ENVIRONMENTAL POLICY STATEMENT March 7, 2013 1.0 INTRODUCTION AND RECYCLING GOAL Atlanta Demolition (ADS) is an Atlanta-based demolition, environmental and recycling firm that is a U.S. Small Business Association small business. Utilizing traditional practices as well as emerging technologies, pioneering environmental stewardship has been central to the company’s culture and practices since its founding. This innovative approach, made possible by the founders’ extensive experience with regulatory requirements and environmental law, not only promotes sustainability but most often reduces costs. Atlanta Demolition has a long history of delivering successful large-scale demolition projects in and around Atlanta and the southeast, and has handled some of the larger and more difficult projects in Atlanta over the last five years. Our recent representative projects include the implosion and 96% recycling of the former Roosevelt Tower across North Avenue from Georgia Tech, the implosion and 93% recycling of the former IBM facility on Northside Parkway to make room for the new North Atlanta High School, and the demolition and 95% recycling of the former Hughes Spalding Children’s Hospital for Grady Health Services. Although full scale reuse, recycling and sustainability is still relatively new to the demolition industry, Atlanta Demolition has long been a pioneer in the market sector and has recycled in excess of 90% of each demolition project performed over the past four years. 2.0 ADS COMPANY PHILOSOPHY ON SUSTAINABILITY ADS’ waste management policies and practices are interwoven with all our operating and compliance principles and are consistent with our overall company-wide sustainability initiatives. It is ADS’ corporate goal to achieve at a minimum a Silver LEED Status for all projects we perform. We frequently achieve gold or platinum levels depending on the specific project parameters and conditions. Our waste management approach is based on the principle of addressing the 4Rs: Reduce Reuse Recycle Renew Reduce – Effect how the generation of “wastes” can be prevented. Reuse – After the determination of how waste generation can be prevented, wastes that can be salvaged are identified for reuse on the current project, reuse on another project, sold, or donated. Recycle – Determination of which waste materials/assets can be recycled. Page 2 of 8 Renew – All wastes and materials are evaluated in their totality to determine if they can be renewed and/or innovatively incorporated into the design of project operations and execution (such as backfilling, aggregate, landscaping, compost, or mulch). Reduce – At ADS we strongly believe that waste prevention is more beneficial and cost effective than recycling. Therefore our staff is well trained in identifying potential waste early in the project planning process which allows us to properly manage and decrease waste generated during demolition/deconstruction/dismantlement. Reuse – Whenever feasible, ADS will maximize the beneficial reuse options applicable to industrial, commercial, and institutional generators and users of solid by-products (waste) and sanitary landfills utilizing alternative cover material. Reuse is generally available to solid by-products that are being disposed of as solid waste in a Georgia landfill, and that meet certain requirements as described in this summary. Wastes/operations that are NOT eligible include: waste that has already been landfill-disposed, land application of solid waste, and solid waste processing operations or solid waste composting. The utilization of solid by-products as resources when such use improves, or at a minimum does not adversely affect, human health and the environment is economically beneficial to both the generator of the waste and the end user. Reuse also decreases the amount of solid waste entering landfills. Issuance of a beneficial use determination by the GAEPD relieves the generator and user(s) of Georgia solid waste requirements specifically noted in the written determination. As part of our sustainability efforts and to achieve the highest potential LEED status for a project, ADS will select the best option for managing a project’s waste; consider the value of the various materials. For instance, there may be materials on a project that have a greater value “as is” for salvage compared to their value as material for recycling. Some of these materials may be valuable to reuse on-site; others may be donated or sold to a used building material retailer or charitable organization. The initial costs for deconstruction services are usually offset by returns from salvaged materials or reduced purchasing costs. Some deconstruction services may also give a tax deduction for materials that are donated. In some cases, reused materials may also provide functional or aesthetic features not available with new materials. There are two ways to recover materials for salvage and reuse: 1. Deconstruct the building; or 2. Conduct a selective salvage operation prior to demolition. Deconstruction involves the careful dismantling of a whole structure in reverse order of assembly, usually by hand, to re-harvest materials for reuse. Salvage is the removal of certain valuable reusable building materials before demolition. Page 3 of 8 3.0 QUALITY ASSURANCE FOR WASTE PLAN AND DISPOSAL ACTIVITIES ADS will conduct waste management activities in compliance with EPA and all state laws, rules, regulations; local ordinances; and clients’ as well as our own internal policies and procedures. The key elements of the Waste Management Plan will be part of the post-award/pre-work meeting where we anticipate reviewing methods and procedures related to waste management including but not limited to the following: 3.1 waste management plan; requirements for documenting quantities of each type of waste and its disposition; finalization of procedures for materials separation and verification availability of containers and bins needed to avoid delays; procedures for periodic waste collection and transportation to recycling and disposal facilities; and waste management requirements for each waste stream and for each trade. Waste Management Report ADS will also develop a Waste Management Report which will include the submission of a cumulative waste management report including the following: a record of the type and quantity, by weight, of each material salvaged, reused, recycled or disposed; total quantity of waste recycled as a percentage of total waste; disposal receipts (copies of receipts issued by a disposal facility for C & D waste that is disposed in a landfill); recycling receipts (copies of receipts issued by an approved recycling facility) For co-mingled materials, ADS will include weight tickets from the recycling hauler or material recovery facility and verification of the recycling rate for co-mingled loads at the facility. Salvaged materials documentation will include the types and quantities, by weight, for materials salvaged for reuse on site, sold or donated to a third party. 4.0 SUSTAINABILITY Sustainable remediation and demolition/deconstruction can be defined as the practice of considering all environmental effects of logistical and operational remedy/demolition implementation while incorporating options to minimize the environmental footprints of our operations. ADS’ operations take into account not only the remedial action required, but also our ongoing operations before, during, and after the demolition operation. The following are some of the ADS’ key sustainability principles which we incorporate into all of our project planning: maximizing of recyclable and reusable materials; minimizing of wastes; minimizing of landfill/disposal facility capacity; Page 4 of 8 minimizing of carbon footprint resulting from project operations; minimizing of vehicle/truck conveyances; maximizing of renewable and cleaner sources of energy; maximizing use of “green”/post-consumer recycled products and materials; development of a sustainable site topographic restoration design which minimizes import materials (and associated efforts such as hauling and installation) needed; maximizing of water conservation techniques; implementation of sustainable post-design of principles for reuse of remediated land; and minimizing of air emissions as well as greenhouse gas generation. These key elements are also flow-down principles that we pass on to our team members and our subcontractors. The demolition and decommissioning of facilities offer some unique opportunities to demonstrate how important sustainability is to our environment and the success of our operations. The success of our operations begins in the planning phase (review the Post Award Submittals) and carries through to the final decommissioning of the facility and returning the site back to the owners in a truly sustainable status. With this philosophy in mind, we are committed to seamlessly integrating health, safety, environmental and sustainability considerations into all aspects of our projects to achieve a measurable net benefit to all stakeholders and achieve the project goal of attaining LEED Silver for this project. The planning phase actually starts during the proposal process when all of the alternatives are considered and we actually begin to address how each waste stream will be minimized and managed. All of the planning culminates in the final Waste Management Plan. It is prepared directly from the specifications of the solicitation. Considerations include the following: Estimate types and quantities of demolition waste generated during each phase of the project; Identify how each waste stream will be sensibly minimized, managed, marketed, and/or disposed of; Provide an estimate of the overall job recycling rate; Lay out plans for training, meetings, and other communications related to job-site waste and material reduction and management; and Provide troubleshooting instructions and contact information. Examples of the breakdown of materials by type and the information collected for each of the materials are shown in the following table. The table also illustrates the type of information that will be routinely be collected to document the project-recycling rate. Page 5 of 8 TABLE 1 – TYPICAL EXAMPLE SUSTAINABILITY TABLE MATERIAL TONS RECYCLING COST AVOIDED DISPOSAL COSTS SAVINGS NR Materials and Debris XX $ $ $ Ferrous Metals XX $ $ $ Non-ferrous Metals XX $ $ $ Concrete XX $ $ $ Block & Brick XX $ $ $ Reuse Items XX $ $ ($) RECYCLING TOTALS XX $ $ $ Mixed Debris to Disposal XX PROJECT RECYCLING RATE XX% Records of all materials reused, removed, and/or transported off-site will be maintained to complete the post-closure report and document the value of the recycling efforts. It is impossible to prove the value of waste reduction and recycling without good documentation. With these elements in mind, at the completion of the project, the ADS will provide a “Scorecard of Sustainable Accomplishments” of this project for both the company and the customer. The scorecard will provide, Impact on the Environment, Health and Safety Record, and the Economics of the project with a focus on Sustainability features of the project. 5.0 PRELIMINARY PLANNING SUSTAINABILITY AND SAFETY CONSIDERATIONS FOR Our sustainability planning process has already begun with a complete review of the project documents (available to date) and site visits to determine where ADS can make the most sustainable impacts on the project. Our approach will be refined upon award and in the course of a comprehensive and detailed waste and material survey. An estimate of the type and quantity of each material that can be reused or recycled has will be included in the plan for each project. The recycling rate will be reconciled with actual bills of lading at the conclusion of the project for the determination of the final recycling rate. ADS also considers the environmental impacts of our operations – among others - from: Page 6 of 8 Direct emissions: o Stationary combustion sources; o Mobile equipment and project offices; o Transportation of materials and wastes to and from the site; o Mobilization to and from the project site; o Travel and lodging; o Electricity consumption; o Purchased materials; and o Landfill impacts. Indirect emissions: o Corporate office emissions; o Material energy; o Greenhouse gases; o Water footprint; and o Recycling of on-site materials. Two items that substantially reduce the air emissions will be the use of ultra-low sulfur diesel or bio-diesel in our equipment and the amount of time the equipment is allowed to idle. The use of low-sulfur typically reduces the emissions of: particulate matter by 14%; nitrogen oxides by 3%; carbon monoxide by 6%; and hydrocarbons by 13%. Unnecessary equipment idling emits excess greenhouse gases, wastes fuel, causes excess engine wear, and can increase project costs. ADS’ corporate policies require the consideration of both of these sustainability measures. Segregation of the materials will improve the quality and quantity of material collected and recycled. Items being collected and segregated for reuse and recycling will be temporarily stored in designated areas until full vehicle/trailer loads of recycled materials can be removed from the site. This process will improve the segregation of materials and reduce the greenhouse emissions, increase safety, and minimize the carbon footprint of the project by eliminating excess vehicular traffic on the site. Page 7 of 8 6.0 RECOVERY OF IDENTIFIED RESOURCES OF REUSE AND RECYCLING We have developed an extensive network of used-equipment and material buyers, brokers and end users to maximize recycling and reuse resulting in the highest value for their material and thus lowest costs to our clients. ADS has developed a demolition plan that will allow us to identify and remove the recoverable materials from the structure during the predemolition phase of the project and move them off-site as quickly as possible. These materials will be segregated at the site as quickly and efficiently as possible. For example, we will segregate the recyclable material and store them in segregated piles until a full load can be accommodated, thereby reducing the trips required for removal of the materials and reducing the carbon footprint being developed during the project. 7.0 PROJECT CLOSEOUT AND REPORTING As the project nears the end ADS will request a meeting to discuss the final phases of the project and items such as the site grading and landscaping discussed above will be coordinated to assure that all aspects of the project are being planned and executed according to the contract specifications and the stakeholders’ expectations. This document is intended to detail the project operations and removal activities as well as all aspects of the segregation of material, recoverable assets, recyclables, and wastes to maximize the projects sustainability goals. During the project execution and especially during the recyclable material removal, the collection and analysis of the material disposition will be critical to making adjustments in how the materials are disposed of or reused so that the project sustainability goals are achieved. Communication of the project sustainability goals with all of the project team is critical to gaining support for achieving the goals. As each new phase of the project is initiated, all team members will be briefed on how each phase impacts the sustainability requirements. During these critical change-over periods all appropriate individuals will work closely together to make sure all recycling efforts are being monitored and adjusted in an attempt to achieve the LEED Silver status for the project. The success of achieving the sustainability goals for the project will be measured by the success of the recycling and reuse of as many components/materials/wastes as possible. The success will be reflected in the “Scorecard of Sustainable Accomplishments”. Page 8 of 8