this secondary treatment system.

Once the second system is operational, it is anticipated that the primary treatment system will need to be backwashed approximately every two weeks and the carbon will not need to be replaced again. The treatment systems are/will be operated by a licensed operator.

As previously noted, wastewater from the decon facilities at the Site will be processed through 5-micron filter bags and then either infiltrated into on-site soils, or directed through the on-Site treatment system. Used 5-micron filtration bags will be disposed of as asbestos-containing material.

The seal and signature of the Licensed Site Professional (LSP) for this revised RAM Plan Modification (Lawrence Feldman, LSP #8107) are provided on the attached transmittal form in Appendix B.

NT PLAN

The following sections contain the text of the NT Plan, as prepared by EH&E. EH&E prepared this revised NT Plan describing the measures to be implemented for the bulk loading, packaging, transport, and offsite disposal of soils that are asbestos-contaminated waste materials (ACWMs) during the Project. Figures and appendices from the NT Plan are included as Appendix D.

DOCUMENTATION

MassDEP Form AQ 36 Application for Non-Traditional Asbestos Abatement Work Practice Approval has already been submitted with this NT Plan along with the $600 fee (refer to Appendix A). After approval of this NT Plan, the contractor will file Asbestos Notification Form ANF-001 to the MassDEP Northeastern Regional Office (NERO) Asbestos Program. The contractor will not proceed with bulk loading or disposal of ACWMs before 10 business days after submitting ANF 001, unless a waiver to this waiting period is obtained from the MassDEP.

The contractor is New Roads Environmental Services, LLC (New Roads). New Roads will perform all asbestos-related activities required under this NT Plan, including waste packaging and vehicle decontamination. J. Derenzo Company will perform all earthwork (excavating/loading). Project monitoring and perimeter air sampling required by this plan will be performed by LBP Solutions, LLC (LBP).

MATERIALS MANAGED UNDER THIS PLAN

Asbestos-contaminated materials excavated during the Project that are designated for offsite disposal will be bulk loaded and disposed of in accordance with this NT Plan; the packaging, transport, storage, disposal, and waste shipment record requirements for ACWMs outlined in 310 CMR 7.15 (15-18);¹ and the RAM Plan Modification dated November 16, 2016. Dust control, decontamination, and air monitoring will be conducted as outlined in this NT Plan. Building materials that are asbestos-containing materials and encountered during excavation will be handled in accordance with traditional asbestos abatement methods in compliance with federal, state, and local regulations.

The determination of what excavated materials will be disposed of offsite will be made by GZA in accordance with the RAM Plan. Although testing is ongoing, samples from less than 10% of the precharacterization grids with visible debris tested by GZA to date (per MassDEP requirements transmitted via email on October 19, 2016) have detectable asbestos in the soil. The figures in Appendix B of the NT Plan show the current status of asbestos in soil testing. All excess ACWM soil excavated on the Project will be disposed of off site. The volume of ACWMs to be disposed of under this NT Plan is currently estimated at 20,000 tons (approximately 12,000 cubic yards).

The site plans in Appendix C shows approximate bulk loading, soil management, and stockpiling locations (locations shown may be subject to modification in the field based on conditions encountered). In areas of the Site where asbestos is

¹ MassDEP. 310 CMR 7.15. Air Pollution Control. Code of Massachusetts Regulations. Title 310, Part 7, Section 15, Asbestos. Boston, MA: Commonwealth of Massachusetts, Department of Environmental Protection.

Modification dated November 16, 2016:

• During construction activities that have the potential to create dust, primarily excavation of soils identified as containing asbestos, the soil will be managed in such a way as to prevent the generation of visible dust and air monitoring will be performed. If dust is being generated by a specific activity involving disturbance of soil that activity will temporarily be halted until additional areas are wetted or misted with water. Temporary water lines or water trucks will be dedicated to each work area where soil with asbestos is disturbed.

• Excavated soil identified for off-Site disposal will either be live-loaded into tractor-trailers for off-Site disposal or will be stockpiled at the Stockpile and Soil Treatment Area. To maintain constructability, soil may need to be temporarily stockpiled near the work area while waiting for truck transport to the stockpile location area or off-Site disposal. Stockpiles will be covered with GeoMatrix Permeable Fiber Mat or Gorilla-Snot™ for dust control. In addition polyethylene sheeting may be used to cover stockpiles. If necessary, polyethylene sheeting will consist of 10-mil thick material that is ballasted over the stockpile. Stockpiles will be kept continuously covered. Active faces of stockpiles being worked will be covered at the end of each work day. The stockpile area will be identified as containing asbestos by placement of placards at the stockpile area.

• Equipment and wheels of vehicles that contact asbestos-impacted soil will be decontaminated using a “wheel wash”

prior to moving onto public streets.

• During on-Site truck transport of excavated soils identified as containing asbestos to the stockpile areas, the truck loads will be dampened as necessary for transport. If this is not effective in preventing generation of dust, the trucks will be covered with tarps to minimize potential dust generation during on-Site transport.

Soil that is contaminated with asbestos and lead will also be managed in accordance with the RAM Plan Modification dated November 16, 2016 (Page 5). There are currently approximately 4,900 cubic yards of ACWM soils stockpiled and treated or awaiting treatment in accordance with the following protocol:

• Soil that precharacterization testing has shown to exceed TCLP levels for lead and arsenic is currently being treated on- Site to render it non-hazardous before it is shipped for off-Site disposal. If testing shows that the soil to be treated contains asbestos, it will be constantly wetted during the treatment process and it will be covered with GeoMatrix Permeable Fiber Mat or Gorilla-Snot™ when stored in the Stockpile and Treatment area before it is removed from the project Site.

• The treatment chemical being used to stabilize soils is a liquid-based agent, the SDS for which is attached to this RAM Plan Modification in Appendix C. As described in Appendix E of the May 3, 2016 RAM Plan, soils classified as Hazardous Material B require treatment for TCLP lead and/or arsenic to facilitate off-Site disposal. Treatment will be performed by uniform spray application of the treatment liquid. A dedicated piece of earthmoving equipment will work within the treatment area and move soil during soil treatment. This equipment will be decontaminated in accordance with the procedures outlined herein prior to leaving the treatment area and/or handling soils that do not contain asbestos.

Dust control will be implemented by the contractor during all ACWM bulk loading operations at the Project in accordance with the provisions of the RAM Plan described above. The contractor will provide all required measures to control the generation of dust from activities and to prevent visible dust emissions will be employed as necessary to control dust levels. Wetting techniques will be used, including the use of direct-sprayed water in active work zones. Clean (city) water sources will be used for dust control. Dust control will occur in accordance with the RAM Plan Modification dated November 16, 2016.

• Dust control will be performed by the Contractor during excavation, stockpiling, and all other earthwork operations at the Site. The Contractor will provide all required measures to control the generation of dust from Site activities and to prevent off-Site dust migration. Dust suppression techniques such as wetting, misting soil covering, ensuring the material is damp when excavated, loaded, and transported, strategic placement of wind barriers, and/or the application of temporary covering agents will be employed as necessary to reduce dust levels. Wetting techniques will be controlled so as not to cause runoff and soil erosion. Dust suppression techniques will be modified or enhanced if on-Site dust is visually observed or if monitoring indicates exceedances of maximum allowable dust levels in accordance with 310 CMR 6.00 or for the air-borne asbestos levels.

If visible dust is observed in an area of ACWM soils, or if monitoring indicates exceedances of the airborne fiber levels described below, work will temporarily halt in the applicable work zone, the MassDEP will be notified immediately, and dust suppression techniques will be modified or enhanced. Visible emissions from non-suspect sources such as vehicle exhausts, road dust from uncontaminated construction areas, pollen, etc. will not be considered cause for work stoppage.

DECONTAMINATION

After being loaded with ACWMs, road vehicles will pass through designated vehicle decontamination areas at the entrance/exit to the work area prior to entering areas accessible to the public. Railcars will not contact the ground. A vehicle wash pad will be established in each work zone. The Contractor will use the wash pad for the decontamination of equipment that contacts potentially asbestos contaminated materials. The vehicle wash pad will be constructed in accordance with the RAM Plan Modification dated November 16, 2016:

• Vehicles and other equipment used during soil disturbance in areas where asbestos is detected in soil will be decontaminated prior to leaving the Site (exclusion zone). One or more decontamination (decon) facilities will be constructed utilizing two layers of 0.45 mil rubber roof membrane sufficient in length and width to accommodate the cleaning of all heavy equipment, trailers and dumpsters prior to their exiting identified asbestos work zone areas. The rubber membrane will be formed over haybales and secured to the ground to form a damming barrier so that all wash water can be effectively collected to be processed through a 5-micron filtering system, either at the individual decon facilities or in the on-Site treatment plant. Following filtering, this water will be infiltrated into the on-site soils using recharge pits. If necessary, the water (after filtration) may be pumped to the currently operating on-Site water treatment system for additional treatment prior to discharge.

No mechanical processing (screening, crushing, milling) of ACWM will occur. Nonporous materials impacted by potentially asbestos-contaminated soils (e.g., onsite granite, curbing, benches, and revetment stones), and designated for offsite disposal, will be disposed of as ACWM, unless these materials are culled and decontaminated. The equipment decontamination facilities in the work areas will be used for this cleaning unless sequencing requires an additional facility,

for disposal as non-asbestos waste will be cleaned and all adhered soil removed.

WORK ZONE PERIMETER ASBESTOS MONITORING

Air samples will be collected around the perimeter of ACWM bulk loading and, as described in the RAM Plan Modification, excavating, handling, and stockpiling operations for the Project:

• Area air samples will be collected in at least four locations around each operation. High flow pumps will be used to collect air samples with sufficient air volumes to achieve detection limits below 0.010 fibers per cubic centimeter (f/cc). During full workdays, two sets of samples will be collected around each location: one set for approximately half of the workday (morning) and a second set for the remainder of the workday (afternoon).

• Samples will be analyzed for total airborne fibers, including but not specific to asbestos, using Phase Contrast Microscopy (PCM) on an immediate turn-around time basis. Results from the first set of samples will be available quickly enough that corrective actions, if warranted, can be implemented the same workday. Results from the second set will be available such that corrective actions, if warranted, can be implemented by the morning of the next workday.

• Any individual perimeter air sampling result that meets or exceeds 0.010 f/cc potentially related to Project work will result in the temporary stoppage of dust generating activities in the work area and the re-evaluation and improvement of work practices, engineering controls, and dust/fiber suppression methods, as warranted.

• Air sampling results will be provided on a daily basis to the MassDEP NERO Asbestos Program at NERO.asbestos@state.ma.us. Notification will also be provided immediately to the MassDEP upon receipt of results meeting or exceeding 0.010 f/cc.

• Air samples will be collected by LBP and analyzed via PCM onsite by LBP personnel. Prior to commencing activities relative to excavation, handling, hauling, stockpiling, treating, and/or bulk loading soils that contain asbestos, the Contractor and GZA’s sub-consultant performing work zone monitoring (LBP) will coordinate the areas where activities will be performed and establish at least four high-flow pumps for collection of air samples in accordance with this plan. These work zone air samples will be appropriately spaced and located proximate to each area where the above described activities are being performed.

Additional air sampling will be performed in a consistent manner at four permanent air monitoring stations located at the perimeter of the site as described in the RAM Plan.

BULK LOADING

The contractor is responsible for managing potential ACWMs designated for offsite disposal on the Project in accordance with this NT Plan; with the packaging, transport, storage, disposal, and waste shipment record requirements for ACWMs outlined in 310 CMR 7.15 (15-18); and with other applicable federal, state, and local requirements. All work activities will also be conducted in accordance with the contractor site-specific health and safety plans. Bulk loading shall occur only in designated and controlled Project work areas as described below.

ACWM designated for offsite disposal will be bulk loaded into railcars lined with one 6-mil RailPac polyethylene bag inside a 14-mil RailPac polyethylene bag, which are form-fitted for railcars. Once filled to acceptable load capacity, the 6-mil bags will be overlapped and sealed individually utilizing spray glue and duct tape. The 14-mil liners are made of woven polyethylene for durability and tear/puncture resistance, and are approved under current railroad regulations for this type of material. Once filled to acceptable capacity, the 14-mil bags will be zipped, buckled and strapped. Appendix D includes RailPac product data sheets, instructions for use, as well as a statement from the manufacturer regarding their leak-proof properties. Appropriate labels will be adhered to the bags including asbestos warning labels and waste generator labels. An asphalt access road will be installed along the rail tracks to facilitate loading of rail cars.

It is anticipated that the majority of offsite disposal of ACWM with less than 1% asbestos will be via railway transport, although some soils with less than 1% asbestos may be transported on roadways, depending on schedule.

Bulk Loading for Road Transport

ACWM designated for offsite disposal will be bulk loaded into trailers/dumpsters that have been lined with two 10-mil bladder bags. Once filled to acceptable load capacity, bladder bags will be overlapped and sealed individually utilizing spray glue and duct tape. Appropriate labels will be adhered to the bladder bags including asbestos warning labels and waste generator labels. The trucks or roll-off dumpsters will be in good condition with no holes or rusted out areas and with tailgates that close tightly and are lockable. U.S. Department of Transportation (DOT) Class 9 placards (2212) will be affixed to all exterior sides of each dumpster/truck onsite.

All ACWM with equal to or greater than 1% asbestos will be handled and disposed of through road transport. Current test results indicate the presence of only very limited volumes of soil containing greater than 1% asbestos (approximately 700 cubic yards). Only limited amounts of ACWM with less than 1% asbestos will be handled through road transport.

TRANSPORT

Contractor will transport ACWM generated during the Project and designated for offsite disposal to a landfill permitted to accept the waste. With each waste shipment, the contractor will complete a waste shipment record (WSR) with all information required by 40 CFR 61.150 and 310 CMR 7.15(18). The contractor will provide the owner with WSR within 30 days following waste disposal. The contractor shall submit copies of WSRs to MassDEP NERO on a daily basis via NERO.asbestos@state.ma.us. All packaged waste materials will include warning labels, waste generator labels, and waste shipment records as required by applicable regulations, including 310 CMR 7.15(15). Labels shall be printed in letters of sufficient size and contrast so as to be readily visible and legible.

Roadways

A DOT licensed hauler will transport and dispose of the waste at a landfill permitted to accept asbestos waste. Each truck shall display the orange placard indicating the transport of asbestos-containing materials (Special Waste). The contractor shall ensure that no water leaks from the waste trailers, open top roll-offs, or the asbestos contractor’s transport vehicles while onsite or during transport and that the waste is covered at all times during transport.

Once the railcar is filled, transportation shall be handled pursuant to U.S. Interstate Commerce Law and in compliance with Federal Railroad Regulations and Rail Tariffs. The contractor will ensure that no water leaks from the waste container on site or during transport to the landfill, and that the waste is covered at all times during transport.

DISPOSAL FACILITIES

Contractor will dispose of all ACWM generated during the Project and designated for offsite disposal in a landfill permitted to accept the waste. The following facilities will receive soils identified as containing asbestos in accordance with the requirements of the RAM Plan Modification dated November 16, 2016:

• Waste Management Crossroads Landfill, Norridgewock, Maine. This facility will be used for soils that do not require treatment for TCLP lead and/or arsenic and that contain asbestos at concentrations above 1%. Soils will be transported via tractor trailer to this facility.

• Waste Management Turnkey (TREE) Landfill, Rochester, New Hampshire. This facility will be used for soils that require treatment for TCLP lead and/or arsenic and that contain asbestos at concentrations both above and below 1%. Soils will be transported via tractor trailer to this facility.

• Waste Industries Taylor County Disposal Landfill, Georgia. This facility will be used for soils that do or do not require treatment for TCLP lead and/or arsenic and that contain less than 1% asbestos concentrations. Soils will be transported via railroad to this facility.

• Allied Niagara Landfill, Niagara Falls, New York. This facility will be used for soils that do require treatment for TCLP lead and/or arsenic and that contain asbestos at concentrations equal to or greater than 1%. These soils will be transported via tractor trailer.

If you should require any further information concerning the planned RAM activities, please do not hesitate to contact the undersigned at (781) 278-3700.

Very truly yours,

GZA GEOENVIRONMENTAL, INC.

William R. Norman, LSP Consultant/Reviewer

Lawrence Feldman, LSP Senior Principal

Figure 1                Site Locus

Figure 2                Asbestos Exclusion Zone

Figure Figure 3                                Air Monitoring Figure

Appendix A                                Limitations

Appendix B         Transmittal Forms BWSC106

Appendix C                                SDS for Soil Treatment

Appendix D  NT Plan and Attachments

Appendix E         Secondary Treatment System Information Provided by J. Derenzo Corporation

J:170,000-179,999171521171521-52.MPSConstruction RAM Plan ModificationWynn Construction RAM Plan Modification – 11-16-16 – FINAL.docx

FIGURES

USE OF REPORT

1. GZA GeoEnvironmental, Inc. (GZA) prepared this report on behalf of, and for the exclusive use of our Client for the stated purpose(s) and location(s) identified in the Proposal for Services and/or Report. Use of this report, in whole or in part, at other locations, or for other purposes, may lead to inappropriate conclusions; and we do not accept any responsibility for the consequences of such use(s). Further, reliance by any party not expressly identified in the agreement, for any use, without our prior written permission, shall be at that party’s sole risk, and without any liability to GZA.

STANDARD OF CARE

1. GZA’s findings and conclusions are based on the work conducted as part of the Scope of Services set forth in the Proposal for Services and/or Report and reflect our professional judgment. These findings and conclusions must be considered not as scientific or engineering certainties, but rather as our professional opinions concerning the limited data gathered during the course of our work. Conditions other than described in this report may be found at the subject location(s).

1. GZA’s services were performed using the degree of skill and care ordinarily exercised by qualified professionals performing the same type of services, at the same time, under similar conditions, at the same or a similar property. No warranty, expressed or implied, is made. Specifically, GZA does not and cannot represent that the Site contains no hazardous material, oil, or other latent condition beyond that observed by GZA during its study. Additionally, GZA makes no warranty that any response action or recommended action will achieve all of its objectives or that the findings of this study will be upheld by a local, state or federal agency.

1. In conducting our work, GZA relied upon certain information made available by public agencies, Client and/or others. GZA did not attempt to independently verify the accuracy or completeness of that information. Inconsistencies in this information which we have noted, if any, are discussed in the Report.

SUBSURFACE CONDITIONS

1. The generalized soil profile(s) provided in our Report are based on widely-spaced subsurface explorations and are intended only to convey trends in subsurface conditions. The boundaries between strata are approximate and idealized, and were based on our assessment of subsurface conditions. The composition of strata, and the transitions between strata, may be more variable and more complex than indicated. For more specific information on soil conditions at a specific location refer to the exploration logs. The nature and extent of variations between these explorations may not become evident until further exploration or construction. If variations or other latent conditions then become evident, it will be necessary to reevaluate the conclusions and recommendations of this report.

1. Water level readings have been made, as described in this Report, in and monitoring wells at the specified times and under the stated conditions. These data have been reviewed and interpretations have been made in this report.  Fluctuations  in the level of the groundwater however occur due to temporal or spatial variations in areal recharge rates, soil heterogeneities, the presence of subsurface utilities, and/or natural or artificially induced perturbations. The observed water table may be other than indicated in the Report.

COMPLIANCE WITH CODES AND REGULATIONS

1. We used reasonable care in identifying and interpreting applicable codes and regulations necessary to execute our scope of work. These codes and regulations are subject to various, and possibly contradictory, interpretations. Interpretations and compliance with codes and regulations by other parties is beyond our control.

SCREENING AND ANALYTICAL TESTING

1. GZA collected environmental samples at the locations identified in the Report. These samples were analyzed for the specific parameters identified in the report. Additional constituents, for which analyses were not conducted, may be present in soil, groundwater, surface water, sediment and/or air. Future Site activities and uses may result in a requirement for additional testing.

1. Our interpretation of field screening and laboratory data is presented in the Report. Unless otherwise noted, we relied upon the laboratory’s QA/QC program to validate these data.

1. Variations in the types and concentrations of contaminants observed at a given location or time may occur due to release mechanisms, disposal practices, changes in flow paths, and/or the influence of various physical, chemical, biological or radiological processes. Subsequently observed concentrations may be other than indicated in the Report.

INTERPRETATION OF DATA

1. Our opinions are based on available information as described in the Report, and on our professional judgment. Additional observations made over time, and/or space, may not support the opinions provided in the Report.

ADDITIONAL INFORMATION

1. In the event that the Client or others authorized to use this report obtain additional information on environmental or hazardous waste issues at the Site not contained in this report, such information shall be brought to GZA’s attention forthwith. GZA will evaluate such information and, on the basis of this evaluation, may modify the conclusions stated in this report.

ADDITIONAL SERVICES

1. GZA recommends that we be retained to provide services during any future investigations, design, implementation activities, construction, and/or property development/ redevelopment at the Site. This will allow us the opportunity to: i) observe conditions and compliance with our design concepts and opinions; ii) allow for changes in the event that conditions are other than anticipated; iii) provide modifications to our design; and iv) assess the consequences of changes in technologies and/or regulations.

CONCEPTUAL SITE MODEL

1. Our opinions were developed, in part, based upon a comparison of site data to conditions anticipated within our Conceptual Site Model (CSM). The CSM is based on available information, and professional judgment. There are rarely sufficient data to develop a unique CSM. Therefore observations over time, and/or space, may vary from those depicted in the CSM provided in this report. In addition, the CSM should be evaluated and refined (as appropriate) whenever  significant new information and/or data is obtained.

RISK CHARACTERIZATION

1. Our risk evaluation was performed in accordance with generally accepted practices of appropriate Federal and/or state regulatory agencies, and of other consultants undertaking similar studies at the same time, for similar purposes, and under similar circumstances. The findings of the risk evaluation are dependent on the numerous assumptions and uncertainties inherent in the risk characterization process. Sources of the uncertainty may include Site conditions; Site use; the nature, extent, concentration and distribution of contaminants; and the available toxicity and/or health/risk  based regulatory information. Consequently, the findings of the risk characterization are not an absolute

characterization of actual risks; but rather serve to highlight potential incremental risks associated with activities indicated in the Report. Actual risks may be other than indicated in the Report.

a

Appendix B – Transmittal Form BWSC106

Appendix C – SDS for Soil Treatment

Appendix D – NT Plan Attachments

Environmental Health & Engineering, Inc.

117 Fourth Avenue Needham, MA 02494-2725

TEL 800-825-5343

781-247-4300

FAX 781-247-4305

www.eheinc.com

November 16, 2016

Massachusetts Department of Environmental Protection Northeast Regional Office

Attention: Asbestos Section 205B Lowell Street Wilmington, MA 01887

RE:      Revised Non-Traditional Asbestos Abatement Work Plan – Wynn Boston Harbor (EH&E 21151)

To Whom It May Concern:

On behalf of Wynn MA, LLC, Environmental Health & Engineering, Inc. (EH&E) prepared this revised non-traditional asbestos abatement work plan (NT Plan) describing the measures to be implemented for bulk loading, packaging, transport, and offsite disposal of soils that are asbestos-contaminated waste materials (ACWMs) during the Wynn Boston Harbor development project (the Project) located at 1 Horizon Way in Everett, Massachusetts. Activities described in this NT Plan are also subject to the Release Abatement Measure (RAM) Plan Modification (RTN: 3-0013341) for the Project prepared by GZA GeoEnvironmental, Inc. (GZA) dated

November 16, 2016 and submitted to the Massachusetts Department of Environmental Protection (MassDEP) via eDEP on this date.

DOCUMENTATION

MassDEP Form AQ 36 Application for Non-Traditional Asbestos Abatement Work Practice Approval has already been submitted with this NT Plan along with the $600 fee (refer to Appendix A). After approval of this NT Plan, the contractor will file Asbestos Notification Form ANF-001 to the MassDEP Northeastern Regional Office (NERO) Asbestos Program. The contractor will not proceed with bulk loading or disposal of ACWMs before 10 business days after submitting ANF 001, unless a waiver to this waiting period is obtained from the MassDEP.

The contractor is New Roads Environmental Services, LLC (New Roads). New Roads will perform all asbestos-related activities required under this NT Plan, including waste packaging and vehicle decontamination. J. Derenzo Company will perform all earthwork (excavating/loading). Project monitoring and perimeter air sampling required by this plan will be performed by LBP Solutions, LLC (LBP).

MATERIALS MANAGED UNDER THIS PLAN

Asbestos-contaminated materials excavated during the Project that are designated for offsite disposal will be bulk loaded and disposed of in accordance with this NT Plan; the packaging, transport, storage, disposal, and waste shipment record requirements for ACWMs outlined in 310 CMR 7.15 (15-18);¹ and the RAM Plan Modification dated November 16, 2016. Dust control, decontamination, and air monitoring will be conducted as outlined in this NT Plan. Building materials that are asbestos-containing materials and encountered during excavation will be handled in accordance with traditional asbestos abatement methods in compliance with federal, state, and local regulations.

The determination of what excavated materials will be disposed of offsite will be made by GZA in accordance with the RAM Plan. Although testing is ongoing, samples from less than 10% of the precharacterization grids with visible debris tested by GZA to date (per MassDEP requirements transmitted via email on October 19, 2016) have detectable asbestos in the soil. The figures in Appendix B show the current status of asbestos in soil testing. All excess ACWM soil excavated on the Project will be disposed of offsite. The volume of ACWMs to be disposed of under this NT Plan is currently estimated at 20,000 tons (approximately 12,000 cubic yards).

The site plans in Appendix C shows approximate bulk loading, soil management, and stockpiling locations (locations shown may be subject to modification in the field based on conditions encountered). In areas of the Site where asbestos is detected in the soil, the following management procedures will be implemented in accordance with the RAM Plan Modification dated November 16, 2016 (Pages 2 and 3):

• During construction activities that have the potential to create dust, primarily excavation of soils identified as containing asbestos, the soil will be managed in such a way as to prevent the generation of visible dust and air monitoring will be performed. If dust is being generated by a specific activity involving disturbance of soil that activity will temporarily be halted until additional areas are wetted or misted with water. Temporary water lines or water trucks will be dedicated to each work area where soil with asbestos is disturbed.

• Excavated soil identified for off-Site disposal will either be live-loaded into tractor-trailers for off-Site disposal or will be stockpiled at the Stockpile and Soil Treatment Area. To maintain constructability, soil may need to be temporarily stockpiled near the work area while waiting for truck transport to the stockpile location area or off-Site disposal. Stockpiles will be covered with GeoMatrix Permeable Fiber Mat or Gorilla-Snot™ for dust control. In

¹ MassDEP. 310 CMR 7.15. Air Pollution Control. Code of Massachusetts Regulations. Title 310, Part 7, Section 15, Asbestos. Boston, MA: Commonwealth of Massachusetts, Department of Environmental Protection.

addition polyethylene sheeting may be used to cover stockpiles. If necessary, polyethylene sheeting will consist of 10-mil thick material that is ballasted over the stockpile. Stockpiles will be kept continuously covered. Active faces of stockpiles being worked will be covered at the end of each work day. The stockpile area will be identified as containing asbestos by placement of placards at the stockpile area.

• Equipment and wheels of vehicles that contact asbestos-impacted soil will be decontaminated using a “wheel wash” prior to moving onto public streets.

• During on-Site truck transport of excavated soils identified as containing asbestos to the stockpile areas, the truck loads will be dampened as necessary for transport. If this is not effective in preventing generation of dust, the trucks will be covered with tarps to minimize potential dust generation during on-Site transport.

Soil that is contaminated with asbestos and lead will also be managed in accordance with the RAM Plan Modification dated November 16, 2016 (Page 5). There are currently approximately 4,900 cubic yards of ACWM soils stockpiled and treated or awaiting treatment in accordance with the following protocol:

• Soil that precharacterization testing has shown to exceed TCLP levels for lead and arsenic is currently being treated on-Site to render it non-hazardous before it is shipped for off-Site disposal. If testing shows that the soil to be treated contains asbestos, it will be constantly wetted during the treatment process and it will be covered with GeoMatrix Permeable Fiber Mat or Gorilla-Snot™ when stored in the Stockpile and Treatment area before it is removed from the project Site.

• The treatment chemical being used to stabilize soils is a liquid-based agent, the SDS for which is attached to this RAM Plan Modification in Appendix C. As described in Appendix E of the May 3, 2016 RAM Plan, soils classified as Hazardous Material B require treatment for TCLP lead and/or arsenic to facilitate off-Site disposal. Treatment will be performed by uniform spray application of the treatment liquid. A dedicated piece of earthmoving equipment will work within the treatment area and move soil during soil treatment. This equipment will be decontaminated in accordance with the procedures outlined herein prior to leaving the treatment area and/or handling soils that do not contain asbestos.

DUST CONTROL

Dust control will be implemented by the contractor during all ACWM bulk loading operations at the Project in accordance with the provisions of the RAM Plan described above. The contractor will provide all required measures to control the generation of dust from activities and to prevent

visible dust emissions will be employed as necessary to control dust levels. Wetting techniques will be used, including the use of direct-sprayed water in active work zones. Clean (city) water sources will be used for dust control. Dust control will occur in accordance with the RAM Plan Modification dated November 16, 2016 (Page 3).

• Dust control will be performed by the Contractor during excavation, stockpiling, and all other earthwork operations at the Site. The Contractor will provide all required measures to control the generation of dust from Site activities and to prevent off-Site dust migration. Dust suppression techniques such as wetting, misting soil covering, ensuring the material is damp when excavated, loaded, and transported, strategic placement of wind barriers, and/or the application of temporary covering agents will be employed as necessary to reduce dust

levels. Wetting techniques will be controlled so as not to cause runoff and soil erosion. Dust suppression techniques will be modified or enhanced if on-Site dust is visually observed or if monitoring indicates exceedances of maximum allowable dust levels in accordance with 310 CMR 6.00 or for the air-borne asbestos levels.

If visible dust is observed in an area of ACWM soils, or if monitoring indicates exceedances of the airborne fiber levels described below, work will temporarily halt in the applicable work zone, the MassDEP will be notified immediately, and dust suppression techniques will be modified or enhanced. Visible emissions from non-suspect sources such as vehicle exhausts, road dust from uncontaminated construction areas, pollen, etc. will not be considered cause for work stoppage.

DECONTAMINATION

After being loaded with ACWMs, road vehicles will pass through designated vehicle decontamination areas at the entrance/exit to the work area prior to entering areas accessible to the public. Railcars will not contact the ground. A vehicle wash pad will be established in each work zone. The Contractor will use the wash pad for the decontamination of equipment that contacts potentially asbestos contaminated materials. The vehicle wash pad will be constructed in accordance with the RAM Plan Modification dated November 16, 2016 (Page 4):

Vehicles and other equipment used during soil disturbance in areas where asbestos is detected in soil will be decontaminated prior to leaving the Site (exclusion zone). One or more decontamination (decon) facilities will be constructed utilizing two layers of 0.45 mil rubber roof membrane sufficient in length and width to accommodate the cleaning of all heavy equipment, trailers and dumpsters prior to their exiting identified asbestos work zone areas. The rubber membrane will be formed over haybales and secured to the ground to form a damming barrier so that all wash water can be effectively collected to be processed through a 5-micron filtering system, either at the individual decon facilities or in the on-Site treatment plant. Following filtering, this water will be infiltrated into the on-site soils using

recharge pits. If necessary, the water (after filtration) may be pumped to the currently operating on-Site water treatment system for additional treatment prior to discharge.

No mechanical processing (screening, crushing, milling) of ACWM will occur. Nonporous materials impacted by potentially asbestos-contaminated soils (e.g., onsite granite, curbing, benches, and revetment stones), and designated for offsite disposal, will be disposed of as ACWM, unless these materials are culled and decontaminated. The equipment decontamination facilities in the work areas will be used for this cleaning unless sequencing requires an additional facility, which will be constructed in the same manner as the equipment decontamination facility. Nonporous material intended for disposal as non-asbestos waste will be cleaned and all adhered soil removed.

WORK ZONE PERIMETER ASBESTOS MONITORING

Air samples will be collected around the perimeter of ACWM bulk loading and, as described in the RAM Plan Modification, excavating, handling, and stockpiling operations for the Project:

• Area air samples will be collected in at least four locations around each operation. High flow pumps will be used to collect air samples with sufficient air volumes to achieve detection limits below 0.010 fibers per cubic centimeter (f/cc). During full workdays, two sets of samples will be collected around each location: one set for approximately half of the workday (morning) and a second set for the remainder of the workday (afternoon).

• Samples will be analyzed for total airborne fibers, including but not specific to asbestos, using Phase Contrast Microscopy (PCM) on an immediate turn-around time basis. Results from the first set of samples will be available quickly enough that corrective actions, if warranted, can be implemented the same workday. Results from the second set will be available such that corrective actions, if warranted, can be implemented by the morning of the next workday.

• Any individual perimeter air sampling result that meets or exceeds 0.010 f/cc potentially related to Project work will result in the temporary stoppage of dust generating activities in the work area and the re-evaluation and improvement of work practices, engineering controls, and dust/fiber suppression methods, as warranted.

• Air sampling results will be provided on a daily basis to the MassDEP NERO Asbestos Program at NERO.asbestos@state.ma.us. Notification will also be provided immediately to the MassDEP upon receipt of results meeting or exceeding 0.010 f/cc.
• Air samples will be collected by LBP and analyzed via PCM onsite by LBP personnel. Prior to commencing activities relative to excavation, handling, hauling, stockpiling, treating, and/or bulk loading soils that contain asbestos, the Contractor and GZA’s sub-consultant performing work zone monitoring (LBP) will coordinate the areas where activities will be performed and establish at least four high-flow pumps for collection of air samples in accordance with this plan. These work zone air samples will be appropriately spaced and located proximate to each area where the above described activities are being performed.

Additional air sampling will be performed in a consistent manner at four permanent air monitoring stations located at the perimeter of the site as described in the RAM Plan.

BULK LOADING

The contractor is responsible for managing potential ACWMs designated for offsite disposal on the Project in accordance with this NT Plan; with the packaging, transport, storage, disposal, and waste shipment record requirements for ACWMs outlined in 310 CMR 7.15 (15-18); and with other applicable federal, state, and local requirements. All work activities will also be conducted in accordance with the contractor site-specific health and safety plans. Bulk loading shall occur only in designated and controlled Project work areas as described below.

Bulk Loading for Rail Transport

ACWM designated for offsite disposal will be bulk loaded into railcars lined with one 6-mil RailPac polyethylene bag inside a 14-mil RailPac polyethylene bag, which are form-fitted for railcars. Once filled to acceptable load capacity, the 6-mil bags will be overlapped and sealed individually utilizing spray glue and duct tape. The 14-mil liners are made of woven polyethylene for durability and tear/puncture resistance, and are approved under current railroad regulations for this type of material. Once filled to acceptable capacity, the 14-mil bags will be zipped, buckled and strapped. Appendix D includes RailPac product data sheets, instructions for use, as well as a statement from the manufacturer regarding their leak-proof properties.

Appropriate labels will be adhered to the bags including asbestos warning labels and waste generator labels. An asphalt access road will be installed along the rail tracks to facilitate loading of rail cars.

It is anticipated that the majority of offsite disposal of ACWM with less than 1% asbestos will be via railway transport, although some soils with less than 1% asbestos may be transported on roadways, depending on schedule.

Bulk Loading for Road Transport

ACWM designated for offsite disposal will be bulk loaded into trailers/dumpsters that have been lined with two 10-mil bladder bags. Once filled to acceptable load capacity, bladder bags will be overlapped and sealed individually utilizing spray glue and duct tape. Appropriate labels will be adhered to the bladder bags including asbestos warning labels and waste generator labels. The trucks or roll-off dumpsters will be in good condition with no holes or rusted out areas and with tailgates that close tightly and are lockable. U.S. Department of Transportation (DOT) Class 9 placards (2212) will be affixed to all exterior sides of each dumpster/truck onsite.

All ACWM with equal to or greater than 1% asbestos will be handled and disposed of through road transport. Current test results indicate the presence of only very limited volumes of soil containing greater than 1% asbestos (approximately 700 cubic yards). Only limited amounts of ACWM with less than 1% asbestos will be handled through road transport.

TRANSPORT

Contractor will transport ACWM generated during the Project and designated for offsite disposal to a landfill permitted to accept the waste. With each waste shipment, the contractor will complete a waste shipment record (WSR) with all information required by 40 CFR 61.150 and 310 CMR 7.15(18). The contractor will provide the owner with WSR within 30 days following waste disposal. The contractor shall submit copies of WSRs to MassDEP NERO on a daily basis via NERO.asbestos@state.ma.us. All packaged waste materials will include warning labels, waste generator labels, and waste shipment records as required by applicable regulations, including 310 CMR 7.15(15). Labels shall be printed in letters of sufficient size and contrast so as to be readily visible and legible.

Roadways

A DOT licensed hauler will transport and dispose of the waste at a landfill permitted to accept asbestos waste. Each truck shall display the orange placard indicating the transport of asbestos- containing materials (Special Waste). The contractor shall ensure that no water leaks from the waste trailers, open top roll-offs, or the asbestos contractor’s transport vehicles while onsite or during transport and that the waste is covered at all times during transport.

Railways

Once the railcar is filled, transportation shall be handled pursuant to U.S. Interstate Commerce Law and in compliance with Federal Railroad Regulations and Rail Tariffs. The contractor will ensure that no water leaks from the waste container onsite or during transport to the landfill, and that the waste is covered at all times during transport.

Contractor will dispose of all ACWM generated during the Project and designated for offsite disposal in a landfill permitted to accept the waste. The following facilities will receive soils identified as containing asbestos in accordance with the requirements of the RAM Plan Modification dated November 16, 2016 (Pages 4 and 5):

• Waste Management Crossroads Landfill, Norridgewock, Maine. This facility will be used for soils that do not require treatment for TCLP lead and/or arsenic and that contain asbestos at concentrations above 1%. Soils will be transported via tractor trailer to this facility.

• Waste Management Turnkey (TREE) Landfill, Rochester, New Hampshire. This facility will be used for soils that require treatment for TCLP lead and/or arsenic and that contain asbestos at concentrations both above and below 1%. Soils will be transported via tractor trailer to this facility.

• Waste Industries Taylor County Disposal Landfill, Georgia. This facility will be used for soils that do or do not require treatment for TCLP lead and/or arsenic and that contain less than 1% asbestos concentrations. Soils will be transported via railroad to this facility.

• Allied Niagara Landfill, Niagara Falls, New York. This facility will be used for soils that do require treatment for TCLP lead and/or arsenic and that contain asbestos at concentrations equal to or greater than 1%. These soils will be transported via tractor trailer.

Sincerely,

Adam S. Bisol                                                             William S. Wade, C.I.H.

Massachusetts Certified                                              Senior Scientist/Project Manager Asbestos Designer AD034163

Appendix A    BWP AQ 36 Application and Copies of Payment and Transmittals Appendix B Current Asbestos in Soil Testing Results

Appendix C     Site Plans

Appendix D    Product Data Sheets and Leak Proof Statement for RailPac Railcar Liners Appendix E    Information for the New York and Georgia Landfills

cc:     John MacAuley, Asbestos Enforcement Section Chief, MassDEP NERO [via email] Andrew Clark, MassDEP NERO [via email]

Lawrence Feldman, LSP, Senior Principal, GZA GeoEnvironmental, Inc. [via email] Chris Gordon, Wynn MA, LLC. [via email]

Environmental Health & Engineering, Inc.  |  21151 | www.eheinc.com    9

APPENDIX A

BWP AQ 36 APPLICATION AND COPIES OF PAYMENT AND TRANSMITTALS

APPENDIX B

CURRENT ASBESTOS IN SOIL TESTING RESULTS

APPENDIX C SITE PLANS

APPENDIX D

PRODUCT DATA SHEETS AND LEAK PROOF STATEMENT FOR RAILPAC RAILCAR LINERS

APPENDIX E

INFORMATION FOR THE NEW YORK AND GEORGIA LANDFILLS

Appendix E – Secondary Treatment System Information Provided by J. Derenzo Corporation