Polychlorinated Biphenyls (PCBs) - Hazardous Building Materials

This information applies to Polychlorinated Biphenyls (PCBs) Demolition, Repairs, and Renovation of Buildings with the potential of PCBs.

Does this apply to my project?

Yes, if you have any of the following: PCBs in Building Materials- Buildings built or renovated between 1949 and 1979 may contain PCBs in caulking, glazing compounds, adhesives and other materials.

Building Sealants are not totally enclosed and are thus an unauthorized use.

A PCB site characterization must be established for the project to ensure the health and safety of the occupants and workers as well as for proper cleanup and disposal.

  • Does the project include a building that was built or renovated between 1949 and 1979?
  • Determine scope of project and identify potential sources of PCBs.
  • Identify any prior sampling.
  • Test or Not test? What methods should be used? PCB abatement can be very costly.
  • Are adjacent surfaces non-porous, or being removed?  This makes the site characterization and abatement costs easier to establish up front.  Thus warranting testing.
  • Option to:  Presume the sealants contain PCBs for establishing scope of project.  Then test and hope for a good result with credit in your favor.
  • Presume the sealants are postive and remove.
  • Maybe cost effective for smaller projects (e.g. window repair, door removal, penetration into a building)
  • Adjacent surfaces remaining would still require sampling to ensure clean-up standards were met.
  • The potential for over-characterizing for disposal.

Site Characterization  Flow Chart

Abatement Options

  • Self-implementing Clean-up and Disposal
    • Low Environmental Impacts & Smaller Projects
    • 40 CFR 761.61(a)
  • o   Performance Based Disposal
    • 40 CFR 761.61(b)
    • 40 CFR 761.62(a)
  • Risk Based Disposal Approval
    • Regional EPA PCB Administrator Describes Plan, Generally Less Restrictive Than Self Implementing
    • 40 CFR 761.61(c)
    • 40 CFR 761.61(c)
    • A risk based approach may take more time for EPA approval, however can save money on sampling costs.
    • Encapsulation requiring long term maintenance and monitoring verses complete removal.

Finding PCBs after a contract has been awarded can have costly change orders.

PCBs in Oil Containing Devices

Oil containing devices manufactured prior to 1979 that may contain PCBs. Some examples include:

  • Transformers and capacitors
  • Other electrical equipment including voltage regulators, switches,  reclosers, bushings, and electromagnets
  • Oil used in motors and hydraulic systems
  • Old electrical devices, lab equipment, or appliances containing PCB capacitors
  • Air compressors or other scientific equipment

Identify PCB Containing Items

  • The identification process may include:
    • Oil testing, verification of equipment components with manufacturers, investigating historical spills and wipe testing

Fluorescent light ballasts that were manufactured before January 1, 1978

o   Fluorescent light ballasts are one of the largest sources of PCB wastes from a campus.

  • Must assume the ballast contains PCBs unless the words “no PCBs” are printed on the ballast
  • While the PCB regulations allow for disposal of ballasts and some small capacitors in local landfills, EPA recommends recycling as a preferential disposal protocol.  Note that using a local landfill for disposal may involve reporting requirements under CERCLA (See CERCLA – Spills).

Dispose of any PCB items appropriately

What do I need to do?

Follow Toxic Substances Control Act (TSCA) regulations governing PCBs (40 CFR 761)

Regulates source materials containing PCBs that are greater than or equal to 50 ppm

Regulates adjacent materials (PCB Remediation Waste) containing PCBs greater than 1 ppm as a result of a spill or leaching from source material

Prohibitions and Exceptions (40 CFR 761.20)

With a few exceptions, concentrations of source material containing less than 50 ppm are exempted from TSCA regulations
PCBs may only be used in a totally enclosed manner.

unless authorized under 40 CFR 761.30
Note: PCB containing caulk is not totally enclosed and is thus not authorized

Authorized Uses (40 CFR 761.30)
Marking (labeling) requirements (40 CFR 761.40 to 45)

See DOE TSCA Information Brief EH-413-0009/0702 “The PCB Mark”

Spill Cleanup, Disposal Requirements and Record Keeping

Manifesting Requirements (40 CFR 761.205 to 211)

  • Use the hazardous waste manifest tracking system under RCRA
  • Weight must be in Kg
  • UMass EH&S staff MUST sign the manifest

Certificate of Disposal (40 CFR 761.218)
Exception Reporting (40 CFR 761.215)
PCB Disposal (40 CFR 761.60 to 79)

Off site Disposal

  • High temperature incinerators, high efficiency boilers, chemical waste landfills
  • The disposal procedure will vary depending on what type of PCBs or PCB items are being disposed of and the location of disposal
  • See DOE TSCA Information Brief EH-231-056/1294 “Disposal Requirements for PCB Waste”

Abatement Verification Flow Charts

Decontamination (40 CFR 761.79)

 

Background

Polychlorinated biphenyls (PCBs) are a class of organic chemicals that have been used in a variety of commercial products. PCBs were domestically manufactured from 1929 until their manufacture was banned in 1979. Due to their non-flammability, chemical stability, high boiling point, and electrical insulating properties, PCBs were used in hundreds of industrial and commercial applications including electrical equipment, surface coatings, inks, adhesives, flame-retardants, and paints.

In 1979, the U.S. Environmental Protection Agency (EPA) banned the commercial production of PCBs, citing health and environmental concerns. PCBs persist in the environment because they are highly unreactive and are largely resistant to breakdown by acids, bases and heat. PCBs are not very soluble in water, but readily soluble in fats. This solubility in fat explains why PCBs can build up in animal fat and along the food chain. Health concerns related to PCB exposure include, but are not limited to, cancer, reproductive effects and neurological effects.

PCBs are regulated by the Toxic Substance Control Act (TSCA) Title 40, Part 761 (enacted in 1976). TSCA requirements include: the manufacturing, processing, distribution in commerce, use, disposal, storage, marking of PCBs and PCB Items, record keeping and reporting.

 

Key TSCA Regulatory Concepts

TSCA Level Classification for Source Material

Note that the different classifications will have different requirements

“Non-PCB”: 

  • Liquid material containing PCBs <50 mg/l or if insufficient liquid material is available for analysis, a non-porous surface having a surface concentration <10 μg/100 cm2
  • Non-liquid material containing PCBs <50 ppm

 “TSCA - PCB Contaminated Waste”

  • Liquid material containing PCBs at concentrations ≥50 mg/l but < 500 mg/l or where insufficient liquid material is available for analysis, a non-porous surface having a surface concentration >10 μg/100 cm2 but < 100 μg/100 cm2
  • Non-liquid material containing PCBs at concentrations ≥50 ppm but < 500 ppm;

“TSCA - PCB Waste”

  • Liquid material containing >500mg/l
  • Non liquid material containing >500 ppm

Mark

A label applied to areas containing PCBs subject to the TSCA regulations.  Displays “Caution contains PCBs” or other descriptive names, instructions, and cautions

PCB Bulk Product Waste

  • Non-liquid “source material” containing ≥50 ppm PCBs at the time of disposal (e.g. building sealants such as caulk, adhesives and glazing compounds).
  • Note that the manufactured PCB material may have been added in the field.

PCB Remediation Waste

  • Waste containing PCBs as a result of a spill or the leaching of PCB Source Material
  • PCB remediation waste includes items such as soil, concrete, wood

Bulk PCB Remediation Waste

  • Includes non liquid waste such as soil, vegetation, sediments, sludge
  • Rags, and other debris generated as a result of any PCB spill cleanup

Non-porous Surfaces

Surface unlikely to absorb PCBs (e.g. metals, glass, aluminum siding, polished building stones such as marble or granite, enameled surfaces)

Porous Surfaces

Surfaces likely to absorb PCBs (e.g. wood, concrete, asphalt, plasterboard)

High Occupancy Area

Any area where PCB remediation waste has been disposed of on-site and where occupancy for any individual is an average of 6.7 hours or more per week. (e.g.  residences, classrooms, day care centers, work stations, cafeterias, control rooms)

Low Occupancy Area

Any area where PCB remediation waste has been disposed of on-site and where occupancy for any individual is less than 6.7 hours per week. (e.g. an electrical substation, the upper floors of the exterior of a building, a location in a facility where a worker spends small amounts of time per week such as an unoccupied area outside a building, an electrical equipment vault, or in the non-office space in a warehouse where occupancy is transitory.

Hazardous Waste

PCBs are not hazardous waste under federal regulations, although many of the management requirements are similar to those for hazardous wastes.  Some states, like Massachusetts, choose to include PCBs in their RCRA Hazardous Waste programs.  Therefore, management and disposal of PCBs in these states are subject to requirements of both TSCA and RCRA.

Documents
File Title
download Chenoweth 219 Window Glazing Compound Completion Report 2/1/11
download Chenoweth 219 Window Glazing Compound Remediation Plan 5/25/10
download Construction Environmental Checklist
download Crampton Hall Release Abatement Plan - 7/12/11
download Du Bois Elevator Communication Plan 4/8/10
download Du Bois Elevator Completion Report 2013 03 29
download Du Bois Elevator Maintenance and Monitoring Plan 2013 03 29
download Du Bois Elevator PCB Approval 4/8/10
download Du Bois Elevator PCB Communication 5/19/10
download Du Bois Elevator PCB Communication 6/4/10
download Du Bois Elevator PCB Remediation Plan 3/24/10
download Du Bois Elevator Project Status Update 10/15/10
download Du Bois Initial Post Abatement Monitoring Results 2012.09.13
download Equipment Disposal - Hazardous Materials Assessment For Disposal
download Hazard Assessment, Abatement, Oversight, and Clearance Process - Outside Design Project
download Hazard Assessment, Abatement, Oversight, and Clearance Process - Inside Funded Work
download Hazardous Materials - Building Survey Guidance
download LGRC Air Monitoring Results, 5-26-09
download LGRC Air Samples, 8-21-06
download LGRC Bulk Samples from Dumpster Site, 8-21-06
download LGRC Communication Plan Flow Chart, 7-27-07
download LGRC Consent Agreement and Final Order, 2012-06-20
download LGRC DEC Interim Measures Plan - 2011.02.11
download LGRC EH&E Addendum to Proposed Abatement Plan, 3-22-07
download LGRC EH&E Additional Indoor Sample Results, 2-21-07
download LGRC EH&E Immediate Response Action Status Report, 11-15-06
download LGRC EH&E Panel Caulking and Concrete Core Samples, 8-21-06
download LGRC EH&E Preliminary Report of Building-Related PCB Assessment, 10/12/06
download LGRC EH&E Presentation Slides, 5-23-07
download LGRC EH&E Project Synopsis of PCB issue at LGRC, 5-15-07
download LGRC EH&E Proposed Abatement Plan 2-21-07
download LGRC EH&E Wipe Samples - Low-Rise Library, 9/6/06
download LGRC EH&E Wipe Samples -Tower A and Low-Rise, 8/22/06
download LGRC EPA- PCB Cleanup and Disposal Approval, 3-25-09
download LGRC Glazing Material Observations and Sampling Data, 5/14/09
download LGRC Interior Window Glazing Report to EPA, 7/10/09
download LGRC LR Air and Wipe Samples, 6-6-07
download LGRC LR and Tower A EPA Response to Proposed Cleanup Plan, 6-22-07
download LGRC LR Library Air Samples, 9-6-06
download LGRC LR Library Dust Thimble Results, 9-6-06
download LGRC NIH Remediation Completion Report, 1/8/13
download LGRC PCB Communication Plan - Revised 8-1-07
download LGRC PCB Communication Plan rev 2013 07 11
download LGRC PCB Communication Plan rev 2013 07 15
download LGRC PCB Interim Measures Completion Report - June 2014
download LGRC PCB Interim Measures Plan 2012 05 07
download LGRC PCB Long Term Maintenance and Monitoring Report 2015 09 29
download LGRC PCB Long Term Maintenance and Monitoring Report 2016
download LGRC PCB Monitoring and Maintenance Implementation Plan - June 2014
download LGRC PCB Remediation Completion Report 2014.12.29
download LGRC PCBs in Interior Window Glazing Sealants - Informational Meeting Presentation by W&C 11/18/10
download LGRC Revised MMIP
download LGRC Soil Remediation Activity Schedule for 4-17, 4-20 4-16-09
download LGRC Soil Remediation Activity Schedule for 4-24, 4-27 4-23-09
download LGRC Soil Remediation Activity Schedule for 4-28, 4-30 4-27-09
download LGRC Soils Self-Implementing On-Site Cleanup and Disposal Plan (SIP) March 2009
download LGRC Summary Data Report – Window Glazing and Existing Indoor Sample, 5/15/09
download LGRC Tower B Exterior Panel Caulking <50 8-22-06
download LGRC Tower C Exterior Panel Caulking <50 8-21-06
download Long-Term Maintenance and Monitoring Report 2012
download Long-term Maintenance and Monitoring Report 2013
download Long-term Maintenance and Monitoring Report 2015
download Long-term Maintenance and Monitoring Report 2016
download Long-Term Monitoring and Maintenance Implementation - 2014 Monitoring Results
download OH Field and Grayson Roof Completion Report 2012 04 24
download OH Field and Grayson Window Replacement - EPA Approval 2012 04 30
download OH Field and Grayson Window Replacement - Remediation Plan 2012 01 06
download OH Webster Windows PCB Remediation Plan March 2011
PCB Remediation
download Physical Plant Window Caulk - Response to EPA Comments on Remediation Plan 9/12/12
download Physical Plant Window Caulk Remediation Plan March 2012
download Polychlorinated Biphenyls (PCBs) Site Assessment Testing Policy
download SW Concourse PCB Completion Report 02.2011
download SW Concourse Release Abatement Measure (RAM) Completion Report and Class A-2 Response Actions Outcome 06.2011
download SW Crampton Amendment to Remediation Plan 5/9/12
download SW Crampton and MacKimmie PCB Completion Report 2012-04-27
download SW Patterson and MacKimmie PCB Completion Report
download SW Patterson/MacKimmie Amendment to PCB Remediation Plan March 2017
download SW Residential Area MMIP, 12-21-10
download SW Residential Concourse 120 Day Release Abatement Measure Status Report 10/14/10
download SW Residential Concourse PCB Remediation Plan 6/25/10
download Sylvan Complex - Soil Characterization Report
download Sylvan PCB Remediation Completion Report 2014.02.20
download Sylvan Remediation Plan Addendum 6/19/13
download Sylvan Residential Complex - PCB Remediation 2013 03 15
download Tobin Hall Deck PCB Completion Report and Addendum 2013 05 10