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)
  • 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

  • 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.

Displaying 1 - 96 of 96 documents

Chenoweth 219 Window Glazing Compound Completion Report by ATC 2/1/11. 

(Note that ... read more

Chenoweth 219 Window Glazing Compound Remediation Plan by ATC Associates 5/25/10. 

ATC Associates' Release Abatement Measure Plan dated July 12, 2011.

EH&S's Du Bois Library PCB Abatement Communication Plan effective 4/9/10.

Du Bois Elevator, PCB containing caulk, Completion Report by Woodard and Curran 2013 03 29. ... read more

Du Bois Elevator Lobby Maintenance and Monitoring Plan 2013 03 29 by Woodard and Curran.

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U.S. Environmental Protection Agency letter dated 4/8/10 re: Du Bois Library PCB Approval.

Du Bois Elevator PCB Communication Remediation Update dated 5/19/10.

Du Bois Elevator PCB Communication Remediation Update dated 6/4/10.

Woodard & Curran's PCB REMEDIATION PLAN - RISK-BASED DISPOSAL AND CLEANUP dated March 2010... read more

Woodard & Curran status update report dated 10/15/10 on the remediation activities re: Du... read more

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Woodard & Curran Preliminary Results of the Interior Air Monitoring at the UMass Amherst... read more

Lederle PCB Abatement Communicate Plan (Flow Chart).

United States Environmental Protection Agency - Region 1 TSCA-01-2012-0036 Consent Agreement and... read more

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EH&E Additional Indoor Sample Results for U.S. EPA, 2-21-07.

LGRC EH&E Immediate Response Action Status Report, 11-15-06. 

Table of Panel Caulking and Concrete Core Samples, Tower A and Low-Rise, 8-21-06.

Preliminary Report of Building-Related PCB Assessment LGRC compiled by Environmental Health and... read more

EH&E Presentation Slides for LGRC PCB meeting held in Campus Center, 5-23-07. 

Environmental Health & Engineering Inc., Project Synopsis dated 5/15/07.

LGRC EH&E Proposed Abatement Plan. Submitted to EPA; 93 pages; 2-21-07. 

LGRC EH&E Wipe Samples - Low-Rise Library, 9/6/06.

LGRC EH&E Wipe Samples -Tower A and Low-Rise, 8/22/06. 

Environmental Protection Agency (EPA)- PCB Cleanup and Disposal Approval under 40 CFR Sec. 761.... read more

Woodard & Curran Status Update – Interior Window Glazing - UMass Amherst – Lederle Graduate... read more

EH&E summary letter of Additional Air and Wipe Samples Low-Rise: 6-5-07, 6-6-07.

U.S. Environmental Protection Agency (EPA) Response of 6/22/07 to Proposed Cleanup Plan for Low-... read more

The attached letter report documents the polychlorinated biphenyl (PCB) remediation activities... read more

EH&S Lederle PCB Abatement Communication Plan Revised 8-1-07.

This document is written to detail the communication plan for the Polychlorinated Biphenyls (PCB... read more

This Polychlorinated Biphenyl (PCB) Interim Measures Completion Report has been prepared by... read more

This Interim Measures Plan has been prepared to document proposed measures to be taken to... read more

This monitoring report has been prepared by Woodard & Curran on behalf of the University of... read more

This monitoring report has been prepared by Woodard & Curran on behalf of the University of... read more

This report provides the results of the monitoring activities conducted in accordance with the... read more

This monitoring report has been prepared by Woodard & Curran on behalf of the University of... read more

This monitoring report has been prepared by Woodard & Curran on behalf of the University of... read more

This revised Monitoring and Maintenance Implementation Plan (MMIP) has been prepared by Woodard... read more

For space constraints, analytical reports have been removed from this web document. Contact... read more

Lederle Graduate Research Center:  PCBs in Interior Window Glazing Sealants - Informational... read more

On behalf of the University of Massachusetts (UMass) and in accordance with the June 2012... read more

Woodard & Curran Self-Implementing On-Site Cleanup and Disposal Plan Lederle Graduate... read more

Woodard & Curran Summary Data Report – Window Glazing and Existing Indoor Sample Data -... read more

LGRC Tower B Exterior Panel Caulking <50 8-22-06. 

LGRC Tower C Exterior Panel Caulking <50ppm PCB  8-21-06 

MONITORING ACTIVITIES – AUGUST 2012

Woodard & Curran performed the following... read more

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On behalf of the University of Massachusetts, this report has been prepared and is being... read more

This report has been prepared and is being submitted to document the results from the 2017 long... read more

On behalf of the University of Massachusetts, this report has been prepared and is being... read more

On behalf of the University of Massachusetts, this report has been prepared and is being... read more

For space constraints, analytical reports have been removed from this web document.  Contact... read more

On behalf of the University of Massachusetts/Amherst (UMASS), ATC Associates Inc. (ATC) has... read more

This Remediation Plan (Plan) has been prepared by Woodard & Curran (W&C) on behalf of... read more

Woodard & Curran PCB Remediation Plan March 2011. First paragraph of Introduction: "This... read more

Polychlorinated biphenyls (PCBs) are a family of man-made chemicals that contain 209 individual... read more

This letter has been sent on behalf of the University of Massachusetts, Amherst (UMASS), to... read more

On behalf of the University of Massachusetts (UMASS), ATC Associates, Inc. (ATC) is requesting... read more

Due to the hazardous nature of PCBs, it is required that testing of caulking and sealants for... read more

For space constraints, analytical reports have been removed from this web document. Contact... read more

For space constraints, analytical reports have been removed from this web document.  Contact... read more

On behalf of the University of Massachusetts (UMASS), ATC Associates, Inc. (ATC) is requesting... read more

ATC Associates Inc., (ATC) has prepared this Final Completion Report for Polychlorinated... read more

In accordance with EPA’s May 5, 2017 Approval referencing the conditions of the August 30, 2010... read more

This polychlorinated biphenyl (PCB) remediation plan has been prepared by Woodard & Curran... read more

For space constraints, analytical reports have been removed from this web document.  Contact... read more

Woodard & Curran 120-Day Release Abatement Measure Status Report dated October 14, 2010.

Woodard & Curran PCB Remedian Plan (224189.00) dated March 2011.

For space constraints, analytical reports have been removed from this web document.  Contact... read more

United States Environental Protection Agency

PCB Decontamination and Disposal Approval... read more

For space constraints, analytical reports have been removed from this web document.  Contact... read more

On behalf of the University of Massachusetts (UMass), this addendum has been prepared by Woodard... read more

This document presents a project timeline and list of significant project milestones/submittals... read more

This Polychlorinated Biphenyl (PCB) Remediation Completion Report has been prepared by Woodard... read more

This Polychlorinated Biphenyl (PCB) Remediation Plan has been developed to present the risk-... read more

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