Managing PCBs during Construction: Recent guidance offers simpler, cost-effective options
by Cynthia Campisano, MS, PG
PCBs pose a major headache for property managers and building owners who need to perform renovations or demolition at their buildings. Expensive sampling procedures and disposal methods can make PCB remediation very difficult for building owners, increasing both the project budget and timeline. In 2012, the U.S Environmental Protection Agency (EPA) issued a reinterpretation of their PCB regulations and more recently (2015) issued guidance on testing requirements that can make the process less onerous for building owners and managers.
Polychlorinated biphenyls, commonly known as PCBs, are a familiar environmental hazard and public health risk. PCBs were manufactured from the late 1920s until 1979 for use in certain applications, most notably dielectric fluids, until their manufacture was banned by the Toxic Substances Control Act (TSCA). PCBs had never been approved for use in building products such as building caulk, paint, sealants, etc., and unfortunately were found to have been used extensively in such applications. These products are often discovered in commercial buildings and schools. As a result, anybody who finds PCBs present in building materials within a building is considered to have an unauthorized use of PCBs, and is responsible for remediation.
Bulk Product Waste vs. Remediation Waste
During the remediation process, PCB-contaminated waste is divided into two different categories: bulk-product waste and remediation waste. The current definition of PCB bulk product waste includes “non-liquid bulk wastes or debris from the demolition of buildings and other man-made structures manufactured, coated, or serviced with PCBs.” Other PCB bulk product wastes may include, but are not limited to, mastics, sealants, or adhesives containing PCBs at concentrations above EPA guidelines (≥ 50 ppm).
PCBs can leach from PCB manufactured products into attached porous building material, such as masonry or concrete. PCB remediation waste is defined as “waste containing PCBs as a result of a spill, release, or other unauthorized disposal”, and leaching is considered a release of PCBs.
More stringent reporting requirements often apply for the management of remediation waste than bulk product waste. Until 2012, bulk-product waste and remediation waste were typically segregated and disposed of differently. This meant that the PCB bulk-waste was separated from the remediation waste, usually through costly, labor-intensive scraping or chiseling methods.
Reinterpretation of PCB Waste Definitions
Building owners and managers found the previous requirements for disposal to be expensive and inefficient. To address the concerns of the regulated community and to better protect public health and the environment, in 2012 EPA issued a reinterpretation of the PCB guidance. Under the reinterpretation, the materials adjacent to an applied PCB-containing building material can be disposed of as bulk product waste as long as they are disposed at the same time as the PCB-containing product.
The reinterpretation streamlines both the removal process and the disposal process. Instead of segregating the waste by painstakingly chipping the bulk product off and then removing the adjacent remediation waste, all contaminated materials can be removed at the same time. There are more options for disposal of adjacent impacted materials, and these options are often cheaper. Finally, in many instances, bulk-product removals do not require a work plan approval by the EPA.
As a result, the PCB abatement costs to building owners and operators are reduced and the removal and disposal processes are simplified.
PCB Testing Requirements
The EPA requirements for testing for the presence of PCBs was clarified in July of 2015. Testing is not required if the waste is assumed to contain high levels of PCBs and is disposed of as such. If a building owner makes reasonable assumptions that materials may contain PCBs and disposes of them as bulk-product waste, testing does not necessarily have to be performed. This is extremely helpful in smaller-scale projects, such as replacing a leaky window. In this case, the window caulk and adjacent materials do not have to be tested if both the caulk and the surrounding material will be disposed of. This eliminates the risk of required abatement at other windows with the same caulk if PCBs were to be confirmed to be present through testing. However, it should be noted that in some cases waste disposal facilities may require testing prior to accepting waste.
EH&E’s hazardous materials management experts recommend the following proactive steps for all construction projects on buildings constructed and / or renovated from 1950 to 1978.
Perform a Pre-Test Risk Evaluation
By carefully evaluating the age, type, and renovation history of the existing structure, an assessment can be made of what materials in the structure may contain PCBs, or whether material testing is required. Hazardous materials management experts can inventory suspect materials and determine the probability of PCB contamination using visual clues and initial screening techniques that don’t involve actual sampling. This assessment can often save the owner time and money by limiting or eliminating the need for expensive testing, and can provide information to support capital planning if PCBs may be present.
Carefully Design the Materials Testing Protocol
Test only what you need to test! If materials testing is warranted, an experienced, knowledgeable expert can design and review a testing protocol and analyze the results, potentially saving the owner a great deal of time and money. A renovation project at a New England university helps illustrate this point. Random testing results from a large multi-wing facility were initially interpreted as requiring remediation of all caulking. EH&E was called-in to conduct a separate, subsequent evaluation of the results which showed that in fact, two wings of the structure were built at a later period and test results actually indicated no remediation was necessary in these areas. The review saved the university approximately $2.5M. EH&E scientists and engineers have pioneered new screening and testing protocols that can rapidly provide useful information to help guide less costly and invasive testing protocols, while still meeting regulatory requirements and ensuring safety.
Get Help with Remediation Project Design
When remediation of PCB–contaminated materials is warranted, EH&E recommends a comprehensive review of the remediation options prior to implementation. Regulatory requirements call for removal of all PCB–containing materials and the removal or encapsulation of PCB-contaminated materials. Knowledgeable, careful analysis of the extent of the contamination can often make a significant difference in removal or encapsulation effort and cost. Alternative project designs that still comply with regulatory requirements may also be negotiated with the EPA and result in major savings of time and project costs.
Provide Risk Communication for Occupants
Should testing determine that building materials require removal, part of the project design should be focused on minimizing occupant impact. Select a knowledgeable consultant that can customize an effective risk communication strategy; this may include communicating testing results and remediation plans to occupants when required and ensuring that all involved parties are aware that proper precautions are being taken.
Expert Guidance Minimizes Costs and Ensures Compliance
The revised EPA guidance for the disposal and testing of PCB-containing building materials can make building renovation projects more streamlined and cost-efficient for building owners. Enlisting the help of a qualified expert will ensure that all EPA regulations and guidelines are being met to ensure public health and safety, while minimizing the costs of PCB abatement.
Cindee Campisano, Project Executive / Senior Scientist at EH&E, works with clients in wide range of settings – healthcare facilities, historic buildings, commercial spaces – to help them address environmental challenges and make informed real estate decisions regarding potential environmental liabilities. Cindee specializes in environmental compliance and management, hazardous building materials assessments, remediation design and implementation, and community relations and risk communication. Cindee can be reached at firstname.lastname@example.org.