By David Schack and Scott Nunes for FacilitiesNet
Facility managers must be aware of the potential impact—including possible lawsuits—of buildings containing Polychlorinated Biphenyls (PCBs), especially schools. There was potentially widespread use of PCBs in both public and private schools built or renovated between 1950 and 1979. However, school administrators can take well-informed actions to reduce or eliminate potential exposure to PCBs by following the steps listed in this article. By implementing these preventive measures, potentially costly legal issues, unwarranted remediation, and construction delays can be avoided.
The emerging concern over polychlorinated biphenyls (PCBs) in construction materials, especially in schools, may significantly impact construction and renovation projects. By now, there is widespread awareness in the public education sector of the requirements for proper identification, management, and disposal of hazardous substances such as asbestos and lead. With PCBs, what was once thought to be a problem related solely to industrial sites and electrical companies is now becoming more prevalent in commercial and governmental buildings, particularly in schools, as awareness grows among contractors, administrators, facility managers, and the public.
In some instances, legal action has been brought against public agencies in citizen lawsuits as provided for under the Toxic Substance Control Act, which has jurisdiction over PCBs and other hazardous substances. Regardless of the project size, building owners and contractors should be aware of the potential impact of buildings containing PCBs, especially for high-risk facilities such as schools.
PCBs are regulated by the Environmental Protection Agency under the Toxic Substance Control Act, 40 CFR part 761. PCBs were commonly used in building materials from approximately 1950 to the late 1970s, when they were banned by Congress. PCBs were useful because of their properties: They offer electrical insulation, and are flame-resistant, plasticizing, chemically stable, and durable. However, PCBs are very persistent in the environment, can vaporize and migrate, and can cause adverse health effects in humans (cancer, reproductive disorders, acne-like skin conditions in adults, and neurobehavioral and immunological changes in children). School occupants can potentially be exposed to PCBs in the dust, indoor air, and surfaces in buildings. Externally, exposure may occur through contact with contaminated soil. Exposure occurs primarily through inhalation (some studies suggest up to 80 percent of exposures are through inhalation), but also through dermal contact or ingestion.
PCBs have been found in schools in materials and equipment such as fluorescent light ballasts, caulking, paints, window glazing, sealants, ceiling tile coatings, and spray-applied fireproofing. It is estimated that close to 50 percent of all U.S. public and private school buildings that are currently active were renovated or built during the period of 1950 to 1979. Some trade names associated with PCBs include Abestol, Aroclor, Askarel, Chlophen, Chlorexto, Fenclor, Pyralene, and Pyranol, among others.
Reducing Exposure to PCBs
EPA recommends actions be taken by school administrators, building owners, and facility managers to reduce PCB exposures if PCBs are present or suspected. This should be done prior to disturbing suspect materials so that students, staff, and workers are protected. A building suspected to contain PCBs should be properly characterized prior to coming up with an action plan to determine proper management, removal, and disposal of the PCBs. Potential primary sources listed above (caulk, sealants, etc.) should be tested. Some building materials — such as paint, masonry, ceiling tiles, carpeting, and wood — can absorb indoor PCB emissions from primary sources and become secondary sources for PCBs. Sometimes secondary sources emit PCBs after primary PCB sources are removed.
The first step in assessment and characterization of school buildings should be to test the indoor air to determine if PCBs are present, and then see if the results are below the PCB-exposure limits established by EPA. If the levels are above allowable exposure levels, then suspect buildings materials (primary sources) should be tested to evaluate whether they contain PCBs. Depending on the outcome of this testing, it may be necessary to further evaluate and test to see if surrounding materials (secondary sources) may be emitting PCBs. Bulk samples (a small portion of the material) should be collected for materials such as caulk and soil (potentially contaminated from emissions from exterior caulks and sealants). For porous surface materials (brick, masonry, concrete, wood), core samples should be collected (top 0.5 to 2 cm). Non-porous surface samples such as unpainted metal surfaces can have wipe samples collected.
If a source material is greater than 50 parts per million (ppm) of PCBs, then the material is regulated under the Toxic Substances Control Act. If an adjacent porous surface is greater than 1 ppm of PCBs, then that material is also regulated.
If identified PCBs are to remain at the site, a management plan should be developed and implemented. Under the management plan, staff at the site must work with the EPA regional PCB coordinator to manage the materials in place. If PCB-impacted materials are to be left in place, the management plan will typically include an ongoing surveillance program, including surface and air sampling. Additionally, building owners are typically required to record a deed restriction indicating the presence of PCBs at the site.
As a best practice, EPA recommends that building owners and facility managers remove PCB-containing caulk, paint, and other materials during planned renovations, as well as removing all PCB fluorescent light ballasts (sudden failure of a light ballast exceeding its lifespan can emit PCBs and cause undue exposure and add significant clean-up costs).
In addition, whether or not PCBs have been identified in school buildings, EPA recommends the following best management practices on a routine basis to minimize potential exposures:
To ensure that PCB materials are properly removed to avoid contaminating surrounding surfaces, trained workers using safe work practices should be used to reduce and contain dust from the removal process. Properly trained maintenance staff or experienced contractors should perform all activities involved in PCB removal, cleanup, and disposal. All contractors should be made aware of the regulatory requirements.
Reducing Potential Lawsuits and Regulatory Enforcement
Schools need to be aware of potential citizen lawsuits under the Toxic Substances Control Act. EPA also has enforcement power and tools that it can use where PCBs are present in materials such as caulking if the PCB content is above regulated levels (50 ppm). If PCBs are discovered to be present, it is important to identify key project leaders responsible for ensuring the proper management and disposal of the materials:
School administrators that are responsible for construction projects (renovation, demolition, modernization) involving PCB materials should understand the regulatory requirements regarding the removal/abatement of those materials. They can also consult with experienced environmental professionals or contact their local EPA office.
Occupants of buildings should be notified of upcoming renovation activities involving PCBs. They should be completely isolated from the work areas where PCB renovation or removal activities will occur to prevent exposure to PCBs. Other measures can be taken such as physically isolating the PCB work areas from other areas of the building by means of physical barriers and negative pressure systems.
When testing confirms that PCBs are present in building materials at regulated levels (building materials can also be assumed to contain PCBs in lieu of sampling), they need to be disposed of in accordance with the PCB regulations in 40 CFR part 761, subpart D. Currently, proper sampling of waste streams is required to properly identify potential hazardous wastes. For a construction project which impacts materials that could potentially contain PCBs, say with lead paint, waste profile samples should be collected.
Having a proper understanding of disposal requirements is an absolute necessity. In general, PCBs are classified as either PCB bulk product waste or PCB remediation waste. PCB bulk product waste is non-liquid waste such as building materials and plastics. (Under EPA’s definition, bulk product waste includes building materials coated or serviced with PCBs like caulking and sealants.) PCB remediation waste is waste that is contaminated with PCBs from spills or releases. This includes items such as soil, rags or debris generated during cleanups, sludge, etc. To further complicate the distinction, sometimes materials such as wood or concrete, into which PCBs have leached, may be considered PCB remediation waste. A hazardous waste specialist should be consulted to discuss packaging, labeling, transportation and disposal requirements.
What FMs Need to Know
There was potentially widespread use of PCBs in schools that were renovated or built between 1950 and 1979. However, school administrators can take well-informed actions to reduce potential exposure to PCBs by: characterizing if there are PCBs present; evaluating the options to address the presence of PCBs including removal, encapsulation, and best management practices; determining the correct disposal method; and coordinating construction team compliance and a public relations plan (to effectively communicate with the school community). By implementing these preventive measures, potentially costly legal issues due to exposure to PCBs (citizen lawsuits), unwarranted remediation, and construction delays can be avoided.
Schools should make sure they are aware of the requirements and that they protect themselves from 1) contractors in relation to change order costs and 2) citizen lawsuits and regulatory enforcement. EPA’s main goal regarding PCBs in schools is to ensure that school districts implement recommended actions to limit exposures. EPA believes that, if school districts implement preventive measures, enforcement may not be the best option to reduce exposure in school buildings. In other words, if schools take appropriate proactive measures to reduce PCB exposure, it is likely EPA will make enforcement a low priority, though they would likely get involved in situations where risks to public health were not being addressed.
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