Protocol for Addressing Polychlorinated Biphenyls (PCBs) in Caulking Materials in School AND OTHER Buildings
I. Background
Recently,
several school districts have discovered that PCBs are present in building
caulk installed on their facilities and sometimes in the soil near caulked
structures. Typical locations include windows and expansion joints.
PCBs are regulated by the U.S. Environmental Protection Agency (U.S. EPA) and
the State of New York, and caulk containing PCBs should be properly managed
when disturbed through building renovations.
PCBs
are currently prohibited from being used in caulk and other commodities (U.S.
EPA, 40 CFR 761). However, prior to 1977, PCBs were present in some
caulking materials used in the construction of schools and other
buildings. Studies have shown that concentrations of PCB can exceed 1%
(10,000 ppm) by weight in some caulk materials. An investigation of 24
buildings in the Greater Boston Area revealed that one-third of the buildings
tested (8 of 24) contained caulking materials with polychlorinated biphenyl
(PCB) content exceeding 50 ppm by weight with an average concentration of
15,600 ppm or 1.5% (Herrick et al., 2004). These buildings included
schools and other public buildings.
The
U.S. EPA regulates the disposal of caulk, as well as soil and other materials contaminated
with PCBs from caulk, if the concentration of PCBs exceeds 50 ppm. Such
materials must be disposed at an appropriate approved or permitted facility.
U.S.
EPA regulation 40 CFR 761 defines "PCB remediation waste" to include
contaminated soil, and specifies a clean-up level of <1ppm without further
conditions for unrestricted use in "high occupancy areas" (i.e.,
areas where individuals may be present for 335 hours or more per year).
PCB caulk is defined as a PCB bulk product waste, and its disposal is subject
to U.S. EPA regulations under the Toxic Substances Control Act (40 CFR761.62).
This protocol has been developed in consultation with the New York State Department of Health, Division of Environmental Health Assessment, Bureau of Toxic Substance Assessment to address concerns about properly managing caulk containing PCBs that will be disturbed during building renovation and maintenance.
II. Objective
For
any school buildings constructed or renovated between 1950 and 1977 and
undergoing current renovation or demolition, NYSED and NYSDOH recommend that
the building(s) be evaluated prior to the renovation work to determine whether
they contain caulk that is contaminated with PCBs. If so, a plan should
be developed to address potential environmental and public health concerns
about potential PCB exposure.
III. Investigation and Testing
To
adequately characterize PCB contamination, a professional environmental
consultant with appropriate experience in environmental investigation and
testing should prepare a detailed workplan to guide this work.
A. Caulk Sample Collection
Buildings
constructed or renovated between 1950 and 1977 have a potential to contain PCBs
in existing caulk. Representative samples of caulking materials from
these buildings prior to renovation or demolition work should be tested to
determine whether the caulk is contaminated with PCBs. Professional judgment should be used to design
the sampling plan for characterizing caulk throughout the building. The
consultant should pay particular attention to construction and maintenance
records and to the appearance of caulking materials (likenesses and
differences). Samples should be
taken from window frames or expansion joints that have not been repaired or replaced
since 1977. Depending on specific
information provided in the workplan developed by the project manager, such as
window placement, compositing of some caulk samples might be appropriate.
Caulk from different time periods or that have a different appearance should
not be composited together.
It
is important to note that caulk used during the time period of interest may
also contain asbestos or lead. Therefore, the work plan should include
testing, handling and disposal requirements appropriate for such regulated
materials.
B.
Soil Sample Collection
Buildings
constructed or renovated between 1950 and 1977, which have undergone further
renovation after 1977, may have residual PCB contamination in adjacent
soils. An adequate representation
of surface soils should be tested to assess the potential for residual PCB
contamination.
When
designing a representative soil sampling plan, the likelihood of soil
contamination from deteriorated or deteriorating caulk should be
considered. Caulk that has in the past dried out and fallen to the ground
is the most important source of soil contamination. Thus, sampling should
include soil beneath windows where caulk has obviously deteriorated or been
replaced because of previous deterioration. Areas subject to the stress
of sun and prevailing weather (typically the southern and western side of each
structure) should be included for sampling. These samples would provide a
conservative evaluation of soil conditions due to an increased potential for
material failure, possibly resulting in contamination of soil. Also, if earlier renovation or demolition work
may have stockpiled potentially contaminated caulk in other school areas, the
school should consider having soils in those areas tested as well.
Soil
sampling should focus on areas of the building where ”banks” or “gangs” of
windows exist/were replaced and areas of the structure where large expansion
joints are located. This would
provide a conservative evaluation of potential soil contamination and permit
efficient sampling.
Any
obvious pieces of caulk encountered during the collection of soil samples
should be removed from the soil, categorized (with respect to location and
depth) and treated as a separate potential sample.
Depth
– At each soil sample location, soil should be collected in depth intervals of
0-2 inches, 2-6 inches and 6-12 inches. The surface soil sample (0-2 inches) should be
collected from below the vegetative surface layer, if present.
Distance
from Structure – Samples should be collected within 1 foot of the building and
5 feet from the building.
Samples
should be collected in a manner that prevents cross-contamination. Augers or driven core samplers should be
avoided, as any caulk caught on the edge of this type of tool could be driven
to lower intervals. Using a designated trowel for each sample location and each
interval of depth is encouraged. If the sampling tool is field cleaned between
samples, do so in a manner that does not add solvent contamination to the
environment.
C.
Laboratory Analyses of Soil and Caulk Samples
Specific
information concerning laboratory procedures and protocols must be detailed in
the work plan.
Duplicate
analysis should be performed on 10% of samples received by the laboratory.
The
soil sample or extract of the soil sample collected at a depth of 6-12 inches
may be archived until the sample results for 2-6 inches are available, provided
that the appropriate sample holding times are not exceeded.
All
caulk and soil samples must be analyzed for PCBs by a NYSDOH Environmental
Laboratory Approval Program (ELAP) certified laboratory. ELAP certified
labs can be found at the following link: www.wadsworth.org/labcert/elap/elap.html
.
Results provided should be for total PCBs.
.
Results provided should be for total PCBs.
IV. Abatement
If
it is determined that caulk materials contain PCBs, a site specific abatement
plan should be developed to address potential environmental and public health
concerns. The HUD Technical Guidelines for the Evaluation and Control of
Lead-Based Paint Hazards in Housing available at www.hud.gov/offices/lead/guidelines/hudguidelines/
can be
used as a basis for developing the steps for abating the contamination and
preventing contamination of nearby areas. This is the same guideline
required by NYSED to manage lead contaminated materials in schools under the
RESCUE regulations. Caulking materials that contain either lead, PCBs, or
both can therefore be managed under the same guidance. Caulking materials
that contain asbestos in addition to either lead or PCBs or samples that
contain only asbestos will be managed in accordance with requirements of the
NYS Department of Labor Code Rule 56.
can be
used as a basis for developing the steps for abating the contamination and
preventing contamination of nearby areas. This is the same guideline
required by NYSED to manage lead contaminated materials in schools under the
RESCUE regulations. Caulking materials that contain either lead, PCBs, or
both can therefore be managed under the same guidance. Caulking materials
that contain asbestos in addition to either lead or PCBs or samples that
contain only asbestos will be managed in accordance with requirements of the
NYS Department of Labor Code Rule 56.
As
stated in Section I, cleanup and disposal of PCB remediation and bulk product
waste is subject to U.S. EPA regulations under the Toxic Substances Control Act
(40 CFR 761) (see http://www.epa.gov/pcb/pubs/200540cfr761.pdf
).
For information or assistance pertaining to the federal PCB regulations, please
contact either Daniel Kraft or James Haklar, at the Pesticides and Toxic
Substances Branch of U.S. EPA Region 2. Daniel Kraft can be contacted at kraft.daniel@epa.gov or (732) 321-6669,
and James Haklar can be reached at haklar.james@epa.gov
or (732) 906-6817.
).
For information or assistance pertaining to the federal PCB regulations, please
contact either Daniel Kraft or James Haklar, at the Pesticides and Toxic
Substances Branch of U.S. EPA Region 2. Daniel Kraft can be contacted at kraft.daniel@epa.gov or (732) 321-6669,
and James Haklar can be reached at haklar.james@epa.gov
or (732) 906-6817.
Disposal
of contaminated materials from abatement activities (soil or caulk) is
regulated by the NYSDEC solid waste regulations (6NYCRRPart 360) if
concentrations are <50 ppm and by the hazardous waste regulations
(6NYCRR370-373) if PCB concentrations are 50 ppm or greater. Contact the
NYSDEC Regional Office for additional guidance.
References
Herrick
RF, McClean MD, Meeker JD, Baxter LK, Weymouth GA. 2004. An Unrecognized Source
of PCB Contamination in Schools and Other Buildings. Environmental Health
Perspectives. 112:1051-1053.
USEPA.
40 CFR 761. Polychlorinated Biphenyls (PCBs) Manufacturing, Processing,
Distribution in Commerce, and Use Prohibitions. (http://www.epa.gov/pcb/pubs/200540cfr761.pdf
)
)
6
NYCRR Part 375. Environmental Remedial Programs. Subpart 375-6: Remedial
Program Soil Cleanup Objectives. §375-6.8 Soil Cleanup Objective Tables.
Table 375-6.8(b): Restricted Use Soil Cleanup Objectives. (http://www.dec.ny.gov/regs/15507.html
)
)
Metropolitan Engineering, Consulting & Forensics
(MECF)
Providing
Competent, Expert and Objective Investigative Engineering and Consulting
Services
P.O. Box
520
Tenafly,
NJ 07670-0520
Tel.:
(973) 897-8162
Fax:
(973) 810-0440
E-mail:
metroforensics@gmail.com
Web
pages: https://sites.google.com/site/metropolitanforensics/
https://sites.google.com/site/metropolitanenvironmental/
http://metroforensics.blogspot.com/
We are happy to announce the launch of our twitter account. Please make
sure to follow us at @MetropForensics or @metroforensics1
Metropolitan appreciates your business.
Feel free to recommend our services to your friends and colleagues.
