Sylvan PCB Remediation Completion Report 2014.02.20

For space constraints, analytical reports have been removed from this web document.  Contact Environmental Health and Safety for review.

On behalf of the University of Massachusetts (UMass), this letter and attached documents have been prepared to document the completion of the polychlorinated biphenyl (PCB) remediation activities conducted at the Sylvan Residential Complex located at 112 Eastman Lane on the UMass Amherst campus in Amherst, Massachusetts.

The Sylvan Residential Area consists of three dormitories, all of similar construction and all built consecutively starting in 1971. These buildings are referred to as the Brown, McNamara, and Cashin Residences (see attached figure). As previously communicated, UMass undertook a three year building envelope repair project at the three buildings beginning in 2011, which also included Americans with Disabilities Act (ADA) restroom upgrades at the Brown and McNamara Residences and common area interior renovations at the McNamara and Cashin Residences. The work activities were conducted during the summer break sessions (May through August) when students were not present in the buildings.

Although plan submittals, status updates and other communications have occurred throughout 2011, 2012, and 2013 activities, formal written Approval from the Agency has not been received to date. As previously discussed, the intent of the previous submittals was to “link” the activities being conducted at the three buildings into one “Approval” for the Sylvan Residential Complex to cover remediation activities associated with the building envelope work, interior renovation areas, and long term monitoring and maintenance activities.

A project timeline and list of significant project milestones and submittals associated with the Sylvan Residential Complex PCB remediation work is provided below:

Brown Residence:

  • PCB Remediation Plan for the Building Envelope Repair Project submitted to EPA – April 6, 2011;
  • PCB Remediation Plan for the ADA Bathroom Upgrade Project submitted to EPA – May 6, 2011;
  • Supporting information/response to EPA questions regarding the Envelope Repair Project submitted to EPA – May 17, 2011;
  • EPA Comment Letter received for the ADA Bathroom Upgrade Project PCB Remediation Plan –June 6, 2011;
  • PCB Remediation activities substantially completed – May 2011 through August 2011;
  • PCB Remediation Update and Addendum submitted to EPA – November 17, 2011;
  • PCB Remediation Status Report (Building Envelope Repair Project) submitted to EPA – February 10, 2012;
  • PCB Remediation Project Status Report (building envelope repair and ADA restroom projects) submitted to EPA – March 15, 2013; and
  • Final completion of PCB Remediation activities (application of clear coat to low occupancy vertical joints) – May 2013 through July 2013 (final verification wipe samples collected November 2013).

McNamara Residence:

  • PCB Remediation Plan for Building Envelope Repair and ADA Restroom Upgrade Project submitted to EPA – March 21, 2012;
  • Supporting information/response to EPA questions (telephone and email communications) – May through June 2012;
  • PCB Remediation activities substantially completed – building envelope repairs and ADA restroom upgrades – May 2012 through August 2012 (final verification wipe samples collected November 2012);
  • PCB Remediation Status Report submitted to EPA – March 15, 2013;
  • Sylvan Residential Complex PCB Remediation Plan Addendum submitted to EPA (interior renovation project) – June 19, 2013; and
  • Interior Renovation PCB Remediation Activities Completed – July 2013 through August 2013.

Cashin Residence:

  • PCB Remediation Plan for Building Envelope Repair submitted to EPA – March 15, 2013;
  • Sylvan Residential Complex PCB Remediation Plan Addendum submitted to EPA (interior renovation project) – June 19, 2013; and
  • PCB Remediation activities substantially completed, building envelope repairs and interior renovation activities – May 2013 through August 2013 (final verification wipe samples collected November 2013).

The following documents are attached to this letter and constitute the PCB Remediation Completion Report for the Sylvan Residential Complex, which is being submitted to comply with recordkeeping requirements of 40 CFR 761. Because the remediation plans and subsequent work was completed individually by building, the completion reports have also been prepared individually and by building:

  • Brown Residence PCB Remediation Completion Report for the building envelope repair and ADA restroom upgrade projects;
  • McNamara Residence PCB Remediation Completion Report for the building envelope repair, ADA restroom upgrade, and interior common area renovation projects; and
  • Cashin Residence PCB Remediation Completion Report for the building envelope repair and interior common area renovation projects.

Also attached is a Long Term Monitoring and Maintenance Plan (MMIP) to monitor the effectiveness of the implemented remedy over time. This document has been prepared for the entire three building complex.