DTC is currently providing environmental consulting services specifically associated with polychlorinated biphenyl (PCB) contaminated building materials and soil in support of the complete renovation of the New Haven Academy. Prior to renovation, the facility will be abated to remove all interior and exterior building materials that are contaminated with PCBs above Federal and State regulatory limits. In addition, surficial soil contaminated by PCBs released from the building materials above will also be excavated and disposed.
DTC became involved with the PCB aspect of this project at the request of the Owner to conduct a third party peer review of PCB-related work completed by another subconsultant on the design team. The subconsultant had completed limited sampling of interior and exterior caulk, window glaze, and soil surrounding the building. The subconsultant had then prepared a PCB cleanup plan that was submitted to the U.S. Environmental Protection Agency (EPA) for approval. EPA subsequently issued a letter stating that the cleanup plan was incomplete and did not meet the federal regulatory requirements. In response, the subconsultant revised and re-submitted the plan to EPA, without conducting additional testing as requested by EPA. DTC began the peer review process after the revised plan had been submitted to EPA.
Upon completion of the peer review, DTC identified a number of significant deficiencies in the revised plan. In addition, the City of New Haven Health Department had requested testing of all building materials that could potentially contain PCBs, not just limited to caulk and window glaze. Such building materials could include: paint on CMU block walls and other surfaces, a variety of adhesives and mastics, moisture barriers, floor tiles, sink under-coatings, spray-on fireproofing, thermal insulation, and a variety of other miscellaneous materials. In addition, PCBs can migrate from parent materials, such as caulk, to the substrate to which they are attached, such as concrete and brick, resulting in contamination of the concrete/brick to levels above the cleanup standards.
DTC developed a comprehensive sampling plan to inventory and test all suspect interior and exterior building materials for PCBs. The Owner requested that DTC complete the testing and prepare a revised cleanup plan for EPA approval as quickly as possible to minimize further delays to the project.
The testing program included collection of over 240 building material samples and 20 soil samples for laboratory analysis. DTC then prepared a Self-Implementing On-site PCB Cleanup & Disposal Plan (SIP), which was submitted to EPA less than two months from the date that DTC began the testing program.
DTC’s testing showed that most exterior caulk and window glaze was contaminated above the Federal limit of 50 parts per million (ppm), and will require removal and disposal along with associated substrates (concrete and brick), in accordance with the EPA Toxic Substance Control Act (TSCA) regulations. DTC’s plan presented a methodology to selectively abate the PCB contaminated materials in a timely and cost-effective manner along with the previously planned demolition of the brick façade of the building.
Except for a very limited area of wall block coated with paint containing high levels of PCBs, DTC’s thorough and comprehensive testing conclusively demonstrated that PCBs were not present in any other interior building materials over the Federal limit of 50 ppm. As such, abatement of all but a very limited area of interior materials was determined NOT to be regulated by EPA, which will result in significant cost savings for disposal of PCB contaminated building material wastes, and will allow for a reduced frequency of post-abatement clearance sampling of remaining materials.
Abatement of materials containing PCBs at levels >1 to <50 ppm is mandated by Connecticut Statute, however, the Connecticut Department of Energy & Environmental Protection (DEEP) does not provide strict requirements regarding the removal and disposal of such materials, except that PCB contaminated materials cannot be disposed within the State. Elimination of EPA involvement with the abatement of the building interior will benefit the project greatly.