2.5 Hazardous Materials Management

2.5.1 Asbestos and Other Hazardous Materials

Current Federal and State environmental statutes require that certain potentially hazardous materials that may be affected by building improvements or modifications involving activities such as construction, repair, maintenance, alterations, and renovations be identified and removed prior to conducting these activities. The requirements mandate that hazardous materials be identified in order to comply with worker and occupant/tenant safety, environmental, and disposal requirements. The primary materials of concern include, but are not limited to, asbestos-containing materials (ACM), lead-based paint, PCB, and mercury-containing building elements.

Prior to developing a scope of work for the proposed improvements or modifications, the Consultant, Contractor and/or Tenants are required to coordinate with the Environmental Compliance Section to obtain recent hazardous materials surveys and to arrange for a Hazardous Materials Site Assessment. An MDOT MAA contractor will inspect the area and provide a report describing the hazardous materials that will be affected by the proposed activities and recommendations for their removal or management. Hazardous materials removal services will be arranged and managed by the MDOT MAA or by the tenant. In either case, "third party" abatement oversight will be provided by the Environmental Compliance Section. The 100% plans shall be submitted to the Environmental Compliance Section for review and coordination.

The following shall be incorporated into the construction documents for hazardous materials abatement work:

A. The Contractor shall coordinate through CMI the scheduling of the Environmental Compliance inspectors and industrial hygienist during the construction demolition phase. The Environmental Compliance Inspectors and Industrial Hygienist would identify any suspect hazardous material that may have been inaccessible during design, for example behind a wall or under a floor. If hazardous material is found during demolition, a Field Revision will be issued by the Engineer.

B. Include Miscellaneous Work Allowance for unforeseen asbestos removal.

The following addresses the post abatement deliverables from abatement contractors and provides a consistent method of reporting required information. This is designed to be included in contracts or agreements between MDOT MAA and abatement contractors.

Contract Language for Office of Engineering & Construction to Provide to Abatement Contractors:

The Abatement Contractor shall perform work in accordance with the contract terms, applicable Federal and State regulations, and approved Abatement Design. Within thirty (30) days of project completion the Contractor shall provide an Abatement Closure Report. The submittal shall consist of two hard copies of the Closure Report and one electronic version in PDF format. The Closure Report must include a Title Page containing the site or renovation area, project name (what was removed from where), Contractor name and information, Contract number, and dates of abatement. An Abatement Summary must be provided that describes the materials removed, controls used, work procedures, total amount removed and location(s) of removal. Indicate if "all" materials were removed or if remnant materials remain and where.

The following appendices must be provided:

· Copies of Abatement Design/Work Plan

· Copies of EPA Notifications or permits (as applicable)

· Copies of Contractor Supervisor and Worker certificates/licenses

· Copies of Daily Sign in Logs and Inspection Logs

· Copies of Air Sample Results

· Copies of Waste Manifests

The hard copy and electronic reports shall be submitted to MDOT MAA’s Environmental Program Manager, Environmental Compliance Section for review and acceptance.

2.5.1.1 Management of Asbestos

For renovation work, a checklist should be formulated to insure all possible sources of asbestos have been removed (i.e., ceiling tile, floor tile, insulation, etc.). If asbestos is suspected, the MDOT MAA Environmental Compliance Officer shall be contacted to initiate the proper documentation and testing of the site and determination of the proper abatement procedures.

Column Covers: Many of the column covers in the terminal building consist of preformed asbestos cement. Because this material is non-friable, there is no health hazard associated with its undisturbed presence. Any cutting, sawing, drilling, or work which disturbs the column will require a licensed asbestos abatement firm to properly isolate, contain, and dispose of debris produced.

2.5.1.2 Management of Lead Paint

The Consultant shall determine if the project has potential lead exposure. Where the potential for lead exposure exists, request the MDOT MAA Environmental Compliance Officer to test the project site for potential areas which may result in lead exposure above the action level. Test locations and results shall be shown on the contract plans. Incorporate the following into the Special Provisions:

“The Contractor shall fully comply with the requirements of COMAR 09.12.32 – ‘Occupational Safety and Health Standard – Occupational Exposure to Lead in Construction Work,’ dated November 28, 1988, and as may be amended.”

“The Maryland Aviation Administration (MDOT MAA) had conducted preliminary tests of the project site to determine the potential lead exposure to workers above the action level. The location and results of those tests are shown in the contract documents.”

“The MDOT MAA has conducted the tests and made the results available as a matter of courtesy to prospective contractors. This information in no way relieves the Contractor from performing his own tests or complying with the requirements set forth in COMAR 09.12.32.”

Project inspectors shall follow-up and insure the requirements of COMAR 09.12.32 – “Occupational Safety and Health Standard – Occupational Exposure to Lead in Construction Work” are being complied with.

2.5.1.3 Management of Radioactive Wastes

The identification, handling, storage, transferring, and disposal of common radioactive wastes, specifically, self-luminous exit signs that may contain radioactive gas, such as tritium or radium, generated from construction projects is subject to Federal regulations that govern tritium or radium-containing signs which are found in the Nuclear Regulatory Commission regulations, 10 CFR Part 31. Accordingly, any construction project at BWI Marshall and Martin State Airports involving removal and disposal of common radioactive waste shall include Specification 010009X_Management of Radioactive Wastes. Specification 010009X can be found in Appendix 4B - Standard Specifications.

2.5.1.4 Management of Universal Wastes

The characterization, handling, storage, transport, and disposal of Universal Wastes (UW), such as mercury-containing equipment, batteries, mercury-containing lamps or bulbs, and fluorescent light ballasts that contain polychlorinated biphenyls (PCBs), generated from construction projects is subject to COMAR 26.13.10. Accordingly, any construction project at BWI Marshall and Martin State Airports involving removal and disposal of UW material/equipment shall include Specification 010008X_Management of Universal Wastes. Specification 010008X can be found in Appendix 4B - Standard Specifications.

2.5.2 Paint Booths

For the purposes of this section and all subsequent subsections, “Owner” refers to the Maryland Aviation Administration (MDOT MAA), or either of BWI Marshall and/or Martin State Airports as determined by the context. “Consultant” refers to any entity commissioned to design and/or specify equipment described herein for construction and/or installation at any MDOT MAA facility or location within the BWI Marshall and/or Martin State Airports.

The design and use of paint booths for paint stripping operations and surface coating operations must meet the requirements set forth in COMAR 26.11.01, COMAR 26.11.02, COMAR 26.11.03, COMAR 26.11.13, and COMAR 26.11.19, as well as the Federal regulatory requirements set forth in 40 CFR Part 63.11173 (if applicable).

2.5.2.1 Paint Stripping Operations

If MDOT MAA or Tenant paint stripping operations includes paint stripping using methylene chloride (MeCl) for the removal of dried paint (including but not limited to paint, enamel, varnish, shellac, and lacquer) from wood, metal, plastic, and other substrates, then the following steps should be taken:

A. Evaluate each application to ensure there is a need for paint stripping (e.g., evaluate whether it is possible to re-coat the piece without removing the existing coating);

B. Evaluate each application where a paint stripper containing MeCl is used to ensure that there is no alternative paint stripping technology that can be used;

C. Reduce exposure of all paint strippers containing MeCl to the air;

D. Optimize application conditions when using paint strippers containing MeCl to reduce MeCl evaporation (e.g., if the stripper must be heated, make sure that the temperature is kept as low as possible to reduce evaporation); and

E. Practice proper storage and disposal of paint strippers containing MeCl (e.g., store stripper in closed, air-tight containers).

Owners or operators of a paint stripping operation using paint strippers containing MeCl must submit an Initial Notification to EPA Region III and MDE/ARMA, as required by 40 CFR Part 63.9(b). For a new affected source, the initial Notification must be submitted no later than 180 days after initial startup. For an existing affected source, the Initial Notification must be submitted no later than January 11, 2010.

If the owner or operator of a paint stripping operation uses more than one ton of MeCl annually, a MeCl Minimization Plan must be development to address the management practices outlined in 40 CFR Part 63.11173(a)(1) through (a)(5). Paint stripping operations that use less than one ton of MeCl annually must comply with the management practices outlined in 40 CFR Part 63.11173(a)(1) through (a)(5), but are not required to develop and implement a written MeCl Minimization Plan.

Each paint stripping operation must maintain copies of annual usage of paint strippers containing MeCl onsite at all times.

MDOT MAA or tenant operations which include a paint stripping operation using paint strippers containing MeCl must submit an Initial Notification to EPA Region III and MDE/ARMA, as required by 40 CFR Part 63.9(b). For a new affected source, the Initial Notification must be submitted no later than 180 days after initial startup. For an existing affected source, the Initial Notification must be submitted no later than January 11, 2010.

MDOT MAA/tenant owners or operators of a paint stripping operation must maintain the records specified below:

A. Records of paint strippers containing MeCl used for paint stripping operations, including the MeCl content of the paint stripper used. Documentation needs to be sufficient to verify annual usage of paint strippers containing MeCl (e.g., material safety data sheets or other documentation provided by the manufacturer or supplier of the paint stripper, purchase receipts, records of paint stripper usage, engineering calculations);

B. Paint stripping sources that annually uses more than one ton of MeCl are required to maintain a record of the current MeCl Minimization Plan onsite for the duration of the paint stripping operations. Records of the annual review of, and updates to, the MeCl Minimization Plan must also be maintained;

C. Records of any deviation from the requirements in 40 CFR Part 63.11173, 40 CFR Part 63.11174, 40 CFR Part 63.11175, or 40 CFR Part 63.11176. These records must include the date and time period of the deviation, and a description of the nature of the deviation and the actions taken to correct the deviation; and

D. Per 40 CFR Part 63.111778, owners or operators of an affected source must maintain copies of the records listed above for a period of at least five years after the date of each record. Copies of records must be kept onsite and in a printed or electronic form that is readily accessible for inspection for at least the first two years after their date, and may be kept offsite after that two year period.

2.5.2.2 Surface Coating Operations

A. Per 40 CFR Part 63.11173(e), motor vehicle and mobile equipment surface coating operations and miscellaneous surface coating operations must meet the following requirements:

1. All painters, including contract personnel, must be certified that they have completed training in the proper spray application of surface coatings and the proper setup and maintenance of spray equipment.

2. All paint spray gun cleaning must be done so that an atomized mist or spray of gun cleaning solvent and paint residue is not created outside of a container that collects used gun cleaning solvent. Spray gun cleaning may be done with, for example, hand cleaning of parts of the disassembled gun in a container of solvent, by flushing solvent through the gun without atomizing the solvent and paint residue, or by using a fully enclosed spray gun washer. A combination of non-atomizing methods may also be used.

B. Owners or operators of a surface coating operation subject to NESHAP Subpart HHHHHH must submit an Initial Notification to EPA Region III and MDE/ARMA, as required by 40 CFR Part 63.9(b). For a new affected source, the Initial Notification must be submitted no later than 180 days after initial startup. For an existing affected source, the Initial Notification must be submitted no later than January 11, 2010.

C. Per 40 CFR Part 63.11176(a), owners or operators of a motor vehicle or mobile equipment, or miscellaneous surface coating affected source, are required to submit an Annual Notification of Changes Report in each calendar year in which information previously submitted in either the Initial Notification, Notification of Compliance, or a previous Annual Notification of Changes Report has changed. Deviations from the relevant requirements in 40 CFR Part 63.11173(a) through (d) or 40 CFR Part 63.11173(e) through (g) on the date of the report will be deemed to be a change. The Annual Notification of Changes Report must be submitted prior to March 1 of each calendar year when reportable changes have occurred.

D. Owners or operators of a surface coating operation must maintain the records specified below:

1. Certification that each painter has completed the training specified in 40 CFR Part 63.11173(f) with the date the initial training and the most recent refresher training was completed;

2. Documentation of the filter efficiency of any spray booth exhaust filter material, according to the procedure in 40 CFR Part 63.11173(e)(3)(i);

3. Documentation from the spray gun manufacturer that each spray gun with a cup capacity equal to or greater than 3.0 fluid ounces (89 cc) that does not meet the definition of an HVLP spray gun, electrostatic application, airless spray gun, or air assisted airless spray gun, has been determined by the Administrator to achieve a transfer efficiency equivalent to that of an HVLP spray gun, according to the procedure in 40 CFR Part 63.11173(e)(4);

4. Copies of any notification submitted as required by 40 CFR Part 63.11175 and copies of any report submitted as required by 40 CFR Part 63.11176; and

5. Per 40 CFR Part 63.11178, owners or operators of an affected source must maintain copies of the records listed above for a period of at least five years after the date of each record. Copies of records must be kept onsite and in a printed or electronic form that is readily accessible for inspection for at least the first two years after their date, and may be kept offsite after that two year period.

2.5.3 Parts Washers/Degreasers

Consultants should consider the use of non-solvent based parts washers and degreasers whenever practicable. Alternative non-solvent based (citrus-based or microbial cleaning agents) parts washers and degreasers do not require permitting and will reduce air emissions and eliminate the generation of associated hazardous wastes at MDOT MAA and tenant owned facilities. If an alternative non-solvent based parts washer and/or degreaser cannot be installed, the Environmental Compliance Section must be notified.

The design and use of parts washers and degreasers must meet the requirements set forth in COMAR 26.11.19.09, as well as the Federal regulatory requirements set forth in 40 CFR Part 63.462 (if applicable).

COMAR 26.11.19.09 requires that Good Operating Practices be employed when using VOC degreasing material. The following are considered Good Operating Practices:

A. A person subject to this regulation shall implement good operating practices to minimize spills and evaporation of VOC degreasing material.

B. Good operating practices shall include covers (including water covers), lids, or other methods of minimizing evaporative losses, and reducing the time and frequency during which parts are cleaned.

C. Good operating practices shall be established in writing and displayed so they are clearly visible to the operator.

D. The written good operating practices shall be maintained at the facility and made available for review by the Department upon request.

E. A person subject to this regulation may not use a halogenated substance that is a VOC in any cold degreasing.

2.5.3.1 Batch Cold Cleaning Machine Standards

A. Owners or operators of an immersion batch cold solvent cleaning machine shall comply with the requirements of 40 CFR Part 63.462(a)(1) through (a)(2).

B. Owners or operators of a remote-reservoir batch cold solvent cleaning machine shall comply with the requirements of 40 CFR Part 63.462(b).

C. Owners or operators of a batch cold solvent cleaning machine complying with 40 CFR Part 63.462(a)(2) or 40 CFR Part 63.462(b) shall comply with the work and operational practice requirements in of 40 CFR Part 63.462(c)(1) through(c)(9), as applicable.

D. Owners or operators of a batch cold cleaning machine shall submit an Initial Notification Report as described in 40 CFR Part 63.468 (a) and (b) and a Compliance Report as described in 40 CFR 63.468(c).

2.5.3.2 Batch Vapor and In-Line Cleaning Machine Standards

A. Owners or operators of an existing or new batch vapor or in-line solvent cleaning machine shall meet all of the required work and operational practices of 40 CFR Part 63.463(d)(1) through (d)(12).

B. Owners or operators of a solvent cleaning machine which complies with 40 CFR Part 63.463(b), (c), (g), or (h) shall comply with the requirements of 40 CFR Part 63.463(e)(1) through (e)(4).

C. Owners or operators of a batch vapor or in-line solvent cleaning machine complying with the idling emission limit standards in 40 CFR Part 63.463(b)(1)(ii), (b)(2)(ii), (c)(1)(ii), or (c)(2)(ii) shall comply with the requirements of 40 CFR Part 63.463(f)(1) through (f)(5).

2.5.3.3 Batch Vapor and In-Line Cleaning Machine Test Methods

A. Owners or operators of a batch vapor or in-line solvent cleaning machine complying with an idling emission limit standard in 40 CFR Part 63.463(b)(1)(ii), (b)(2)(ii), (c)(1)(ii), or (c)(2)(ii) shall determine the idling emission rate of the solvent cleaning machine using Reference Method 307 in 40 CFR Part 63 Appendix A.

B. Owners or operators of a batch vapor or in-line solvent cleaning machine complying with 40 CFR Part 63.464 shall, on the first operating day of every month ensure that the solvent cleaning machine system contains only clean liquid solvent. This includes, but is not limited to, fresh unused solvent, recycled solvent, and used solvent that has been cleaned of soils. A fill line must be indicated during the first month the measurements are made. The solvent level within the machine must be returned to the same fill-line each month, immediately prior to calculating monthly emissions as specified in 40 CFR Part 63.465(c). The solvent cleaning machine does not have to be emptied and filled with fresh unused solvent prior to the calculations.

C. Owners or operators of a batch vapor or in-line solvent cleaning machine complying with 40 CFR Part 63.464 shall, on the first operating day of the month, comply with the requirements of 40 CFR Part 63.465(c)(1) through (c)(3).

D. Owners or operators of a batch vapor or in-line solvent cleaning machine using a dwell to comply with 40 CFR Part 63.463 shall determine the appropriate dwell time for each part or parts basket using the procedures specified in 40 CFR Part 63.465(d)(1) and (d)(2).

E. Owners or operators of a source shall determine their potential to emit from all solvent cleaning operations using the procedures described in 40 CFR Part 63.465(e)(1) through (e)(3).

2.5.3.4 Batch Vapor and In-Line Cleaning Machine Monitoring Procedures

A. Owners or operators of a batch vapor or in-line solvent cleaning machine complying with the equipment standards in 40 CFR Part 63.463(b)(1)(i), (b)(2)(i), (c)(1)(i), (c)(2)(i), (g)(1), or (g)(2) shall conduct monitoring and record the results on a weekly basis for the control devices, as appropriate, specified in 40 CFR Part 63.466(a)(1) through (5).

B. Owners or operators of a batch vapor or in-line solvent cleaning machine complying with the equipment standards of 40 CFR Part 63.463 (b)(1)(i), (b)(2)(i), (c)(1)(i), or (c)(2)(i) shall conduct monitoring and record the results on a monthly basis for the control devices, as appropriate, specified in 40 CFR Part 63.466(b)(1) and (b)(2).

C. Owners or operators of a batch vapor or in-line solvent cleaning machine complying with the equipment or idling standards in 40 CFR Part 63.463 shall monitor the hoist speed as described in 40 CFR Part 63.466(c)(1) through (c)(4).

D. Owners or operators of a batch vapor or in-line solvent cleaning machine complying with the equipment standards in 40 CFR Part 63.463 (b)(1)(i), (b)(2)(i), (c)(1)(i), or (c)(2)(i) using a reduced room draft shall conduct monitoring and record the results as specified in 40 CFR Part 63.466(d)(1) or (d)(2).

E. Owners or operators using a carbon adsorber to comply with this subpart shall measure and record the concentration of halogenated HAP solvent in the exhaust of the carbon adsorber weekly with a colorimetric detector tube. This test shall be conducted while the solvent cleaning machine is in the working mode and is venting to the carbon adsorber. The exhaust concentration shall be determined using the procedure specified in 40 CFR Part 63.466(e)(1) through (e)(3).

F. Owners or operators of a batch vapor or in-line solvent cleaning machine complying with the idling emission limit standards of 40 CFR Part 63.463 (b)(1)(ii), (b)(2)(ii), (c)(1)(ii), or (c)(2)(ii) shall comply with the requirements specified in 40 CFR Part 63.466(f)(1) and (f)(2).

G. Owners or operators using a control device listed in 40 CFR Part 63.466(a) through (e) can use alternative monitoring procedures approved by the Administrator.

2.5.3.5 Parts Washers/Degreasers Recordkeeping Requirements

A. COMAR requires the MDOT MAA and tenants using VOC degreasing materials to maintain monthly records of the total VOC degreasing materials used and to make the records available to the Department upon request.

B. Owners or operators of a batch vapor or in-line solvent cleaning machine complying with the provisions of 40 CFR Part 63.463 shall maintain records in written or electronic form specified in 40 CFR Part 63.467(a)(1) through (7) for the lifetime of the machine.

C. Owners or operators of a batch vapor or in-line solvent cleaning machine complying with 40 CFR Part 63.463 shall maintain records specified in 40 CFR Part 63.467(b)(1) through (b)(4) either in electronic or written form for a period of 5 years.

D. Owners or operators of a batch vapor or in-line solvent cleaning machine complying with the provisions of 40 CFR Part 63.464 shall maintain records specified in 40 CFR Part 63.467(c)(1) through (3) either in electronic or written form for a period of 5 years.

2.5.3.6 Parts Washers/Degreasers Reporting Requirements

A. Owners or operators of an existing solvent cleaning machine subject to the provisions of 40 CFR Part 63.468 shall submit an Initial Notification Report to the Administrator no later than August 29, 1995. This report shall include the information specified in 40 CFR Part 63.468(a)(1) through (a)(6).

B. Owners or operators of a new solvent cleaning machine subject to the provisions of 40 CFR Part 63.468 shall submit an Initial Notification Report to the Administrator. New sources for which construction or reconstruction had commenced and initial startup had not occurred before December 2, 1994, shall submit this report as soon as practicable before startup but no later than January 31, 1995. New sources for which the construction or reconstruction commenced after December 2, 1994, shall submit this report as soon as practicable before the construction or reconstruction is planned to commence. This report shall include all of the information required in 40 CFR Part 63.5(d)(1) of Subpart A (General Provisions), with the revisions and additions in 40 CFR Part 63.468(b)(1) through (b)(3).

C. Owners or operators of a batch cold solvent cleaning machine subject to the provisions of 40 CFR Part 63.468 shall submit a Compliance Report to the Administrator. For existing sources, this report shall be submitted to the Administrator no later than 150 days after the compliance date specified in 40 CFR Part 63.460(d). For new sources, this report shall be submitted to the Administrator no later than 150 days after startup or May 1, 1995, whichever is later. This report shall include the requirements specified in 40 CFR Part 63.468(c)(1) through (c)(4).

D. Owners or operators of a batch vapor or in-line solvent cleaning machine complying with the provisions of 40 CFR Part 63.463 shall submit to the Administrator an Initial Statement of Compliance for each solvent cleaning machine. For existing sources, this report shall be submitted to the Administrator no later than 150 days after the compliance date specified in 40 CFR Part 63.460(d). For new sources, this report shall be submitted to the Administrator no later than 150 days after startup or May 1, 1995, whichever is later. This statement shall include the requirements specified in 40 CFR Part 63.468(d)(1) through (d)(6).

E. Owners or operators of a batch vapor or in-line solvent cleaning machine complying with the provisions of 40 CFR Part 63.464 shall submit to the Administrator an Initial Statement of Compliance for each solvent cleaning machine. For existing sources, this report shall be submitted to the Administrator no later than 150 days after the compliance date specified in 40 CFR Part 63.460(d). For new sources, this report shall be submitted to the Administrator no later than 150 days after startup or May 1, 1995, whichever is later. The statement shall include the information specified 40 CFR Part 63.468(e)(1) through (e)(4).

F. Owners or operators of a batch vapor or in-line solvent cleaning machine complying with the provisions of 40 CFR Part 63.463 shall submit an Annual Report by February 1 of the year following the one for which the reporting is being made. This report shall include the requirements specified in 40 CFR Part 63.468(f)(1) through (f)(3).

G. Owners or operators of a batch vapor or in-line solvent cleaning machine complying with the provisions of 40 CFR Part 63.464 shall submit a Solvent Emission Report every year. This Solvent Emission Report shall contain the requirements specified in 40 CFR Part 63.468(g)(1) through (g)(4).

H. Owners or operators of a batch vapor or in-line solvent cleaning machine shall submit an Exceedance Report to the Administrator semiannually except when, the Administrator determines on a case-by-case basis that more frequent reporting is necessary to accurately assess the compliance status of the source or, an exceedance occurs. Once an exceedance has occurred, the owner or operator shall follow a quarterly reporting format until a request to reduce reporting frequency is approved. Exceedance Reports shall be delivered or postmarked by the 30th day following the end of each calendar half or quarter, as appropriate. The Exceedance Report shall include the applicable information in 40 CFR Part 63.468(h)(1) through (h)(3).

I. Owners or operators who are required to submit an Exceedance Report on a quarterly (or more frequent) basis may reduce the frequency of reporting to semiannual if the conditions in 40 CFR Part 63.468(i)(1) through (i)(3).

Owners or operators of a solvent cleaning machine requesting an equivalency determination, as described in 40 CFR Part 63.469 shall submit an Equivalency Request Report to the Administrator. For existing sources, this report must be submitted to the Administrator no later than June 3, 1996. For new sources, this report must be submitted and approved by the Administrator prior to startup.

2.5.4 Design Requirements for Glycol Collection

Underground Diversion Vaults, Lift Stations, and other similar structures related to glycol collection system shall be designed with Schedule 80 CPVC pipe and fittings. Ductile iron pipe will be accepted as an alternate piping material only if there is a potential for hydrocarbons, e.g. or fuel or oil to enter the piping system. Support brackets, clamps, and braces shall be non-metallic, and use non-corrosive materials. Hardware shall be corrosion resistant.

The deicing collection system shall communicate with the existing BWI Marshall Metasys Facility Management System (FMS).