final pcb pilot study feasibility study 01-31-12 changes

FEASIBILITY STUDY

FOR THE

NEW YORK CITY SCHOOL CONSTRUCTION AUTHORITY PILOT STUDY TO

ADDRESS PCB CAULK IN NEW YORK CITY SCHOOL BUILDINGS

EPA CONSENT AGREEMENT AND FINAL ORDER

DOCKET NUMBER: TSCA-02-2010-9201

SCA LLW NO.: 060390 SCA CONTRACT NO.: C000011517

SCA JOB NO.: 34425

TRC ENGINEERS, INC. PROJECT NO.: 166423-0000-0025

January 31, 2011

Prepared by: Prepared for:

TRC Engineers, Inc. NYC SCA 1430 Broadway, 10th Floor 30-30 Thomson Avenue New York, NY 10018 Long Island City, NY 11101-3045 Phone: (212) 221-7822 Phone: (718) 472-8501 Fax: (212) 221-7840 Fax: (718) 472-8297

NYCSCA FEASIBILITY STUDY

PILOT STUDY TO ADDRESS PCB CAULK IN NYC SCHOOL BUILDINGS

TRC ENGINEERS, INC. i 166423-0000-0025

TABLE OF CONTENTS

Section Page

EXECUTIVE SUMMARY .................................................................................................................... VII

1.0 INTRODUCTION ......................................................................................................................... 1

1.1 Purpose ............................................................................................................................... 1 1.2 Background ......................................................................................................................... 1

1.2.1 Relevant Schools .................................................................................................... 2 1.2.3 Overview of Remedial Investigations ..................................................................... 4 1.2.4 Applicable Comparison Criteria ........................................................................... 5 1.2.5 Nature and Extent of PCB Caulk ........................................................................... 6 1.2.6 PCB Caulk Fate and Transport ............................................................................. 7 1.2.7 USEPA Defined Areas to be Evaluated in Each Pilot School Building ................. 7

1.3 Scope of Pilot Study ........................................................................................................... 8 1.4 Summary of Findings and Recommendations of the Pilot Study ....................................... 8

2.0 DESCRIPTION OF THE REMEDIAL ALTERNATIVES .................................................... 13

2.1 Introduction ....................................................................................................................... 13 2.2 Remedial Objectives ......................................................................................................... 13 2.3 General Scope of Response Actions ................................................................................. 13 2.4 Description of Individual Remedial Alternatives Evaluated ............................................ 13

2.4.1 Patch and Repair of All Damaged and Deteriorated PCB Caulk ....................... 14 2.4.2 Encapsulation of All PCB Caulk ......................................................................... 14 2.4.3 Removal of All PCB Caulk and Replacement with New Caulk ............................ 14 2.4.4 Window Removal and Replacement ..................................................................... 14 2.4.5 Removal and Replacement of PCB Light Ballasts and Fixtures .......................... 15 2.4.6 Best Management Practices ................................................................................. 15 2.4.7 Remediation of Surface Soils in Outside Exposure Areas ................................... 16

3.0 COST ANALYSIS OF PILOT STUDY REMEDIAL ALTERNATIVES .............................. 17

3.1 Cost Analysis of Patch and Repair Remedy ..................................................................... 17 3.1.1 Description of Work Performed ........................................................................... 17 3.1.2 Labor .................................................................................................................... 19 3.1.3 Transportation and Disposal ............................................................................... 20 3.1.4 Summary of Contractor Costs .............................................................................. 20 3.1.5 Amount of PCB Caulk Remediated ...................................................................... 20 3.1.6 Cost to Remediate PCB Caulk ............................................................................. 20



TRC ENGINEERS, INC. ii 166423-0000-0025

TABLE OF CONTENTS

Section Page

3.2 Cost Analysis of Removal and Replacement Remedy ...................................................... 21 3.2.1 Description of Work Performed ........................................................................... 21 3.2.2 Labor .................................................................................................................... 23 3.2.3 Transportation and Disposal ............................................................................... 23

3.2.4 Summary of Contractor Costs ...................................................................... 23 3.2.5 Amount of PCB Caulk Remediated ...................................................................... 24 3.2.6 Cost to Remediate PCB Caulk ............................................................................. 24

3.3 Cost Analysis of Encapsulation Remedy .......................................................................... 24 3.3.1 Description of Work Performed ........................................................................... 24 3.3.2 Labor .................................................................................................................... 27 3.3.3 Transportation and Disposal ............................................................................... 27 3.3.4 Summary of Contractor Costs .............................................................................. 27 3.3.5 Amount of PCB Caulk Remediated ...................................................................... 27 3.3.6 Cost to Remediate PCB Caulk ............................................................................. 27

3.4 Cost Analysis of Window Removal and Replacement Remedy ....................................... 28 3.4.1 Description of Work Performed ........................................................................... 28 3.4.2 Labor .................................................................................................................... 28 3.4.3 Transportation and Disposal ............................................................................... 28 3.4.4 Summary of Contractor Costs .............................................................................. 28 3.4.5 Amount of PCB Caulk Remediated ...................................................................... 28 3.4.6 Cost to Remediate PCB Caulk ............................................................................. 28

3.5 Cost Analysis of Light Fixture Ballast Removal and Replacement Remedy ................... 29 3.5.1 Description of Work Performed ........................................................................... 29 3.5.2 Labor .................................................................................................................... 29 3.5.3 Transportation and Disposal ............................................................................... 29 3.5.4 Summary of Contractor Costs .............................................................................. 29 3.5.5 Number of PCB Light Ballasts/Fixtures Remediated .......................................... 29 3.5.6 Cost to Remediate PCB Light Ballasts/Fixtures .................................................. 29

3.6 Cost to Remediate Outdoor Exposure Areas .................................................................... 30 3.6.1 P.S. 178X/176 ...................................................................................................... 30 3.6.2 P.S. 199M ............................................................................................................. 30 3.6.3 P.S. 309K ............................................................................................................. 30

3.7 Cost Analysis Discussion .................................................................................................. 31



TRC ENGINEERS, INC. iii 166423-0000-0025

TABLE OF CONTENTS

Section Page

4.0 INDIVIDUAL ANALYSIS OF REMEDIAL ALTERNATIVES ............................................ 34

4.1 Introduction ....................................................................................................................... 34 4.2 Patch and Repair Remedy ................................................................................................. 35

4.2.1 Description ............................................................................................................... 35 4.2.2 Assessment ............................................................................................................... 35

4.2.2.1 Overall Protectiveness .................................................................................. 35 4.2.2.2 Compliance with Comparison Criteria ......................................................... 35 4.2.2.3 Long-Term Effectiveness and Permanence ................................................... 36 4.2.2.4 Reduction of Toxicity, Mobility or Volume Through Treatment ................... 36 4.2.2.5 Short-Term Effectiveness .............................................................................. 36 4.2.2.6 Ease of Implementation ................................................................................. 36 4.2.2.7 Cost ............................................................................................................... 37

4.3 Encapsulation .................................................................................................................... 37 4.3.1 Description .......................................................................................................... 37 4.3.2 Assessment ........................................................................................................... 37


4.4 Removal and Replacement ............................................................................................... 39 4.4.1 Description .......................................................................................................... 39 4.4.2 Assessment ........................................................................................................... 39




TRC ENGINEERS, INC. iv 166423-0000-0025

TABLE OF CONTENTS

Section Page

4.5 Window Removal and Replacement ................................................................................. 41 4.5.1 Description .......................................................................................................... 41 4.5.2 Assessment ........................................................................................................... 41


4.6 PCB Light Fixture and Ballast Replacement .................................................................... 43 4.6.1 Description .......................................................................................................... 43 4.6.2 Assessment ........................................................................................................... 43


4.7 Best Management Practices .............................................................................................. 45 4.7.1 Description .......................................................................................................... 45 4.7.2 Assessment ........................................................................................................... 45




TRC ENGINEERS, INC. v 166423-0000-0025

TABLE OF CONTENTS

Section Page

4.8 Soil Removal in Outside Exposure Areas ......................................................................... 46 4.8.1 Description .......................................................................................................... 46 4.8.2 Assessment ........................................................................................................... 47


5.0 PROPOSED PILOT PREFERRED REMEDY ........................................................................ 49

6.0 REFERENCES ............................................................................................................................. 51

LIST OF TABLES (WITHIN TEXT) Table 1.1 – Summary of Pilot School Buildings Table 1.2 – USEPA’s Public Health Levels of PCBs in School Indoor Air Table 3.1 - List of 2010 Remediated Areas: PCB Caulk Patch and Repair for P.S. 178X/176 Table 3.2 - List of 2011 Remediated Areas: PCB Caulk Patch and Repair for P.S. 178X/176 Table 3.3 - List of 2011 Remediated Areas: PCB Caulk Removal and Replacement with New Caulk for

P.S. 199M Table 3.4 - List of 2010 Remediated Areas: PCB Caulk Encapsulation for P.S. 309K Table 3.5 - List of 2011 Remediated Areas: PCB Caulk Encapsulation for P.S. 309K Table 3.6 – Cost Comparison of Interior Remedial Alternatives Table 3.7 - Cost Comparison of Exterior Remedial Alternatives



TRC ENGINEERS, INC. vi 166423-0000-0025

LIST OF FIGURES

Figure 1A – P.S. 178X/176 Site Location Map Figure 2A – P.S. 199M Site Location Map Figure 3A – P.S. 309K Site Location Map Figure 4A – P.S. 183Q Site Location Map Figure 5A – P.S. 3R Site Location Map

LIST OF APPENDICES

A. Figures B. Individual Analysis of Remedial Alternatives C. List of Relevant Schools D. SCA Specification Section 02082 PCB-Containing Caulk Removal Work E. SCA PCB Ballast Inspection and Response Project Plan F. Best Management Practices (BMP) for PCB Caulk in New York City School Buildings G. Pilot Study Remedial Alternative Cost Analyses H. Encapsulant Manufacturer’s Cut Sheets and Material Safety Data Sheets I. Remedial Investigation Plan Dust Control J. Soil Sampling Procedures



TRC ENGINEERS, INC. vii 166423-0000-0025

EXECUTIVE SUMMARY

The New York City Division of School Facilities (DSF) and School Construction Authority (SCA) currently implement a PCB Program that includes protocols to properly manage PCB Caulk in public schools and during capital improvement projects.

On January 19, 2010, The City of New York (the City) and SCA reached an agreement regarding the assessment and remediation of PCB Caulk in public school buildings with the United States Environmental Protection Agency (USEPA), Region 2 (Consent Agreement and Final Order (CAFO), Docket Number TSCA-02-2010-9201). As a result of the agreement, the City is undertaking a comprehensive Pilot Study to evaluate the possible presence of PCB Caulk and preferred remedial alternatives. Where necessary, the Pilot Study also evaluated non-caulk sources of PCBs, such as light ballasts. The ultimate goal of the CAFO is to develop a Citywide PCB Management Plan for the relevant schools (built between 1950 and 1978). The agreement required the City to select, and USEPA to approve, five Pilot School Buildings from the list of relevant schools. The five approved Pilot School Buildings are P.S. 178X/176 in the Bronx, P.S. 199M in Manhattan, P.S. 309K in Brooklyn, P.S. 3R in Staten Island, and P.S. 183Q in Queens.

A Pilot Study was developed and implemented to test and evaluate selected remedial strategies in these Pilot School Buildings. The study was performed in accordance with the Remedial Investigation (RI) Plan dated July 9, 2010 and the Addendum No.1 to the RI Plan dated July 19, 2010 (approved by USEPA on August 12, 2010), and the modification dated November 23, 2010 (approved by USEPA on November 29, 2010). The study was also performed in accordance with recommendations presented in TRC’s Interim Remedial Investigation Report (IRIR) dated June 15, 2011 (approved by USEPA on August 30, 2011). The purpose of these studies was to assist in identifying a preferred remedy or remedies for PCB Caulk and PCB light ballasts in public school buildings. The remedial alternatives selected, in consultation with the USEPA, for evaluation during the Pilot Study and the Feasibility Study included:

(1) Patch and repair of caulk (i.e., remove loose and deteriorating caulk and replace with new non PCB-containing caulk);

(2) Encapsulation of caulk;

(3) Removal of all caulk and replacement with new non PCB-containing caulk;

(4) Window frame and caulk removal and replacement with new window frames and non PCB-containing caulk;

(5) PCB light ballast and fixture removal; and,

(6) Best management practices (i.e., use pre-remedial baseline sampling data to evaluate the effectiveness of current operation and maintenance practices).

Remedial alternatives (1), (2), and (3) were evaluated in three Pilot School Buildings - P.S. 178X/176, P.S. 309K, and P.S. 199M, respectively. Remedial alternative (4) was evaluated in P.S. 183Q. Remedial alternative (5) was evaluated in P.S. 3R. Remedial alternative (6) was also evaluated in each of the five Pilot School Buildings through the evaluation of the pre-remediation sampling data. The Pilot Study was implemented in two primary phases. In the first phase, which was conducted from June 2010 through November 2010, the SCA implemented a remedial investigation of three Pilot School



TRC ENGINEERS, INC. viii 166423-0000-0025

Buildings (P.S. 178X/176, P.S. 199M, and P.S. 309K) in accordance with the CAFO and the RI Plan. The scope, results, findings and recommendations of these initial remedial investigations are presented in the IRIR dated June 15, 2011, and Addendum No. 1 to the Report dated October 5, 2011, which the USEPA approved in its letter dated October 20, 2011. As presented in the subsequent RI report, the second phase of the Pilot Study occurred from April 2011 through October 2011. Whole-school remedies consistent with the first phase remedies were implemented in P.S. 178X/176, P.S. 199M, and P.S. 309K. In addition, two additional schools were studied under the Pilot Study to evaluate other remedial alternatives: light ballast and fixture removal was evaluated in P.S. 3R and window removal and replacement was evaluated in P.S. 183Q. Based upon post-remedial air sample results, additional post-pilot remedial efforts were also undertaken in 2011 in all five of the Pilot School Buildings except P.S. 178X/176. As part of the RI Report, this Feasibility Study (FS) has been prepared to present the results of an evaluation of the potential remedial actions based on the Pilot Study results completed to date at these five Pilot School Buildings. Included in the FS is an evaluation of the individual remedial alternatives in order to aid in the selection of the most appropriate remedy. The individual analysis examines the performance of each alternative against seven evaluation criteria highlighting the specific strengths and weaknesses relative to each evaluation criterion. A matrix summarizing the results of the evaluation of the remedial alternatives against the evaluation criteria is included in Appendix B. These criteria are designed to allow the analysis of each alternative to address all the statutory requirements and considerations in order to select the most appropriate remedial alternative.

The proposed Pilot Preferred Remedy, as supported by the companion Remedial Investigation Report, is as follows:

• The Pilot Study evaluated five remedial alternatives with respect to interior caulk: (1) Patch and repair of caulk at P.S. 178X/176; (2) Encapsulation of caulk at P.S. 309K; (3) Removal of all caulk and replacement with new non PCB-containing caulk at P.S. 199M; (4) Window frame and caulk removal and replacement with new window frames and non PCB-containing caulk at P.S. 183Q; and (5) Best Management Practices at all Pilot School Buildings. Based on the current data, each of these alternative remedial approaches has been shown to be effective at reducing potential exposures to interior PCB caulk in the Pilot School Buildings. Thus, the alternative remedial approaches implemented at each Pilot School Building for interior caulk should remain in place and continue to be evaluated pursuant to the USEPA-approved long-term monitoring plan.

• The Pilot Study determined that the replacement of PCB light ballasts and associated fixtures is a successful remedial measure for lowering PCB levels in indoor air where concentrations exceed the USEPA air guidance values. Light fixture replacements were implemented at P.S.309K, P.S. 178X/176, and P.S. 199M as supplemental remedial measures, and at P.S. 3R as the primary remedial measure. Light fixture replacement is effective where a supplemental remedy is necessary, and also as a primary remedial measure. Thus, the Pilot Preferred Remedy includes light fixture replacement at the Pilot School Buildings. Light fixture replacement will be implemented at P.S. 183Q in accordance with the Greener, Healthier Schools for 21st Century and Energy Savings Performance Contracting (ESPC) program.

• PCB contamination of soil encountered in Outside Exposure Areas at P.S. 199M, P.S. 178X/176 and P.S. 309K was successfully mitigated through the process of delineation, excavation, and off-site disposal. The PCB contaminated soil identified in the outdoor exposure areas at P.S. 183Q



TRC ENGINEERS, INC. ix 166423-0000-0025

and P.S. 3R should be excavated and disposed utilizing these same protocols. Create a Soil Remediation Plan for USEPA approval and remediate soils above 1 part per million (ppm) by excavation and off-site disposal, and obtain confirmatory post-excavation soil results. Backfill with clean fill and reestablish surface features. Exterior caulk at the Pilot School Buildings should be periodically inspected and be repaired to the extent it becomes damaged or deteriorated.

This proposed Pilot Preferred Remedy offers a reasoned approach to efficiently manage PCB Caulk, PCB light ballasts and associated fixtures, and contaminated surface soils in Outside Exposure Areas, at the Pilot School Buildings. This proposed Pilot Preferred Remedy is subject to USEPA review and possible modification prior to approval. In addition, the Pilot Preferred Remedy is subject to modification based on the results of ongoing and future Pilot Study activities to be reported in Supplemental Reports to this RIR.



TRC ENGINEERS, INC. 1 166423-0000-0025

1.0 INTRODUCTION

1.1 Purpose

The purpose of this Feasibility Study (FS) is to evaluate the remedial alternatives to address PCB Caulk, PCB light ballasts and fixtures, and PCB-contaminated surface soils, with consideration of the methods and products utilized, affects of remedial alternatives on post-remediation PCB concentrations, reducing human exposure to PCB sources, short-term and long-term effectiveness, cost, labor requirements, length of implementation, potential to disrupt normal school activities, and other relevant factors in primary, transitory and outside exposure areas (defined in Section 1.2.5). This study will help to establish the activities that will inform the development of City-Wide PCB Management Plan, as explained in the Consent Agreement and Final Order (CAFO) Docket Number TSCA-02-2010-9201 between the United States Environmental Protection Agency (USEPA) and the New York City School Construction Authority (SCA) and the City of New York. 1.2 Background

In recent years, the USEPA has studied caulking materials and determined that caulk produced between 1950 and 1978 may potentially contain PCBs. Although the manufacture and most uses of PCBs were banned, buildings constructed or renovated from 1950 to 1978, including schools, may contain caulk with PCBs. During this period, the use of PCBs in caulk was legal. Exposure to PCBs in caulk may occur as a result of their release from the caulk into the air, dust, surrounding surfaces and soil, and through direct contact. In September 2009, the USEPA published a series of guidance materials pertaining to the management of PCB Caulk in older buildings. The guidance materials explained the current state of knowledge regarding PCB Caulk and set forth best management practices for addressing PCB Caulk. The USEPA defines "PCB Caulk" as caulk that contains PCBs at concentrations of 50 parts per million (ppm) or greater. Caulk is defined for purposes of this study as any semi-drying or slow drying plastic material used to seal joints or fill crevices around window frames or panes, doors, or other building components; caulk does not include coatings, glazing varnishes or sealants that are or were applied as liquids (U.S. EPA 2010a).

On January 19, 2010, the City of New York (the City) and the USEPA reached an agreement regarding the monitoring and remediation of PCB Caulk in public school buildings. As a result of the agreement, the City undertook a Pilot Study to evaluate the possible presence of PCB Caulk and the most effective methods for remediation in five Pilot School Buildings. The study is the first of its kind nationwide in a public school setting. Although the agreement is significant, it is not the first step that the City has taken regarding PCB Caulk. The SCA currently implements a PCB Program that includes protocols to identify and remove PCB Caulk in areas of public schools renovated during capital improvement projects.

From June, 2010, through November 2010, the SCA implemented a remedial investigation at three Pilot School Buildings (P.S. 178X/176, P.S. 199M, and P.S. 309K) in accordance with the CAFO and the Remedial Investigation Plan for The New York City School Construction Authority Pilot Study to Address PCB Caulk in New York City School Buildings (RI Plan), prepared by TRC Engineers, Inc. (TRC) and dated July 9, 2010, and approved by the USEPA. From April, 2011, through October, 2011, remedial investigations were implemented in all five Pilot School Buildings, including the additional




Pilot School Buildings P.S. 3R and P.S. 183Q. The scope of the remedial investigations completed so far is summarized as follows:

• Performed a caulk survey in each of the potential Pilot Study Areas at P.S. 178X/176, P.S. 309K, P.S. 183Q and P.S. 199M;

• Conducted an initial inspection and collected pre-remedial wipe and air samples in a representative number of areas in each of the five Pilot School Buildings;

• Conducted soil sampling in unpaved areas immediately surrounding each of the Pilot School Buildings for laboratory analysis as discussed in the Remedial Investigation Plan. Additionally, exterior caulk samples were collected where soil sample results exceeded the comparison criteria;

• Applied various remedial alternatives for managing PCB Caulk and/or light ballasts in the five Pilot School Buildings;

• Collected post-remedial air and wipe samples from the same locations as the pre-remedial samples to gauge the effects of the remedial alternatives;

• Evaluated the effectiveness of current best management practices in each Pilot School Building;

• Prepared an Interim Remedial Investigation Report presenting and evaluating all data, analytical results of sample analyses, and remedial methods from the first phase of the study performed in 2010;

• Prepared a Remedial Investigation Report presenting and evaluating all data, analytical results of sample analyses, and remedial methods for the second phase of the study performed in 2011; and,

• Prepared this appended Feasibility Study utilizing the Pilot Study data and identifying the proposed Pilot Preferred Remedies.

1.2.1 Relevant Schools

From 1950 to 1978, it was legal to manufacture PCBs and use materials containing PCBs in the construction and renovation of buildings. In 1979, PCB manufacturing was banned by Congress and its use phased out due to concerns about potential adverse effects to human health and the environment. The SCA has identified Relevant Schools that were constructed between 1950 and 1978. The CAFO focuses on identifying and remediating PCB Caulk that may be present in these schools. A list of the Relevant Schools is presented in Appendix C.




1.2.2 Description of Pilot School Buildings

From this list of Relevant Schools, the SCA proposed and the USEPA approved the following five Pilot School Buildings for the Pilot Study.

Table 1.1 – Summary of Pilot School Buildings

NYC School ID School Name Address Current Student

Education Levels

P.S. 178X/176

Dr. Selman Waksman School/

P.S. 176 (Charter School)

850 Baychester Ave. Bronx, NY 10475

718-904-5570

Grades K-5/ Grades PK - 12

P.S. 199M Jessie Isador Straus School

270 West 70th Street Manhattan, NY 10023

212-799-1033 Grades K-5

P.S. 309K

George E. Wibecan Preparatory

Academy/Excellence Charter School for Girls

794 Monroe Street Brooklyn, NY 11221

718-574-2381

Grades PK – 5/ Grades K – 1

P.S. 3R Margaret Gioiosa School

80 South Goff Avenue Staten Island, NY 10309

718-984-1021 Grades PK – 5

P.S. 183Q Dr. Richard R. Green School

2-45 Beach 79th Street Queens, NY 11693

718-634-9459 Grades PK – 8

K = Kindergarten PK = Pre-Kindergarten

The location of each Pilot School Building is shown on the figures provide in Appendix A. A brief summary of the relevant architectural and mechanical systems at the five Pilot School Buildings follows:

• P.S. 178X/176 - This school is housed in a three-story brick and concrete building constructed in

1972. Five central HVAC units are located on the roof and one HVAC unit is located in the basement of the building. Each unit services a different zone inside the building. The zones are organized as North, South, East, West, and Center. There is central air conditioning (A/C) and perimeter radiant heat. Approximately seven window-mounted A/C units supplement the central HVAC system. Hot water is supplied to the building from an off-site location. The hot water is pumped to the rooftop and basement HVAC units for heating. The windows are double-paned, have a membrane between the panes, and have aluminum casing. Window glazing was recently replaced throughout the school.




• P.S. 199M - This school is housed in a three-story brick building constructed in 1962. The mechanical systems consist of a classroom and bathroom exhaust system, with perimeter heating units. Make-up air for this system is provided by operable windows. There are 19 rooftop exhaust fans, which were replaced in September of 2008, that service the classrooms and bathrooms. The gymnasium and auditorium utilize forced air for heating and ventilation. The gymnasium and auditorium are serviced by separate blower and exhaust fans located in mechanical rooms on the second and third floors. Outside air enters the gymnasium and auditorium systems through louvers located in the third floor mechanical room. There are window mounted A/C units in the majority of the classrooms. Windows (including frames) were recently replaced in this school.

• P.S. 309K - This school is housed in a three-story brick building constructed in 1963. The

mechanical systems consist of a classroom and bathroom exhaust system, with perimeter heating units. Make-up air for this system is provided by operable windows. There are a total of 15 exhaust fans, ten of which are located on the upper roof and five on the lower roof. Basement fans provide forced air heat and ventilation to the auditorium and gymnasium. Outside air enters the gymnasium and auditorium systems through louvers located in the basement mechanical room. There are window mounted A/C units in the majority of the classrooms. Windows (including frames) were recently replaced in this school.

• P.S. 183Q – This school is housed in a three-story brick building built in 1961. Four HVAC units are located on the roof; however, these HVAC units are not operable. There are also eleven exhaust fans located on the roof. Approximately ten window-mounted and ten portable units supply air conditioning in certain building spaces. Hot water and steam heat is supplied to the building from two boilers in the basement that operate on No. 6 fuel oil. Wall-mounted steam radiators are utilized throughout the building. The first floor and stairwell windows are “hopper” windows that fold inward to open. The second and third floor windows consist of two sets of operable double paned sashes for airplane noise reduction in each location.

• P.S. 3R – This school is housed in a one-story brick building with a basement. P.S. 3R was built in 1959, with additions in 1968 and 2005. The portion of the school that was constructed in 2005 is not included in the Pilot Study. The mechanical systems consist of a classroom exhaust system vented to the roof. Steam heated radiators are located in each room. Offices contain window-mounted air conditioning units. Three rooftop HVAC units service the newly constructed portion of the school.

1.2.3 Overview of Remedial Investigations

The scope of the remedial investigations, which have been completed within the five Pilot School Buildings, followed the sequential phasing of work as described below:

• Performed a caulk survey (including sampling, location, quantity, and condition) to inventory suspected PCB Caulk in potential Pilot Study Areas.

• Conducted pre-remedial air and wipe sampling for laboratory analysis in the Pilot Study Areas. Samples were collected indoors, from primary exposure areas and transitory areas where students are typically located, just prior to performing remedial alternatives.

• Conducted soil sampling in unpaved areas immediately surrounding each of the Pilot School Buildings for laboratory analysis.




• Evaluated various remedial alternatives in each Pilot School Building. The remedial alternatives selected, in consultation with the USEPA, for evaluation during the Pilot Study were:

(1) Patch and repair of caulk (i.e., remove loose and deteriorating caulk and replace with new non PCB-containing caulk);

(2) Encapsulation of caulk;

(3) Removal of all caulk and replacement with new non PCB-containing caulk;

(4) Window frame and caulk removal and replacement with new window frames and non PCB-containing caulk; and,

(5) Best management practices (i.e., use pre-remedial sampling data from each Pilot School Building to evaluate the effectiveness of current operation and maintenance practices).

Remedial alternates (1), (2), and (3) were evaluated in the Pilot School Buildings - P.S. 178X/176, P.S. 309K, and P.S. 199M, respectively. In each of these schools, the remedial alternates were implemented in only limited Pilot Study areas in 2010, and then the remainder of the areas throughout the schools were remediated in 2011. Remedial alternative (4) was implemented in 2011 in all areas where windows had not been previously replaced in P.S. 183Q. Remedial alternative (5) was also evaluated in each of the five Pilot School Buildings through the evaluation of the pre-remediation sampling data. In addition, due to findings in the first three Pilot School Buildings studied during 2010, removal of light fixture PCB ballasts was evaluated in one Pilot School Building (P.S. 3R) in 2011 pursuant to the SCA RI Plan modification dated November 23, 2010, which was approved by the USEPA in correspondence dated November 29, 2010.

1.2.4 Applicable Comparison Criteria

This section summarizes the existing comparison criteria for each media that will be incorporated into the evaluation of the Pilot Study results. • Bulk Caulk Samples

Any bulk caulk samples that exceeded 50 ppm of total PCBs were considered to be PCB Caulk. (Bulk caulk samples will be hereafter referred to as caulk samples.)

• Air Samples

Based upon USEPA’s indoor air guidelines for schools and ages of building occupants (U.S. EPA 2009), air sampling results were compared to the following values:

Table 1.2 – USEPA’s Public Health Levels of PCBs in School Indoor Air (ng/m3)

Age 3 to <6 yr

(Pre Kindergarten and Kindergarten)

Age 6 to <12 yr

(Elementary School)

Age 12 to <15 yr

(Middle School)

Age 15 to<19 yr

(High School)

Age 19+ yr

(Faculty)

100 300 450 600 450




It is important to note that EPA guidance contained in the document entitled "Proper Maintenance, Removal, and Disposal of PCB-Containing Fluorescent Light Ballasts" states, "In order to provide guidance on levels of concern regarding chemicals in the environment, EPA develops reference doses (RfD) and concentrations (RfC). A reference dose is an estimate of a daily oral exposure level that the human population, including sensitive subpopulations that if one were exposed to for a lifetime would not cause appreciable risk to human health. EPA's RfD for the one type of PCB, Aroclor 1254, is 0.02 micrograms per kilogram per day. Based on this RfD and exposure factors such as typical air inhalation rates and the period of time spent at school, EPA has estimated the PCB levels of 0.2 - 0.3 micrograms per cubic meter of air in schools would not result in harmful effects to human health even if one were exposed over a lifetime. This is a conservative, health protective estimate. EPA's goal is not to have people exposed above this RfD level. Exceeding this level does not mean that adverse effects will necessarily occur. However, as exposure levels become higher, EPA has less confidence that the exposures will not result in adverse effects."

• Surface Wipe Samples Pre and post-remedial wipe samples were compared to USEPA’s High Occupancy wipe sample criteria of 10 µg/100 cm2 (40 CFR 761.3, 761.123 and 761.30).

• Soil Samples

Soil samples were compared to USEPA’s clean backfill standard (40 CFR 761.125(4) (v) and 40 CFR 761.125(b) (ii)) and the New York State Department of Environmental Conservation (NYSDEC) Technical and Administrative Guidance Memorandum (TAGM) 4046 and 6 NYCRR Part 375 value of 1 ppm for PCBs.

Target Laboratory Reporting Limits for each sampling media were below these comparison criteria. 1.2.5 Nature and Extent of PCB Caulk

PCB Caulk has been surveyed and identified in four out of the five Pilot School Buildings. In P.S. 3R, surveying and sampling of interior caulk was not performed as PCB light fixtures were evaluated in place of caulk. At P.S. 178X/176, P.S. 199M and P.S. 309K, all of the spaces within the three buildings were evaluated for PCB Caulk, while in P.S. 183Q only the Pilot Study rooms were evaluated. In the schools evaluated, the condition, concentration, and location of PCB Caulk varied from school-to-school, and even from room-to-room within a particular school. For instance, at P.S. 183Q and P.S. 309K, PCB Caulk was identified in transitory areas but not primary areas, while in P.S. 199M and P.S. 178X/176, PCB Caulk was identified in both primary and transitory areas. In total, 826 individual suspect caulk locations/materials were surveyed in 407 different spaces at P.S. 178X/176, P.S. 199M and P.S. 309K, during the Pilot Study work performed in 2010 and 2011. Generally, samples from three or more discrete locations comprising each homogeneous material were composited for laboratory analysis. Of the 826 individual interior caulk locations/materials identified, 176 were found to contain total PCB concentrations greater than 50 ppm. The analytical results for the interior caulk samples obtained from the three schools indicate PCB concentrations ranged from non-detect (less than 0.323 ppm) to 440,000 ppm. Of those 176 positive individual locations/materials, 78 locations/materials were found to be damaged, deteriorated, and/or loose. Please refer to Section 2.0 of the Interim RI Report and RI Report for additional details regarding the bulk caulk survey and sampling.




At P.S. 183Q, a total of 64 individual suspect caulk locations/materials were surveyed in 12 different locations during the Pilot Study work performed in 2011. Of the 64 individual caulk locations/materials identified, 17 were found to contain PCBs greater than 50 ppm, and 13 of those locations/materials were found to be damaged, deteriorated, and/or loose. The analytical results for the interior caulk samples obtained at P.S. 183Q indicate that PCB concentrations ranged from non-detect (less than 1 ppm) to 328,000 ppm. The five schools the Pilot Study has examined represents less than one percent (1%) of the total number of Relevant Schools. From the Pilot Study activities to date, no distinct pattern has emerged that could be used to predict the location, concentration, or condition of PCB Caulk. 1.2.6 PCB Caulk Fate and Transport

Understanding how individuals can be exposed to PCBs is critical in order to evaluate ways to limit exposure. One source of exposure to PCBs is through fine particulates contaminated with PCBs. Once in the air, fine particulate with PCBs may be widely dispersed. Larger sized particulates can also be dispersed, although they tend to settle out of the air fairly rapidly. Contact with such particulate may result in any or all of three possible exposure routes – inhalation, ingestion and direct contact. Exposure through inhalation occurs when an individual breathes in air containing respirable sized PCB-laden particulate in the form of dust or deteriorated caulk. Inhalation exposure to PCBs is also possible when PCBs volatilize directly from source materials (e.g., PCB Caulk and ballasts containing PCBs) into indoor air. When an individual comes into direct contact with settled particulates, a portion of the PCBs may absorb through the skin. Ingestion is also possible if particulates are transferred to the mouth. Exposure through direct contact and ingestion are also possible through other means. If an individual directly contacts building materials (e.g., PCB Caulk) or soil contaminated with PCBs, some may be absorbed through the skin. Ingestion is also possible if building materials or soil is ingested directly through hand-mouth transfer. The risks associated with exposure to a given concentration of PCBs are greater in the Primary Exposure Areas, as opposed to Transitory Areas, because individuals spend a longer amount of time in these areas. The RI Report indicates that the dust found in the building does not generally contain PCBs at concentrations above the applicable comparison criteria. Therefore, the risks associated with inhalation, direct contact, and ingestion of PCB-laden dusts are believed to be minimal. Airborne concentrations of PCBs sometimes exceeded the applicable comparison criteria. Therefore, excluding dietary intake, the primary route of exposure within the Pilot School Buildings is believed to be through inhalation of PCBs. The greatest risk from soil is direct contact and ingestion. Because the soil is located outside of the building, any PCBs that volatilize from the soil will tend to dissipate into the atmosphere. 1.2.7 USEPA Defined Areas to be Evaluated in Each Pilot School Building

The CAFO defines three exposure areas requiring study – Primary Exposure Areas, Transitory Areas, and Outside Exposure Areas. A brief description of these evaluation areas and the scope of the evaluation are provided below:

Primary Exposure Areas - Classrooms, gymnasiums and cafeterias. These areas in the school buildings are where students are typically located for prolonged periods during the school day. Approximately fifteen percent (15%) of the classrooms in each school building were selected for




surveying and sampling. Representative classrooms were selected for sampling and surveying on each floor of the school occupied by students. In addition, the cafeterias and gymnasiums were selected for sampling and surveying, when present.

Transitory Areas – Interior areas such as stairways, hallways and bathrooms where students may be present, but generally for relatively shorter periods during the school day. One or more transitory areas were surveyed and sampled at each Pilot School Building.

Outside Exposure Areas – Areas within a ten foot wide strip of any exposed soil immediately adjacent to school buildings. Exposed soil was subjected to sampling and laboratory analysis at three distances from the building (0.5 feet, 3 feet, and 8 feet) at intervals along the building face of approximately twenty feet.

1.3 Scope of Pilot Study

The purpose of the Pilot Study is to evaluate the possible presence of PCB Caulk located in primary, transitory and outside exposure areas and evaluate remedial strategies with consideration of the effectiveness of the remedy, logistics, disruption to educational activities, and overall costs. This Feasibility Study will evaluate the remedial alternatives and recommend, a suitable Pilot Preferred Remedy. 1.4 Summary of Findings and Recommendations of the Pilot Study

Based on the results of the 2010 and 2011 pilot activities to-date, the following is a summary of the overall findings of the Pilot Study:

• In all five (5) Pilot School Buildings, despite the significant variability in the quantity and concentration of PCB Caulk concentrations in the study areas, pre- and post-remediation wipe samples were consistently below the USEPA guidance value of 10 µg/100 cm2. Based on those results, surface exposure through ingestion or dermal contact with PCB-laden dust has not been identified as a concern and current housekeeping/cleaning methods employed by the schools adequately address this issue. Therefore, future pre- and post-remediation low and high contact surface wipe sampling should be discontinued. Airborne PCB concentrations within individual classrooms were typically variable from one sampling event to another. Airborne PCB concentrations also varied between Pilot Study areas during the same sample event. These results are consistent with the temporal and spatial variations associated with the behavior of air in building interiors.

• Aroclor 1254 was by far the most common contributor to the reported total PCB concentrations in air and wipe samples, with a much smaller portion being attributed to Aroclor 1248. No other Aroclors were identified in any of the air or wipe samples collected in the Pilot School Buildings.

• In all five (5) Pilot School Buildings the remedial methods studied (PCB Caulk encapsulation; PCB Caulk patch and repair; PCB Caulk removal and replacement; PCB Caulk window replacement; and PCB light ballast and light fixture removal and replacement) were effective in controlling airborne PCB concentrations. An additional cleaning of areas following replacement of windows has been recommended.

• There was not a statistically significant change in airborne PCB concentrations between pre- and post-remedial air sample results at the four (4) Pilot School Buildings in locations where interior PCB Caulk remediation was performed in the summer, 2011. Additional air monitoring beyond




the scope of the Pilot Study would be required to determine whether or not there is a significant reduction in airborne PCB concentrations over time that results from the PCB mass removal and control afforded by the remedial measures.

• Mean airborne PCB concentrations in Transitory Areas appear greater than in Primary Exposure Areas within P.S. 199M, P.S. 3R, and P.S. 183Q for the 2011 Pilot Study, which may be due to the general absence of exhaust ventilation in hallways and stairwells.

• At P.S. 183Q, an additional, detailed, and fine cleaning of the physical spaces subject to the window removal and replacement work by a qualified environmental contractor resulted in subsequent air sampling results meeting the applicable acceptance criteria. Future window replacement project procedures should be modified to incorporate such a detailed and fine cleaning following the replacement work and prior to re-occupancy.

• As reported in the IRIR, removal and replacement of the PCB light ballasts and associated fixtures had the most pronounced effect in terms of lowering PCB levels in air in the three Pilot School Buildings in which more than one remedy was implemented (i.e., P.S. 199M, P.S. 178X/176 and P.S. 309K). The primary source of airborne PCB in these schools appears to have been leaking light fixture ballasts, rather than caulk. In PS. 199M, other non-ballast and non-caulk PCB sources appear to be contributing factors as well. In P.S. 3R, concentrations in air were on average lower in Primary Exposure Areas following light fixture removal; however the difference was not statistically significant.

• The mean airborne PCB concentrations at P.S. 199M were significantly reduced after the light ballast removal and replacement in 2010, and were below the USEPA guidance values during the 2011 winter sampling. However, airborne PCB concentrations were found to be elevated in several spaces prior to and after removal and replacement of all identified PCB Caulk during the summer, 2011. This suggests one or more other contributing sources of PCBs are likely present at this school.

• To continue to reduce PCB air concentrations in P.S. 199M, activated carbon air filtration units are currently operating in all occupied spaces (i.e., classrooms, offices, library, cafeteria, and gymnasium). Carbon filtration has been effective at reducing airborne PCB concentrations, as the mean PCB concentration measured in air within the Primary Exposure Areas decreased significantly after implementing the on-going carbon filtration for approximately one (1) month. After two (2) months of operation, the mean PCB concentration in air was lower than the one-month results, but the difference was not statistically significant. In the case of both rounds of measurements, the mean PCB concentration was less than the guidance value for elementary-age rooms, with certain individual measurements exceeding guidance values.

• PCB-containing interior building materials, other than caulk and light ballasts, were identified in P.S. 199M and P.S. 309K. The relative degree to which these other building materials contribute to the airborne PCB concentrations measured in the air is inconclusive, as an evaluation of the data from both schools did not indicate a positive correlation between the quantity of other, specific PCB-containing materials in the various classrooms and the total airborne PCB concentration measured within those same classrooms. However, comparison of representative normalized Relative Source Strength between P.S. 199M and P.S. 309K indicate that the average RSS of major surface area materials at P.S. 199M was more than double the average RSS at P.S. 309K.




• Evaluation indicates that the total normalized Relative Source Strength of PCB-containing materials for the select rooms at P.S. 199M ranged from 0.373 to 1.385, with an average of 1.107. The total normalized RSS for comparable select classrooms at P.S. 309K ranged from 0.199 to 0.621, with an average of 0.419. Although no correlation between the RSS and airborne PCB concentration in either school was identified, the higher normalized RSS in P.S. 199M as compared to P.S 309K, which is similar to P.S. 199M in both construction type and date, as well as ventilation configuration, suggests that the other interior PCB-containing materials may be contributing to the higher mean airborne PCB concentration associated with post-remediation samples at P.S. 199M.

• Based on a review of the results of soil sampling efforts in 2010 and 2011, varying areas of soil contamination were identified at all five Pilot School Buildings studied. With the exception of one (1) sample location at P.S. 3R, the row-by-row methodology that SCA currently utilizes for soil evaluations outside the Pilot Study would have resulted in the same contaminated soil delineation with less data collection than was required for the remedial investigations. The distance from the building face to which soil contamination extended was typically limited to eight feet. Soil contamination encountered at P.S. 199M, P.S. 178X/176 and P.S. 309K was successfully mitigated through the process of delineation, excavation, and off-site disposal. Soil contamination at P.S. 3R and P.S. 183Q has been isolated pending implementation of soil excavation and disposal.

• With the exception of P.S. 309K, PCB Caulk was identified on the building exterior of each of the Pilot School Buildings. Survey inspections indicated that the existing PCB Caulk was most often not deteriorated or damaged; therefore, it is unclear as to the extent existing PCB Caulk has contributed to PCBs present in surface soils. PCB Caulk impacted by historical construction projects prior to the use of current PCB Caulk containment and removal procedures is thought to represent a primary source of the PCBs encountered in soil rather than release from existing PCB Caulk.

• Evaluation of multiple rounds of wide-scale testing data at P.S. 199M suggests a positive relationship between indoor air PCB concentration at P.S. 199M and both indoor and outdoor temperature. In addition, school-wide mean airborne PCB concentrations at P.S. 199M are higher in the warmer summer months, when school is generally not in session and lower in cooler fall and winter months, when school is in session. In addition, on a floor-by-floor basis, mean PCB air concentrations in classrooms were highest on the third floor and lowest on the first floor. The correlation of indoor air PCB concentration and temperature could not be evaluated at other Pilot School Buildings due to the low numbers of temperature data.

• Based on a simple trend analysis of the data, no correlation was identified between measured air exchange rates and airborne PCB concentrations at P.S. 199M.

• An evaluation of the ventilation systems at P.S. 199M and P.S. 309K indicated that designed and measured ventilation rates were variable between classrooms. At P.S. 199M, short circuiting of make-up air may be the result of incomplete air mixing within rooms explaining the higher calculated exchange rates relative to the tracer gas-measured air exchange rates. With one or two windows partially opened, measured air exchange rates at P.S. 199M increased by an average of up to 78%. This same phenomenon, although not actually observed, may also occur at P.S. 309K based on room configurations similar to those at P.S. 199M.




On the basis of the work performed and summarized in the Interim Remedial Investigation Report and this Final Remedial Investigation Report (RIR), the following proposed supplemental actions are recommended:

(1) Supplemental Actions Related to P.S. 199M

- Evaluate indoor air temperature trends by recording and evaluating indoor air temperature on multiple floors over several weeks. For future air sampling events, data log temperature in representative areas throughout each sampling event.

- Encapsulate other PCB-containing materials within a representative number of interior spaces and conduct a minimum of two rounds of air sampling and analysis in these same spaces, following encapsulation, to evaluate the impact, if any, on the concentration of PCBs in air.

- Perform an airborne pollutant pathway study in representative interior spaces to evaluate the potential migration and distribution of contaminants in air from floor to floor.

(2) Supplemental Actions Related to P.S. 178X/176

- Other than implementing the long-term monitoring program, no further post-pilot investigation or remediation actions are recommended at this time.

(3) Supplemental Actions Related to P.S. 309K

- Due to the relatively low air exhaust rates measured in specific areas at P.S. 309K, engage a heating and ventilation contractor to identify and implement appropriate repairs to the existing ventilation systems.

(4) Supplemental Actions Related to P.S. 183Q

- Continue to isolate surface soil documented to contain PCB concentrations above 1 ppm as an interim measure pending implementation of soil excavation and disposal. A construction fence associated with a capital improvement project is currently in place. When construction is completed and the construction fence is removed, cover the contaminated soil areas with geotextile fabric and a 3” to 4” top layer of cedar mulch and maintain it. Encapsulate exterior PCB Caulk in areas immediately adjacent to soils to be remediated in accordance with the SCA’s commitment to USEPA prior to soil remediation. Remediate soils above 1 ppm by excavation and off-site disposal, and obtain confirmatory post-excavation soil results. Backfill with clean fill and reestablish surface features.

- Remove and replace ballasts and light fixtures as part of the on-going light fixture replacement program due to evidence of historic ballast leakage.

(5) Supplemental Actions Related to P.S. 3R

- Continue to isolate surface soil documented to contain PCB concentrations above 1 ppm as an interim measure pending implementation of soil excavation and disposal. Maintain the existing geotextile fabric and cedar mulch. Encapsulate exterior PCB Caulk in areas immediately adjacent to soils to be remediated in accordance with the SCA’s commitment to USEPA prior to soil remediation. Remediate soils above 1 ppm by excavation and off-site




disposal, and obtain confirmatory post-excavation soil results. Backfill with clean fill and reestablish surface features.

(6) Supplemental Actions Related to All Pilot School Buildings

- Implement bulk and wipe sampling as defined in the USEPA-approved Long Term Monitoring Plan.

- Report results of additional Pilot Study related efforts to USEPA by Supplemental Reports to this RIR which shall be submitted to USEPA not later than June 15, 2012.




2.0 DESCRIPTION OF THE REMEDIAL ALTERNATIVES

2.1 Introduction

The goal of the Feasibility Study is to assess the various remedial alternatives studied thus far in the five Pilot School Buildings. The evaluation of remedial actions undertaken in Section 3.0 will ultimately assist in identifying a pilot preferred remedy or remedies for PCB Caulk and PCB ballasts in Pilot School Buildings. The FS contains an analysis of remedial alternatives in terms of methods and products utilized, affects of remedial actions on post-remediation PCB concentrations, reducing human exposure to PCB sources, short-term and long-term effectiveness, cost, labor requirements, length of implementation, potential to disrupt normal school activities, and other relevant factors. The following are the remedial alternatives evaluated, in consultation with USEPA, for this FS:

• Patch and repair of PCB Caulk (i.e., remove loose and deteriorating PCB Caulk and replace with new non PCB-containing caulk) and annual bulk sampling of new caulk for a period of five (5) years;

• Encapsulation of PCB Caulk and annual wipe sampling of the new sealant for a period of five years;

• Removal of all PCB Caulk and replacement with new non PCB-containing caulk, and annual bulk sampling of new caulk for a period of five years;

• Removal and replacement of window systems and removing all associated PCB Caulk and replacing with new, non PCB-containing caulk;

• Best management practices (i.e., use pre-remedial baseline sampling data to evaluate the effectiveness of current operation and maintenance practices); and,

• Removal and replacement of PCB light ballasts and fixtures. 2.2 Remedial Objectives

The objective of the remediation is to adequately control levels of PCBs in primary, transitory and outside exposure areas (i.e., soil within ten feet of the building façade) of the school environment. The overall goal of the remedial efforts is to reduce and maintain surface and air PCB concentrations below all applicable comparison criteria, as discussed in Section 1.2.4. 2.3 General Scope of Response Actions

This evaluation of the remedial alternatives relies on the information pertaining to the nature, extent and distribution of PCB Caulk, in particular, and PCBs, in general, generated thus far in the course of the implementation of the Pilot Study at the five Pilot School Buildings. 2.4 Description of Individual Remedial Alternatives Evaluated

The six remedial alternatives implemented in the Pilot Study Areas in the five Pilot School Buildings will be evaluated for purposes of this FS. A description of each of these remedial alternatives is provided below.




2.4.1 Patch and Repair of All Damaged and Deteriorated PCB Caulk

Patch and repair of PCB Caulk consisted of removing any significantly damaged and deteriorated caulk and replacing the removed caulk with new, non PCB-containing caulk in the Pilot Study Areas within one Pilot School Building. This remedial strategy evaluated the use of two dust control scenarios. Both the PCB and asbestos containing material dust control methods were deemed to be effective in controlling dust with PCBs. Therefore, unless asbestos containing materials are present, dust controls implemented in accordance with the Remedial Investigation Plan Dust Control (Appendix I) are adequate. 2.4.2 Encapsulation of All PCB Caulk

The encapsulant product utilized during the summer 2010 Pilot Study at P.S. 309K was Macropoxy 646 Fast Cure Epoxy and Sealant manufactured by Sherwin Williams. Due to the cracking observed within the Macropoxy 646 encapsulant, two alternative commercially available encapsulant products were utilized for purposes of the whole-school remedy during the summer of 2011 (i.e., Series-151-1051 Elasto-Grip FC manufactured by TNEMEC and Sikagard® 550W manufactured by Sika Corporation). The Elasto-Grip product was generally applied in the western half of the school, while the Sikagard® product was applied in the eastern half of the school. The encapsulant was applied to PCB Caulk in accordance with manufacturers’ recommendations and the SCA’s specifications. In order to separate the effectiveness of encapsulation and patch and repair alternatives, areas of significantly deteriorated and/or loose PCB Caulk were removed and replaced in accordance with procedures described above in the patch and repair remedial alternative prior to encapsulation, because loose caulk does not provide a suitable foundation for encapsulation. Patch and repair, with dust control measures consistent with Appendix B of the RI Plan, was performed as required in areas of significantly deteriorated and/or loose caulk prior to encapsulation. 2.4.3 Removal of All PCB Caulk and Replacement with New Caulk

Removal of all PCB Caulk consisted of removing all visible and accessible PCB Caulk and replacing the removed caulk with new, non PCB-containing caulk in the school building. Removal of all PCB Caulk was accomplished utilizing manual tools to mitigate dust creation. This remedial strategy evaluated the use of two dust control scenarios. Both the PCB and asbestos containing material dust control methods were deemed to be effective in controlling dust with PCBs. Therefore, unless asbestos containing materials are present, dust controls implemented in accordance with the Remedial Investigation Plan Dust Control (Appendix I) are deemed to be adequate. 2.4.4 Window Removal and Replacement

The window replacement project within one Pilot School Building (P.S. 183Q), which included the removal of PCB and ACM Caulk associated with window frames and window openings, was conducted utilizing ACM dust control procedures.

The window locations and contiguous spaces within a radius of 10 feet were demarcated with caution tape as regulated areas to allow only certified workers and authorized visitors to enter. A remote worker and waste decontamination unit was constructed outside the work area. The contractor personnel donned personal protective equipment (PPE) and prepared the work areas. The movable and loose items from the work areas were cleaned using HEPA vacuum equipment and removed in the work areas. Fixed objects within the work areas were pre-cleaned using HEPA vacuum equipment and enclosed with a minimum of two layers of 6-mil, polyethylene sheeting sealed airtight with tape. The contractor then installed two




layers of polyethylene sheeting around the window frames and caulking, sealing it to form an airtight barrier between the window and caulking and the interior of the building. The contractor then constructed modified tents exterior to the building, fully framed with 2” x 3” wood studs, sufficient in size to effectively manage the large size of the window frames. The tents were enclosed with two layers of polyethylene sheeting inside and around the window frames and caulking, sealing them to form an airtight barrier between the window and caulking and the exterior of the building. An airlock between the two curtained doorways was constructed at the entrance to each tent. The window frame removal commenced after the tent enclosures successfully passed a pre-removal inspection.

The window frames were removed using wet methods, wrapped in two layers of six mil polyethylene sheeting, and removed from the tent. The window openings were then thoroughly cleaned using hand tools with any residual caulk waste being directly bagged. The surfaces of the work area were rendered free of visible debris.

Final asbestos air sampling conducted inside the work areas indicated that acceptance criteria for re-occupancy were achieved in each work area prior to removal of containment.

2.4.5 Removal and Replacement of PCB Light Ballasts and Fixtures

Removal and replacement of fluorescent light fixtures and ballasts was performed in Pilot Study Areas within one Pilot School Building (P.S. 3R). The furniture and all other movable items were either removed from each room or moved to the side. The contractor then installed three (3) polyethylene sheeting flaps on each doorway and sealed all openings/penetrations in the work area including exhaust and supply ventilation system vents. Electrical power to the light fixtures was de-energized. The fixed objects within the work area were enclosed with a minimum of one layer of 6-mil polyethylene sheeting sealed airtight with tape. The contractor then installed six-mil polyethylene sheeting on the floor directly beneath the light fixture(s) and extending approximately five (5) feet in all directions. Non-movable objects within this five foot area were covered with one layer of sheeting.

The contractor workers, wearing PPE, removed the lamp cover or grille from each light fixture exposing the fluorescent lamps. The fluorescent lamps were removed and the ballast enclosure cover was then removed exposing the ballasts. The exterior of the ballast and the interior exposed section of the light fixture including housing (with ballast removed), cover and wires were visually inspected for evidence of any leakage or staining.

If leaking or staining was identified on the ballast and/or light fixture, the ballast was removed and placed directly in the authorized waste container (leaking PCB ballast drum), and the light fixture was wrapped in two layers of clear six-mil, polyethylene sheeting, placed in waste container and disposed of as PCB remediation waste.

If no leaking or staining was identified on the ballast or light fixture, the ballast was removed and placed directly in the authorized waste container (non-leaking PCB ballast drum), and the light fixture was wrapped in two layers of clear six-mil polyethylene sheeting, placed in waste container and disposed of as ACM waste. 2.4.6 Best Management Practices

The currently proposed best management practices (BMP) activities in the schools for managing undisturbed PCB Caulk are presented in the BMP protocol (see Appendix E). The protocol includes measures and practices to be used to protect PCB Caulk from accidental damage and to identify the potential for deterioration requiring further action on an ongoing basis during school maintenance, repair




and renovation. The BMPs are being modified to include the currently proposed remediation of deteriorated PCB Caulk by patch and repair, remove and replace, or encapsulation remedies. 2.4.7 Remediation of Surface Soils in Outside Exposure Areas

In addition to the remedial alternatives described above to address interior PCBs, any soil within ten feet of the building containing PCBs at a concentration of greater than 1 ppm were or will be the subject of remediation. In accordance with 40 CFR 761.61, the permanent remedy to address soil exposure includes soil excavation in all areas where PCB concentrations are greater than 1 ppm in the surface soil. After removing impacted soil, the excavation is then backfilled using clean fill with a PCB concentration no greater than 1 ppm. Each of the six interior remedial alternatives and the outside exposure area remedy are individually evaluated in Section 3.0 below.




3.0 COST ANALYSIS OF PILOT STUDY REMEDIAL ALTERNATIVES

This section presents an analysis of the costs associated with the implementation of the remedial alternatives presented in Section 2.4 above. The reported costs typically represent the contractor’s costs for the labor, materials and equipment associated with implementing the various remedial alternatives in the Pilot School Buildings. Costs associated with the implementation of the Pilot Study such as consulting oversight, surveys, investigations, laboratory analysis and reporting are not included in the cost analysis, as these efforts would often not be required for actual future remediation projects. In addition, to the extent required, the magnitude of such costs would be expected to be fairly consistent across the remedies and relatively low as compared to the contractor’s costs (which are captured). In several of the Pilot School Buildings, additional post-pilot remedial efforts were undertaken in response to the Pilot Study post-remedial air sampling results as summarized in the sections below. Costs for these post-pilot remedial efforts are presented, to the extent cost information was available and the efforts are consistent with one of the remedial alternatives. While light ballast and fixture removal and replacement occurred in a total of four Pilot School Buildings, in three of the schools (P.S. 199M, P.S. 178X and P.S. 309K) this work pre-dated the inclusion of this remedial alternative into the Pilot Study. Therefore, the cost analysis for the light ballast and fixture removal and replacement remedial alternative includes only the P.S. 3R Pilot Study work which is believed to be representative of this type of work. 3.1 Cost Analysis of Patch and Repair Remedy

3.1.1 Description of Work Performed

The initial Pilot Study work performed at P.S. 178X/176 involved evaluating the patch and repair remedial alternative. This approach involved removing any loose or significantly deteriorated caulk containing PCBs and replacing the removed caulk with new, non PCB-containing caulk. The 2010 remedial activity evaluated the use of two different dust control methods. The first method instituted asbestos abatement-type dust controls which were used on the 3rd floor classrooms as well as the Lobby (Room 103). For the remainder of the Pilot Study Areas in P.S. 178X/176, on the first and second floors, dust control methods in accordance with Appendix I were used. For the work performed in 2010, a total of 213 linear feet of interior caulk was remediated from the following locations at P.S. 178X/176:

Table 3.1 –List of 2010 Remediated Areas: PCB Caulk Patch and Repair for P.S. 178X/176

Bulk Material Description Floor Room/ Location Total Quantity

Remediated (linear feet)

Door window glaze – silver 1 103 - Lobby 2

Window frame caulk – brown 1 139 27










Window sill caulk – brown 2 258 22


Window sill caulk – brown 3 322A 21

Window frame caulk – brown 3 337A 14

Window sill caulk – brown 3 357 18 For the work performed in 2011, a total of 397 linear feet of interior caulk was remediated from the following locations at P.S. 178X/176:




Air handler caulk – gray* Basement Boiler room 40

Window frame caulk - brown 1 108 37

Ceiling caulk – white* 1 110 18

Ceiling caulk – white* 1 118 12

Display case glaze – gray* 1 121 – SE Lobby 11

Rolling gate case caulk - gray 1 Kitchen 6




Display case glaze – gray* 1 147 6

Ceiling caulk – white* 1 150 – MER 56

Ceiling caulk – white* 1 154 – Foyer 18

Display case glaze – gray* 1 164 – NW Lobby 13












Window frame caulk - brown 3 322B 10



Window sill caulk – brown 3 358 5 During the work performed in 2010 and 2011, there were some cases where the amount of loose or significantly deteriorated caulk was less than approximately ten percent (10%) of the total linear footage of each homogenous PCB Caulk identified; therefore, “sound” PCB Caulk was removed and replaced to achieve a minimum of approximately ten percent (10%) by linear footage of PCB Caulk subject to this remedial alternative. In addition to interior areas remediated by Air Tech Lab, Inc., in July, 2011, a total of approximately 1,030 linear feet of exterior PCB-containing window caulk and 2,180 linear feet of PCB-containing masonry caulk on the north and south sides of the building exterior were encapsulated. On each side of the building the contractor, Air Tech Lab, Inc., divided the work zones into equal size areas. In each area the contractor applied one of two different commercially available encapsulant products. Prior to encapsulation, the PCB caulk surfaces were wet cleaned, using water, and any damaged or loose caulk was removed and replaced with non PCB-containing caulk (Sikasil-C995, manufactured by Sika). Caulking on the northeast and southeast areas was encapsulated with a base coat of Elasto-Grip FC and a finish coat of Enviro-Crete® 156, manufactured by TNEMEC, while the caulking on the northwest and southwest areas was encapsulated with Sikagard®-62 two-part epoxy protective coating, manufactured by Sika. 3.1.2 Labor

For the initial phase of patch and repair work in the Pilot Study areas which was performed from July 19 to July 25, 2010, the SCA’s contractor, KISS Construction, had an average of 13 handlers and one supervisor working per day based on the Contractor’s total number of hours broken down by the number of days worked and number of hours worked per day. The total time spent on the project was 759 man hours, with 94 of those hours as overtime. The cost of labor for this period totaled $54,400.14. The contractor labor costs are associated only with the implementation of the remedial alternative and do not include contractor labor costs for post-pilot remedial activities such as supplemental cleaning or replacing light fixtures with leaking ballasts. For the subsequent phase of patch and repair work and exterior caulk encapsulation for the whole school which occurred from July 5 to August 2, 2011, the SCA’s contractor, Air Tech Labs, had an average of 7 handlers and one supervisor working per day. A total of 1,886.5 man hours were spent on the project. The cost of labor for this period totaled $142,486.42. Based on TRC field notes, an estimated 652 labor hours were associated with the exterior caulk encapsulation work and the remaining 1,234.5 labor hours were associated with the interior patch and repair work. The labor costs associated with the exterior caulk encapsulation work was $49,409.16 and labor costs associated with the interior patch and repair work was $93,077.26.




3.1.3 Transportation and Disposal

Brookside Environmental provided the disposal services for waste contaminated with PCBs for the initial phase of work conducted from July 19 to July 25, 2010. A roll-off container was rented and mobilized to the school. Twenty cubic yards of presumed TSCA and New York State hazardous PCB waste were placed in the roll-off container and transported and disposed at Wayne Disposal Inc. in Belleville, Michigan, a Hazardous Waste disposal site. The total cost for the transportation and disposal of the PCB waste before the contractor markup was $7,985.

Clean Venture/Cycle Chem provided the disposal services for waste contaminated with PCB waste for the subsequent phase of work conducted from July 5 to August 2, 2011. Ninety-five cubic yards of presumed TSCA and New York State hazardous PCB waste in roll-offs were sent to Wayne Disposal Inc. in Belleville, Michigan for proper disposal. The total cost associated with the transportation and disposal of this waste was approximately $43,400. Two, fifty-five gallon drums of PCB-contaminated caulk and one drum of PCB- and ACM-contaminated caulk were transported and disposed of at a cost of $1,400. Three, fifty-five gallon drums of PCB-contaminated water were disposed of at Veolia- Port Arthur, Texas via Cycle Chem, Inc., a permitted TSDF. The transportation and disposal cost of these drums of water was $3,800. The total cost for the transportation and disposal of the PCB waste was approximately $48,600. Approximately $43,000 of the total was related to the interior caulk patch and repair, and $5,600 was related to the exterior caulk encapsulation. 3.1.4 Summary of Contractor Costs

Markups applied by Kiss Construction for the initial phase of work were based on percentages of regular time labor, waste transport and disposal and materials and equipment. The total cost of the project in 2010 was $73,848.66.

Markups applied by Air Tech Labs for the subsequent work were based on percentages of regular time labor, waste transport and disposal and materials and equipment. The total cost of the project in 2011 was $225,387.50. The interior patch and repair work totaled $153,263.50 (approximately 68% of the total) and the exterior encapsulation work totaled $72,124.00 (approximately 32% of the total). The exterior encapsulation costs included the exterior boom rental and the purchase of a power washer as well as five percent (5%) of the total disposal costs and ten percent (10%) of the transportation cost as these were not separated out in the contractor invoice. 3.1.5 Amount of PCB Caulk Remediated

The quantities of PCB Caulk remediated were based on the Pilot Study Area Caulk Survey results which gave the approximate dimensions of PCB Caulk that was remediated at P.S. 178X/176. The amount of caulk remediated was based on classrooms where survey and sampling indicated the presence of deteriorated PCB Caulks. For P.S. 178X/176, a total of 213 linear feet of caulk was physically remediated by patch and repair during the initial phase of work in 2010. A total of 397 linear feet of interior caulk and 3,210 linear feet of exterior caulk were remediated by patch and repair and encapsulation, respectively during the subsequent phase of work in 2011.

3.1.6 Cost to Remediate PCB Caulk

The cost to perform the remediation at P.S. 178X/176 is presented on a linear foot basis. The price per foot of caulk remediated was determined by taking the total cost of the work and dividing it by the total quantity of linear feet remediated. The result was a cost of approximately $347 per linear foot of caulk




for the initial phase of work. An approximate cost of $386 per linear foot of caulk was the result during the subsequent phase of work for the whole school. The resultant cost per linear foot of caulk for both phases of work is approximately $372 per linear foot. The resultant cost for the exterior encapsulation was $22 per linear foot. Refer to the P.S. 178X/176 Pilot Study Remedial Alternative Cost Analyses in Appendix F for a breakdown of the amount of PCB Caulk remediated and the costs.

3.2 Cost Analysis of Removal and Replacement Remedy


The Pilot Study work performed at P.S. 199M involved evaluating the removal and replacement remedial alternative. Removal of PCB Caulk involved removing all visible and accessible PCB Caulk and replacing the removed caulk with new, non PCB-containing caulk. Removal of all PCB Caulk was accomplished utilizing manual tools and methods. For the work performed in 2010, a total of 1,090 linear feet of interior caulk was remediated from the following locations at P.S. 199M: Primary Exposure Areas • Classroom Areas

- Rooms 116 and 118 – 1st Floor - Room 202 – 2nd Floor - Rooms 308, 316, 318, 320, 328 – 3rd Floor - Cafeteria – 1st Floor - Gym – 2nd Floor -

Transitory Areas • Main Entrance Stairwell – 2nd Floor • North Corridor – 3rd Floor For the work performed in 2011, a total of 1,986 linear feet of interior caulk was remediated from the following locations at P.S. 199M:

Table 3.3 - List of 2011 Remediated Areas: PCB Caulk Removal and Replacement with New Caulk for P.S. 199M



Door frame caulk – gray 1 113 – Slop Sink 14

Door frame caulk - white 1 Kitchen 28

Door frame caulk – gray

1 North Corridor

182

Gate runner caulk – gray 32

Metal panel caulk above fire extinguisher 8


1 South Corridor

196






Table 3.3 - List of 2011 Remediated Areas: PCB Caulk Removal and Replacement with New Caulk for P.S. 199M



Door frame caulk – gray 1 East Corridor 84

Door frame caulk – gray 1 West Corridor 95

Door frame caulk – gray 1 Exit 4

90

Transom window glaze - gray 72

Door frame caulk – gray 1 Stairwell B 70

Door frame caulk – gray 1 Stairwell C 56

Door frame caulk – beige 2 235 - Bathroom 8

Gym rolling gate caulk - gray 2 Storage Room 14


2 North Corridor

174




2 South Corridor

252




Door frame caulk – gray 2 West Corridor

56



Door frame caulk – gray 2 Stairwell C 28

Door frame caulk – gray 3 South Corridor

213




Door frame caulk – gray 3 Stairwell C 28 In addition, bulk sampling of exterior caulk in locations where soils were found with PCB levels exceeding 1 ppm indicated the presence of door, louver and masonry caulk in certain locations containing PCBs greater than 50ppm. As a result, the door and louver caulk was removed and replaced, and masonry caulk on the south side of the building was encapsulated, in April of 2011 prior to implementation of soil remedial activities. In all, a total of approximately 607 linear feet of caulking around 26 doors and 4 louvers was removed. During the same time period, approximately 1,685 linear feet of PCB-containing masonry caulk on the south side of the building was encapsulated.




3.2.2 Labor

For the initial phase of work in the Pilot Study areas which occurred from July 21 to July 31, 2010, the SCA’s contractor, KISS Construction, had an average of 15 handlers and one supervisor working per day based on TRC field notes. The total time spent on the project was 1,147 man hours, with 80 of those hours as overtime. The cost of labor for this period totaled $80,814.26.

For the subsequent phase of work for the whole school which occurred from July 5 to July 28, 2011, the SCA’s contractor, KISS Construction, had an average of 35 handlers and one supervisor working per day. The total time spent on the interior removal and replacement work was 3,862 man hours, with 233 of those hours as overtime. The cost of labor for this work totaled $291,541.08. An estimated 584 labor hours were associated with the exterior caulk encapsulation work. The labor costs associated with the exterior caulk encapsulation work was $43,419.20. 3.2.3 Transportation and Disposal

Brookside Environmental provided the disposal services for waste contaminated with PCBs for the initial phase of work conducted from July 21 to July 31, 2010. Forty cubic yards of presumed TSCA and New York State hazardous PCB waste were sent in roll-offs to Wayne Disposal Inc. in Belleville, Michigan for proper disposal. The resulting total cost for the transportation and disposal of PCB Remediation Waste before the contractor markup was $15,035.

Brookside Environmental again provided the disposal services of the presumed TSCA and New York State hazardous PCB waste from the subsequent phase of the interior caulk removal and replacement work conducted from July 5 to July 28, 2011. A total of sixty cubic yards of PCB Remediation Waste were sent in a roll-off to Wayne Disposal Inc. in Belleville, Michigan for proper disposal. One drum of PCB and lead contaminated caulk, at a rate of $785 per drum, was disposed of at Veolia - Port Arthur, Texas via Veolia’s permitted TSDF in Flanders, New Jersey. The resulting total cost for the transportation and disposal of PCB waste before the contractor markup was approximately $20,065. Brookside Environmental also provided the disposal services for the presumed TSCA and New York State hazardous PCB waste associated with the exterior caulk encapsulation work performed in 2011. Thirty cubic yards of PCB Remediation Waste were sent in a roll-off to Wayne Disposal Inc. in Belleville, Michigan for proper disposal. One drum of PCB and lead contaminated caulk was disposed of at Veolia - Port Arthur, Texas via Veolia’s permitted TSDF in Flanders, New Jersey. The resulting total cost for the transportation and disposal of PCB waste with the contractor markup was approximately $12,344. 3.2.4 Summary of Contractor Costs

Markups applied by KISS Construction for the initial phase of work were based on percentages of regular time labor, waste transport and disposal and materials and equipment. The total cost of the project in 2010 was $119,499.53.

KISS Construction performed exterior caulk removal and encapsulation activities in April, 2011. The total cost for this phase of work was $67,408.02.

Markups applied by KISS Construction for the subsequent phase of work were also based on percentages of regular time labor, waste transport and disposal and materials and equipment. The total cost of the project, not including the purchase or operation of the activated carbon air filtration systems, was $411,137.07 for the July, 2011, work.




3.2.5 Amount of PCB Caulk Remediated

The quantities of PCB Caulk remediated were based on the Pilot Study Area Caulk Survey results which provided the approximate dimensions of PCB caulk that was remediated at P.S. 199M. For P.S. 199M, a total of 1,090 linear feet of caulk was remediated during the initial phase of work in 2010. A total of 2,292 linear feet of exterior caulk and 1,986 linear feet of interior caulk were remediated during the subsequent phase of work in 2011. 3.2.6 Cost to Remediate PCB Caulk

The cost to perform the remediation at P.S. 199M is presented on a linear foot basis. The price per foot of caulk remediated was determined by taking the total cost of the project and dividing it by the total quantity of linear feet remediated. The result is an approximate cost of $110 per foot of caulk for the initial phase of work. An approximate cost of $207 per linear foot of caulk was the result during the subsequent phase of work for the whole school. The resultant cost per linear foot of caulk for both phases of work is approximately $172. The resultant cost for the exterior encapsulation was $29 per linear foot. Refer to the P.S. 199M Pilot Study Remedial Alternative Cost Analyses in Appendix F for a breakdown of the amount of PCB Caulk remediated and the costs. 3.3 Cost Analysis of Encapsulation Remedy


The Pilot Study work performed at P.S. 309K involved evaluating the encapsulation remedial alternative. This approach involves the use of a commercially available encapsulant that acts as a barrier or coating to prevent dust generation and dermal contact with PCB-containing caulk. For the work performed in 2010, a total of 1,056 linear feet of interior caulk was remediated from the following locations at P.S. 309K:

Table 3.4 – List of 2010 Remediated Areas: PCB Caulk Encapsulation for P.S. 309K

Bulk Material Description Floor Room / Location Total Quantity


Electrical penetration caulk – brown/red 1 116

1

Sink caulk – beige 8

Sink caulk – beige 1 147 8

Door frame caulk – grey

1 West Corridor

98

Door frame caulk – white 56

Marble drinking fountain caulk – grey 1

Display case caulk – grey 22

Green marble wall joint caulk – beige 6

Former gate runner caulk – beige 31







Metal door window glaze – beige

1 Cafeteria

3

Door frame caulk – grey 154

Metal door window glaze – beige 20

Bay door frame caulk – grey 13

Column/wall seam caulk – grey 71

Heat vent caulk – beige 1 Gymnasium

2

Bay door frame caulk – grey 70

Electrical penetration caulk – brown/red

2 207

1

Water fountain caulk – beige 6


Sink caulk – beige 2 Library - 211

8

Electrical penetration caulk – brown/red 1

Electrical penetration caulk – brown/red 2 220

1


Electrical penetration caulk – brown/red

3 300

1

Sink caulk – white 8

Sink caulk – white 9

Access panel caulk – white 3 312

7


Door frame caulk – beige

All North Stairwell

70

Door window glaze caulk – beige 110

Ceiling joint caulk – grey 120

Door frame caulk – dark grey 44

Door frame caulk – brown/red 88





For the work performed in 2011, a total of 2,502 linear feet of interior caulk was remediated from the following locations at P.S. 309K:




Door frame caulk – brown Basement Vestibule 2 18

Door frame caulk – red/brown 1 141/143 Vestibule 23

Door frame caulk – red/brown 1 145/147 Vestibule 23

Door frame caulk – red/brown 1 Kitchen Exit Vestibule

22

Door frame caulk – gray 42

Door frame caulk – red/brown 1 South Exit Lobby E

31

Door frame caulk – gray 25



Door frame caulk – gray 1 North Auditorium Hallway 42

Door frame caulk – gray 1 South Auditorium Hallway 70

Door frame caulk – gray 1 North Corridor 420

Column/Wall seam caulk – gray 1 Cafeteria 71


Door frame caulk – gray 2 Center Corridor 224




Door frame caulk – gray 3 Corridor 738

Door frame caulk – gray All West Stairwell

42

Door frame caulk – red/brown 18

Door frame caulk – gray All East Stairwell

42

Door frame caulk – red/brown 63




3.3.2 Labor

During the initial phase of work in the Pilot Study areas, which occurred from July 26 to July 30, 2010, the SCA’s contractor, KISS Construction, had an average of 13 handlers and one supervisor working per day based on TRC field notes. A total of 601 man hours were spent on the project. The cost of labor for this period totaled $41,328.14.

For the subsequent phase of work for the whole school, which occurred from July 5 to July 26, 2011, the SCA’s contractor, ABC, had an average of 9 handlers and one supervisor working per day. The total time spent on the project was 1,306.5 man hours, with none of those hours as overtime. The cost of labor for this period totaled $103,726.30. 3.3.3 Transportation and Disposal

Brookside Environmental provided the disposal services for the presumed TSCA and New York State hazardous PCB waste from the initial phase of work in 2010. Twenty cubic yards of PCB Remediation Waste were sent in a roll-off to Wayne Disposal Inc. in Belleville, Michigan for proper disposal. The resulting cost for the transportation and disposal of PCB Remediation Waste before the contractor markup was approximately $8,090.

Clean Venture/Cycle Chem provided the disposal services of the presumed TSCA and New York State hazardous PCB waste from subsequent phase of work in 2011. Twenty cubic yards of PCB waste were sent in a roll-off to Wayne Disposal Inc. in Belleville, Michigan for proper disposal. Two, 55-gallon drums of PCB- and lead-contaminated caulk were sent to Veolia - Port Arthur, Texas via Cycle Chem Inc., a permitted TSDF, for proper disposal. The resulting total cost for the transportation and disposal of PCB Remediation Waste before the contractor markup was $13,546.03. 3.3.4 Summary of Contractor Costs

Markups applied by KISS Construction were based on percentages of regular time labor, waste transport and disposal and materials and equipment. The total cost of the project in 2010 was $57,168.40.

Markups applied by ABC were based on percentages of regular time labor, waste transport and disposal and materials and equipment. The total cost of the project in 2011 was $132,141.50. 3.3.5 Amount of PCB Caulk Remediated

The quantities of PCB Caulk remediated were based on the Pilot Study Area Caulk Survey results which gave the approximate dimensions of PCB Caulk that was remediated at P.S. 309K. For P.S. 309K, a total of 1,056 linear feet of caulk was remediated during the initial phase of work in 2010. A total of 2,502 linear feet of caulk was remediated during the subsequent phase of work in 2011.

3.3.6 Cost to Remediate PCB Caulk

The cost to perform the remediation at P.S. 309K is presented on a linear foot basis. The price per foot of caulk remediated was determined by taking the total cost of the project and dividing it by the total quantity of linear feet remediated. The result was a cost of approximately $54 per linear foot of caulk for the initial phase of work.

A cost of approximately $53 per linear foot of caulk was the result of the subsequent whole school work. The resultant cost per linear foot of caulk for both phases of work is about $53 per linear foot. Refer to




the P.S. 309K Pilot Study Remedial Alternative Cost Analyses in Appendix F for a breakdown of the amount of PCB Caulk remediated and the costs.

3.4 Cost Analysis of Window Removal and Replacement Remedy


The Pilot Study work performed at P.S. 183Q involved evaluating the removal of PCB Caulk associated with the window removal and replacement project. This approach involves the removal of the entire window system and associated PCB Caulk, the replacement of the window system and sealing with non PCB-containing caulk, and the fine and detailed cleaning of all workspaces by an environmental contractor prior to re-occupancy. The incremental costs for the associated capital improvement project including the purchase and installation of the replacement windows and scaffolding, for instance, are also captured in this analysis. 3.4.2 Labor

From July 1 to August 21, 2011, the SCA’s contractor, Rici Corp., had an average of eight handlers a day and one supervisor to perform the window and PCB Caulk removal work. The time spent on the window and caulk removal work was 2,160 man hours. The cost of labor for this period totaled $127,228.80. The time spent on fine and detailed cleaning performed by the environmental contractor, Kiss Construction, was 226.5 man hours. The total time spent on the project was 2,386.5 man hours. 3.4.3 Transportation and Disposal

Tri-State Transfer Assoc., Inc. provided the disposal services for the presumed TSCA and New York State hazardous PCB waste associated with this project, which included the old window systems. Thirty-three tons of PCB waste were sent in roll-offs to Waste Management-Emelle Treatment Facility in Emelle, Alabama for proper disposal. The resulting total cost for the transportation and disposal of PCB waste before the contractor markup was $35,854. 3.4.4 Summary of Contractor Costs

Markups applied by the contractor were based on percentages of regular time labor, waste transport and disposal and materials and equipment. The total cost to implement the remedial aspects of the alternative in 2011 was $209,492.19. The cost associated with the fine and detailed cleaning performed by the environmental contractor, Kiss Construction, was $30,475. In addition, costs for the purchase and installation of the replacement windows, scaffolding, and sidewalk shed, with a twenty percent (20%) allowance to reflect other incremental capital improvement costs such as design and administrative filing fees, totaled $990,000. Therefore, the total project cost to implement the work is estimated at $1,229,967. 3.4.5 Amount of PCB Caulk Remediated

The quantities of PCB Caulk remediated were based on the Pilot Study Area Caulk Survey results which provided the approximate dimensions of PCB caulk that was remediated at P.S. 183Q. For P.S. 183Q, a total of 12,629 linear feet of caulk was remediated. 3.4.6 Cost to Remediate PCB Caulk

The cost to perform the remediation at P.S. 183Q is presented on a linear foot basis. The price per foot of caulk remediated was determined by taking the total cost of the total project cost and dividing it by the




total quantity of linear feet of caulk remediated. The result was a cost of approximately $97 per linear foot of caulk. Refer to the P.S. 183Q Pilot Study Remedial Alternative Cost Analyses in Appendix F for a breakdown of the amount of PCB Caulk remediated and the costs.

3.5 Cost Analysis of Light Fixture Ballast Removal and Replacement Remedy


The Pilot Study work performed at P.S. 3R involved evaluating the light ballast and fixture removal and replacement remedial alternative. 3.5.2 Labor

From June 29 to July 20, 2011, the SCA’s contractor, Empire Control Abatement had an average of 18 handlers a day and one supervisor. The total time spent on the project was 3,020 man hours, of which 580 hours were overtime. The total cost of labor for this period was $190,662.03. 3.5.3 Transportation and Disposal

Tri-State Transfer Associates, Inc. and Brookside Environmental provided the disposal services for the presumed TSCA and New York State hazardous PCB waste from this work. Thirty cubic yards of PCB waste were sent in roll-offs to Wayne Disposal Inc. in Belleville, Michigan for proper disposal. In addition, thirty tons of PCB waste were sent to Waste Management-Emelle Treatment Facility in Emelle, Alabama for proper disposal. The resulting total cost for the transportation and disposal of PCB waste for the project, before the contractor markup, was $59,935. 3.5.4 Summary of Contractor Costs

Markups applied by the contractor were based on percentages of regular time labor, waste transport and disposal and materials and equipment. The total cost of the remedial aspects of the project in 2011 was $348,754.61. In addition, costs for the purchase and installation of the replacement light fixtures (including ballasts), with a twenty percent (20%) allowance to reflect other incremental capital improvement costs such as design and administrative filing fees, totaled $1,129,200. Therefore, the total project cost to implement the work is estimated at $1,477,955. 3.5.5 Number of PCB Light Ballasts/Fixtures Remediated

The quantities of PCB light fixtures and ballasts remediated were based on consultant summary reports from the field which provided the number of fixtures and ballasts removed at P.S. 3R. A total of 848 fixtures containing 927 ballasts were removed and replaced. 3.5.6 Cost to Remediate PCB Light Ballasts/Fixtures

The cost to perform the remediation at P.S. 3R is presented on a per fixture basis. The price per fixture removed was determined by taking the total cost of the project and dividing it by the total quantity of fixtures removed. The result is a cost of approximately $1,743 per fixture or $1,594 per ballast. Refer to the P.S. 3R Pilot Study Remedial Alternative Cost Analyses in Appendix F for a breakdown of the amount of PCB light ballasts remediated and the costs.




3.6 Cost to Remediate Outdoor Exposure Areas

3.6.1 P.S. 178X/176

Remediation of soils containing greater than 1 ppm of PCBs was performed at P.S. 178X/176 during the summer of 2011. Areas along the northern and southern façade of the building where previous sample results indicated PCB concentrations that exceeded 1 ppm were excavated. Soil areas were excavated to a depth of two (2) feet below ground surface (bgs). Post-excavation soil samples were collected and laboratory results, with the exception of one (1) sidewall sidewalk sample, indicated PCBs were less than 1 ppm. Additional excavation was conducted under the sidewalk surrounding the failed sidewall sidewalk sample. Excavated areas were backfilled with environmentally clean fill including sand and landscaped areas were restored using hydro-seed. According to the Louis Berger Associates (LBA) Polychlorinated Biphenyl Soil Remediation Report (PCB Report), dated October 17, 2011, the cost for the outside exposure areas, including soil remediation and landscaping, came to $128,000. LBA estimated that approximately 62 tons of soil was disposed of as non-hazardous PCB Remediation Waste and approximately 39 tons of soil was disposed of as Hazardous PCB Remediation Waste (greater than 50 ppm). The resultant cost per ton of soil disposed was approximately $1,267. 3.6.2 P.S. 199M

Remediation of soils containing greater than 1ppm of PCBs was performed at P.S. 199M during the summer of 2011. Soil areas were excavated to a depth of two (2) feet bgs. Post-excavation soil samples were collected and laboratory analytical results of all initial post-excavation samples, with the exception of one (1) sidewall sample, indicated PCBs were less than 1 ppm. Additional excavation was conducted surrounding the failed sidewall sample and an additional post-excavation sample was collected. Laboratory analysis showed this sample to be less than 1 ppm total PCBs and there was no further excavation required in this or any other remediation area of the site. According to the Louis Berger Associates (LBA) Polychlorinated Biphenyl Soil Remediation Report (PCB Report), dated October 17, 2011, the cost for the outside exposure areas, including soil remediation and landscaping, came to $140,000. LBA estimated that approximately 120 tons of soil was disposed of as non-hazardous (greater than 1 ppm and less than 50ppm) for PCBs. The resultant cost per ton of soil disposed is approximately $1,170. 3.6.3 P.S. 309K

Remediation of soils containing greater than 1 ppm of PCBs was performed at P.S. 309K during the summer of 2011. Areas along the northern façade of the building where previous sample results indicated PCB concentrations that exceeded 1 ppm were excavated. Soil areas were excavated to a depth of two (2) feet bgs. Post-excavation soil samples were collected and laboratory analytical results of all initial post-excavation samples, with the exception of one (1) bottom centerline sample, indicated PCBs were less than 1 ppm. Additional excavation was conducted in the area of the failed bottom centerline sample down to a depth of three (3) feet bgs and an additional post-excavation sample was collected. Laboratory analysis showed this sample to be less than 1 ppm total PCBs and there was no further excavation required in this or any other remediation area of the site. According to the Louis Berger Associates (LBA) Polychlorinated Biphenyl Soil Remediation Report (PCB Report), dated October 17, 2011, the cost for the outside exposure areas, including soil remediation and landscaping, was $120,000. LBA estimated that approximately 127 tons soil was disposed of as non-




hazardous (greater than 1 ppm and less than 50ppm) for PCBs. The resultant cost per ton of soil disposed is approximately $950. 3.7 Cost Analysis Discussion

Table 3.6 summarizes the results of the individual cost analyses for the interior alternatives which were described above.

Table 3.6 - Cost Comparison of Interior Remedial Alternatives

School ID Remedial Alternative

Total Labor Hours

(Remediation)

Approximate Total Cost

Approximate Quantity

Remediated

Approximate Unit Cost

P.S. 178X/176 Caulk Patch and Repair (2010)

759 $73,849 213 linear feet (lf)

$347 per lf

Caulk Patch and Repair (2011)

1,234.5 $153,263 397 lf $386 per lf

Caulk Patch and Repair (2010 and

2011)

1,993.5 $227,112 610 lf $372 per lf

P.S. 199M Caulk Removal and Replacement

(2010)

1,147 $119,500 1,090 lf $110 per lf

Caulk Removal and Replacement

(2011)

3,862 $411,137 1,986 lf $207 per lf

Caulk Removal and Replacement (2010 and 2011)

5,009 $530,637 3,076 lf $172 per lf

P.S. 309K Caulk Encapsulation

(2010)

601 $57,168 1,056 lf $54 per lf

Caulk Encapsulation

(2011)

1,306.5 $132,142 2,502 lf $53 per lf

Caulk Encapsulation

(2010 and 2011)

1,907.5 $189,310 3,558 lf $53 per lf




Table 3.6 - Cost Comparison of Interior Remedial Alternatives


Total Labor Hours

(Remediation)



Remediated


P.S. 183Q Window Removal and Replacement

2,386.5 $1,229,967 12,629 lf $97 per lf

P.S. 3R Light Ballast and Fixture Removal and Replacement

3,020 $1,477,955 848 fixtures (with 927 ballasts)

$1,743 per fixture

($1,594 per ballast)

In summary, on a cost per linear foot basis, the Pilot Study cost analysis suggests that the caulk patch and repair alternative is the most expensive short-term remedy, followed in descending order by the caulk removal and replacement alternative, and the caulk encapsulation alternative. However, the relatively lower quantity of caulk remediated by the patch and repair method as compared to the encapsulation and removal remedies resulted in an upward bias in the unit cost for this remedy. Patch and repair and removal remedies both require the same dust control work area preparation requirements; however, during the patch and repair remedial alternative, subsequent to completion of area preparation, only a portion of the total caulk was remediated as compared to the removal remedy, which addressed all of the caulk. This is believed to be the primary reason for the upward bias in unit costs for patch and repair. An additional factor was the requirement for more stringent ACM dust control measures in a number of patch and repair work areas, due to the presence of ACM, which were not required for the removal remedy, as all caulk was non-ACM. Based on the level of effort and amount of waste generated at P.S. 178X/176, it is anticipated that in a given school, the patch and repair method would result in a unit cost that would be higher than the encapsulation method, but lower than the removal and replacement alternative if comparable quantities were remediated in each work area. The unit cost per linear foot of caulk for removal and replacement at P.S. 199M was approximately double in 2011 as compared to 2010 (i.e., $207 versus $110 per linear foot). The primary reason for the difference in unit costs was higher labor costs, which are believed to be the result of the labor intensive construction of relatively larger containments for dust control in 2011 versus 2010. A secondary contributor to the higher labor costs was also higher hourly labor rates. A comparable amount of caulk was remediated by the encapsulation and removal and replacement methods, with the encapsulation method resulting in an average unit cost per linear foot of about one third of the removal and replacement method.

The window removal alternative remediated the greatest amount of PCB Caulk with the lowest total incremental cost (i.e., without the capital improvement project costs such as purchasing and installing the replacement windows) of $17 per linear foot of caulk. This unit cost is misleading because a significant capital expenditure is required as part of this work to return the school to fully restore the school to operational status. If the capital project costs of the replacement window purchase and installation were included in the cost analysis, the unit price increases from $17 to $97 per linear foot of caulk which is greater than the encapsulation unit cost, but less than the patch and repair and removal remedies unit costs. The lower window replacement unit cost is believed to be the result of the relatively high quantity of window caulking removed within each work area as compared to the patch and repair and removal remedies, which were implemented in disparate locations throughout the school. Due to the high capital improvement project costs, including window purchase and installation, window replacement is not




considered a viable remedial method per se. Rather, window replacement represents a capital improvement that should be performed when operationally appropriate in the schools using methods to control, remove, and dispose of any related PCB Caulk.

Table 3.7 summarizes the results of the individual cost analyses for the exterior alternatives which were described above.

Table 3.7 - Cost Comparison of Exterior Remedial Alternatives


Total Labor Hours



Remediated


P.S. 178X/176 Exterior Caulk Encapsulation

(interim response)

652 $72,124 3,210 lf $22 per lf

P.S. 199M Exterior Caulk Encapsulation

(interim response)

584 $67,408 2,292 lf $29 per lf

Pilot Study Total Exterior Caulk Encapsulation

1,236 $139,532 5,502 lf $25 per lf

P.S. 178X/176 Soil Remediation -- $128,000 101 tons $1,267 per ton

P.S. 199M Soil Remediation -- $140,000 120 tons $1,170 per ton

P.S. 309K Soil Remediation -- $120,000 127 tons $950 per ton

Pilot Study Total Soil Remediation -- $388,000 348 tons $1,115 per ton

The average unit cost per linear foot associated with the exterior caulk encapsulation was fairly consistent for the two schools studied despite significant differences in the associated hours and quantities of caulk remediated. In addition, the average unit cost per linear foot for the exterior caulk encapsulation was approximately one half of the unit cost associated with the interior caulk encapsulation.

The unit cost on a per ton basis associated with soil remediation is relatively consistent from school to school, especially at P.S. 199M and P.S. 309K where no hazardous soil was disposed. The unit cost per ton associated with P.S. 178X was somewhat higher, and is believed to be primarily due to a higher unit cost for disposal of a portion of the soil as a hazardous waste.

Based on the Pilot Study cost analysis, the unit costs, and total costs, associated with implementing these remedial alternatives in the future are anticipated to vary due to differences in the distribution of PCB Caulk in the schools, contract pricing, and economies of scale, for instance. In addition, cost savings could be realized if remediation waste is segregated by type and PCB concentration and subjected to characterization, thus diverting portions of the total waste stream to lower-cost management and disposal alternatives.




4.0 INDIVIDUAL ANALYSIS OF REMEDIAL ALTERNATIVES

4.1 Introduction

The purpose of the individual analysis is to assess each remedial alternative against these seven standard USEPA evaluation criteria (U.S. EPA October 1989). The evaluation criteria are as follows:

1. Overall Protectiveness:

Under this criterion, an alternative is evaluated to determine whether it can adequately protect human health and the environment, in both the short- and long-term, from risks posed by contaminants present at the site by eliminating, reducing or controlling exposures to chemical impacts in Site media.

2. Compliance with Comparison Criteria This criterion evaluates whether the alternative will likely be able to attain applicable or relevant and appropriate requirements (ARARs) under federal environmental laws and state environmental or facility citing laws, or if a waiver is required and how it is justified.

3. Long-Term Effectiveness and Permanence: Under this criterion, an alternative is evaluated for the long-term effectiveness and permanence in maintaining protection of human health after response actions have been completed. Factors to be considered include: the magnitude of risk from any residual contaminants at the conclusion of the remedial activities; and the adequacy and reliability of controls that are necessary to manage exposure to any remaining contaminants.

4. Reduction of Toxicity, Mobility or Volume Through Treatment:

This criterion evaluates the degree to which an alternative employs recycling or treatment in order to reduce the toxicity, mobility, or volume of the principal threats posed at the site. Factors that are considered include: the alternatives employed and the materials they will treat; the amount of contaminants that will be destroyed, treated, or recycled; the degree of expected reduction in toxicity, mobility or volume of the contaminants due to treatment or recycling; the degree to which the treatment is irreversible; the type and quantity of residuals remaining; and the degree to which treatment reduces the inherent hazards posed by principal threats at the site.

5. Short-Term Effectiveness:

This criterion evaluates the impacts of the alternative during implementation with respect to human health and the environment. The short-term impacts of an alternative are assessed considering: short-term risks that might be posed to the community during implementation of an alternative; potential impacts on workers during remedial action and the effectiveness and reliability of protective measures; potential environmental impacts of the remedial action and the effectiveness and reliability of mitigation measures during implementation. In addition, relative remediation time frames are discussed for each alternative.




6. Ease of Implementation:

This criterion addresses the technical and administrative feasibility of implementing the alternative as well as the availability of various services and materials required.

7. Cost:

This criterion evaluates the initial and operations and maintenance (O&M) expenditures to implement each alternative.

These criteria are designed to allow the analysis of each alternative to address a broad range of factors encompassing statutory requirements and other fundamental considerations with the goal of selecting the most appropriate remedial alternatives. The individual analysis examines the performance of each alternative against the evaluation criteria highlighting the specific remedial alternative strengths and weaknesses. A summary is presented in Appendix B which assesses each remedial alternative against the evaluation criteria. 4.2 Patch and Repair Remedy

4.2.1 Description

Patch and repair of PCB Caulk involves removing any loose or significantly deteriorated caulk and replacing the removed caulk with new, non PCB-containing caulk. After the caulk is removed, a non PCB-containing caulk is installed in the areas where the PCB Caulk was removed. This remedial action is implemented using adequate dust controls. Dust controls can be performed in the manner described in the Remedial Investigation Plan Dust Control (Appendix I) or, if asbestos will be disturbed, in accordance with asbestos abatement regulations. 4.2.2 Assessment

4.2.2.1 Overall Protectiveness

Direct contact, ingestion, and inhalation of PCB caulk would be minimized to varying degrees by identifying and removing any loose or significantly deteriorated PCB caulk. Although protective of human health, since exposure to PCB Caulk would be controlled, this remedial alternative would still present some exposure potential because a portion of PCB Caulk would remain. This alternative is not likely to have an adverse affect the environment because PCBs from interior caulk are unlikely to migrate to outside soils or off-site. 4.2.2.2 Compliance with Comparison Criteria

Implementation of the patch and repair alternative on interior caulk is anticipated to have a positive impact towards compliance with comparison criteria, because loose or deteriorated portions of the PCB Caulk are being removed. However, any PCB Caulk that is not in a loose or deteriorated condition, and therefore not remediated, would remain. This alternative would have some degree of positive impact on the indoor air quality, with regard to PCBs, because the overall condition of the PCB caulk would be improved and the volume of PCB Caulk would be reduced. The results of post-remedial wipe and air sampling for the Pilot School Building evaluated under this alternative were below the comparison criteria. Refer to Section 1.2.4 for applicable comparison criteria.




This alternative will largely prevent any further contamination of outside soil by helping to stabilize deteriorated exterior PCB Caulk, but does not address any existing soil contamination that may be present. 4.2.2.3 Long-Term Effectiveness and Permanence

Direct contact, ingestion, and inhalation of PCB Caulk, is effectively minimized by identifying and removing any loose or significantly deteriorated caulk. For this alternative to remain effective over the long-term, periodic inspections and maintenance in accordance with the BMP are required. Additionally, evaluation of caulk through the annual sampling per the 5-year long–term monitoring program will provide additional information relative to long-term effectiveness. Potential exposure still exists because not all of the PCB Caulk would be removed. 4.2.2.4 Reduction of Toxicity, Mobility or Volume Through Treatment

Patch and repair is an irreversible treatment process that would remove and dispose of portions of PCB Caulk by identifying any loose or significantly deteriorated caulk and replacing the removed caulk with new, non PCB-containing caulk. Any PCB Caulk removed will be taken off-site for proper disposal. The total volume of PCB Caulk is thus reduced by removing a portion of it. This treatment effectively reduces the toxicity, mobility, and volume of treated PCB Caulk, but has no affect on the toxicity, mobility or volume of the PCBs in the remaining caulk. This alternative addresses the preference for using treatment as a principal element because the risks are addressed by patching, repairing, and disposing of loose or deteriorated PCB Caulk. 4.2.2.5 Short-Term Effectiveness

When implementing this alternative, there would be no increased risk to the community (i.e., the school population and general public). The possibility of a small additional risk to the community through inhalation does exist if dust from remediation activities is not adequately controlled. This risk, however, would be mitigated by using good housekeeping practices and utilizing dust control measures when implementing this alternative. Workers can be readily and adequately protected from contaminants during the implementation of this alternative through the use of appropriate engineering controls and personal protective equipment. The equipment needed for personal protection is readily available and relatively inexpensive.

No significant adverse impacts to the environment are anticipated by implementing this alternative. Controlling dust will prevent migration of contaminants. 4.2.2.6 Ease of Implementation

The patch and repair alternative is considered to be relatively easy to implement and can be implemented in a particular school in a reasonable timeframe with appropriate planning and resources. Through procedures described in the CAFO, the City would obtain prior approval from the USEPA to routinely implement this remedial alternative. The effectiveness of this alternative can be readily monitored during the course of the work. If more action is needed, more work can readily be performed. All the necessary tools, equipment, services and specialists to implement the patch and repair remedy are readily available. It is required that the work be performed when school is not in session (e.g., nights, weekends, holidays, etc.). For this reason, shorter implementation timeframes provide more opportunities to implement the




remedy with a reduced likelihood of disrupting normal school activities. This alternative is thought to have a low potential to disrupt normal school activities because of its relatively straight forward nature. 4.2.2.7 Cost

This alternative can be implemented and maintained at a relatively low initial and operations and moderate maintenance costs, respectively. Although the relatively small quantity of caulk subject to the patch and repair remedial alternative resulted in a unit price per linear foot greater than removal and replacement, the overall short-term cost to implement this alternative is believed to be less costly than removing and replacing PCB Caulk, but more expensive than encapsulation as discussed in Section 3.7, above. 4.3 Encapsulation

4.3.1 Description

The encapsulation remedy involves the use of a commercially available encapsulant that acts as a barrier or coating to prevent dust generation and direct contact with PCB Caulk. Because this remedial alternative involves little to no disruption of PCB Caulk, it requires less comprehensive dust controls. 4.3.2 Assessment


The risk of direct contact, ingestion, and/or inhalation of PCB Caulk would be minimized, if not eliminated, to the extent that the encapsulant acts as a barrier and remains intact. Although protective of human health, because exposure to PCB Caulk would be controlled, this remedial action might still allow some exposure if the encapsulant becomes damaged or deteriorated. The possibility of the PCBs leaching through the encapsulant is being evaluated through the long-term monitoring annual sampling program. This alternative is not likely to have an adverse effect upon the environment. 4.3.2.2 Compliance with Comparison Criteria

Implementation of the encapsulation alternative is anticipated to have a positive impact towards compliance with comparison criteria because the PCB Caulk is being isolated from the school population. This alternative would likely lower the concentrations of PCBs in the air, dust, and surfaces because the PCB Caulk would no longer be directly exposed. The results of post-remedial wipe sampling for the Pilot School Building evaluated under this alternative were below the comparison criteria. The results of post-remedial air sampling in the areas remediated were initially unchanged (indicating that encapsulation did not adversely impact air quality) and were below the applicable comparison criteria when re-sampled approximately two months later. Refer to Section 1.2.4 for the applicable comparison criteria. This alternative, if implemented on exterior PCB Caulk, will potentially help prevent any further contamination of outside soil by stabilizing PCB Caulk, but does not address any preexisting soil contamination that may exist. 4.3.2.3 Long-Term Effectiveness and Permanence

Direct contact, ingestion, and inhalation of PCB Caulk, is effectively minimized by encapsulation of PCB caulk. For this alternative to remain effective over the long-term, periodic inspections and maintenance in




accordance with the BMP are required. Additionally, evaluation of caulk encapsulant through annual sampling per the five-year, long–term monitoring program will provide additional information relative to long-term effectiveness. This remedial alternative has the potential to allow exposure to residual PCB Caulk, because not all of the PCB Caulk would be removed. Areas where the encapsulant was applied will require regular inspections and if any encapsulant is observed to be damaged or deteriorated, re-encapsulation would need to be performed. 4.3.2.4 Reduction of Toxicity, Mobility or Volume Through Treatment

The encapsulation alternative is a potentially reversible treatment process that acts as a barrier or coating to mitigate dust generation and dermal contact. The total volume and toxicity of contaminants remains unchanged because no PCB Caulk is removed or otherwise eliminated. The mobility of the contaminants is reduced because the encapsulant will act as a barrier to the PCB Caulk. This alternative addresses the preference for using treatment as a principal element by physically isolating the PCB Caulk. 4.3.2.5 Short-Term Effectiveness

When implementing this alternative, there would be no increased risk to the community (i.e., the school population and general public). Compared to the other alternatives being evaluated, the potential for dust generation is considered low because PCB Caulk needs to be intact to be encapsulated and is not being disturbed. As indicated by the post-remedial air-sampling results, PCB air concentrations in the areas remediated were initially unchanged (indicating that encapsulation did not adversely impact air quality) and were below the applicable comparison criteria approximately two months after implementing this remedial alternative. A thorough cleaning of the work area by an environmental contractor is recommended when implementing this alternative to ensure adequate removal of any dust generated from work activities. Workers can be readily and adequately protected from contaminants during the implementation of this alternative through the use of appropriate engineering controls and PPE. The equipment needed for personal protection is readily available and relatively inexpensive. No significant adverse impacts to the environment are anticipated by implementing this alternative. 4.3.2.6 Ease of Implementation

Encapsulation is the easiest remediation method to implement compared to the other remedial alternatives under consideration, and with appropriate planning and resources can be implemented in a particular school in the most reasonable timeframe. Any areas with significantly deteriorated PCB Caulk would require patching and repairing either before or in lieu of encapsulation, because loose caulk does not provide an adequate foundation for the bonding of the encapsulant. Through procedures described in the CAFO, the City would obtain prior approval from the USEPA to routinely implement this remedial alternative. The effectiveness of this alternative can be readily monitored during the course of the work. If more action is needed, additional work can readily be performed. Work would need to be performed when school is not in session (e.g., nights, weekends, holidays, etc.). For this reason, shorter implementation timeframes provide more opportunities to implement the remedy with a reduced likelihood of disrupting normal school activities. This alternative has a low potential to disrupt normal school activities because of the relatively shorter time anticipated for implementation as compared to the other alternatives being evaluated.




As various encapsulants contain potentially hazardous components, review, understanding and compliance with the encapsulant specific material safety data sheets (MSDS) is required to adequately protect applicators and school environment. 4.3.2.7 Cost

Encapsulation can be implemented at relatively low to medium operations and maintenance costs. As supported by the Pilot Study cost analysis provided in Section 1.4 above, the overall short-term cost to implement the encapsulation alternative is anticipated to be less than for either the “remove and replace” or the “patch and repair” PCB Caulk alternatives. 4.4 Removal and Replacement

4.4.1 Description

Removal and replacement of all PCB Caulk involves removing all visible and accessible PCB Caulk and replacing the removed caulk with new caulk that does not contain PCBs. This remedial alternative will require the use of adequate dust controls. Dust controls can be performed in the manner described in the Remedial Investigation Plan Dust Control (Appendix I) or, if asbestos will be disturbed, in accordance with asbestos abatement regulations. The type of dust control required must be evaluated on a project by project basis. 4.4.2 Assessment


Of all the alternatives addressing PCB Caulk, the removal and replacement alternative offers the most protection to human health because the source of contamination is removed in its entirety. There would be no potential risk associated with direct contact, ingestion or inhalation. The possibility of the residual PCBs leaching into the newly applied caulk that does not contain PCBs is being evaluated through the long-term monitoring annual sampling program. The remediation is not expected to have an adverse effect upon the environment. 4.4.2.2 Compliance with Comparison Criteria

Implementation of the removal and replacement alternative is anticipated to have a positive impact towards compliance with comparison criteria, including indoor air quality, because all accessible PCB Caulk is removed. This alternative would likely have the greatest degree of positive impact on the indoor air quality with regard to PCBs as compared to the other PCB Caulk remediation alternatives being evaluated because, unlike the other alternatives, all accessible PCB Caulk is removed. The results of post-remedial wipe sampling for the Pilot School Building evaluated under this alternative were below the comparison criteria. As indicated by the post-remedial air-sampling results, PCB air concentrations in the areas remediated were initially unchanged (indicating that removal and replacement did not adversely impact air quality). Refer to Section 1.2.4 for applicable comparison criteria. This alternative, if implemented on exterior PCB Caulk, will largely prevent any further contamination of outside soil from that caulk, but does not address any existing soil contamination that may be present.




4.4.2.3 Long-Term Effectiveness and Permanence

This remedial alternative is thought to offer a high level of long-term effectiveness as compared to the other remedial alternatives in which full removal of PCB Caulk is not contemplated. By removing all PCB Caulk, residual risk is believed to be largely eliminated because the source has been removed. As a result, the risk of direct contact, ingestion, or inhalation of PCBs from the caulk has been significantly reduced, if not eliminated entirely, and no additional controls should be necessary. Evaluation of installed non PCB-containing caulk through annual sampling pursuant to the five-year, long–term monitoring program will provide additional information relative to long-term effectiveness, including the possibility of any residual PCBs leaching into the new caulk. 4.4.2.4 Reduction of Toxicity, Mobility or Volume Through Treatment

The removal and replacement alternative is an irreversible treatment process that would remove all visible and accessible PCB Caulk and replace the removed caulk with new caulk that does not contain PCBs. The total volume, toxicity and mobility of PCBs in the caulk are reduced to zero by its removal and off-site disposal. This alternative addresses the preference for using treatment as a principal element because the risks are addressed by removing and replacing all of the PCB Caulk. 4.4.2.5 Short-Term Effectiveness

When implementing this alternative, no increased risk to the community (i.e., the school population and general public) or adverse impact to the environment would be expected. The possibility of a small additional risk to the community through inhalation does exist if dust from remediation activities is not adequately controlled. This risk can be minimized by observing good housekeeping practices and utilizing dust control and suppression measures when implementing this alternative. Workers can be readily and adequately protected from contaminants during the implementation of this alternative through the use of appropriate engineering controls and PPE. Proper PPE for this type of work is readily available and relatively inexpensive. 4.4.2.6 Ease of Implementation

The removal and replacement alternative is considered to be relatively easy to implement in the interior of schools and can be implemented in a particular school in a reasonable timeframe with appropriate planning and resources. Through procedures described in the CAFO, the City would obtain prior approval from the USEPA to routinely implement this remedial alternative. The effectiveness of this alternative can be readily monitored through the course of the work. If more action is needed, additional work can be performed. Work must be performed when school is not in session (e.g., nights, weekends, holidays, etc.) For this reason, shorter implementation timeframes provide more opportunities to implement the remedy with a reduced likelihood of disrupting normal school activities. This alternative, however, is thought to have a moderate potential to disrupt normal school activities because the scope of the remedy is greater than the patch and repair or encapsulation alternatives. The potential disruption caused by this alternative is anticipated to be less than the disruption expected for light fixture and ballast removal/replacement and the window replacement alternatives.




4.4.2.7 Cost

The initial cost to implement this remedy is relatively moderate, but is somewhat more expensive than the other alternatives being evaluated for PCB Caulk. These costs are partially offset by little or no subsequent operation and maintenance costs. Because all PCB Caulk is being removed, any future loose or deteriorated caulk is likely to be non PCB-containing caulk which on this basis does not require any special training, handling, or disposal associated with its disruption. 4.5 Window Removal and Replacement

4.5.1 Description

The window replacement alternative involves removal and replacement of windows and window systems and removal of all associated PCB Caulk and replacement with new caulk that does not contain PCBs. This remedial alternative requires the use of dust controls performed in the manner described in the Remedial Investigation Plan Dust Control (Appendix I) or, if asbestos will be disturbed, in accordance with asbestos abatement regulations. 4.5.2 Assessment


Direct contact, ingestion, and inhalation of PCB Caulk would be eliminated by identifying and removing a significant amount of PCB Caulk and replacing the removed caulk with new caulk that does not contain PCBs. This alternative only addresses PCB Caulk that is associated with the building windows and window systems. With the use of proper procedures, this alternative is not likely to adversely affect the environment, because PCB Caulk would be controlled. 4.5.2.2 Compliance with Comparison Criteria

Implementation of the window replacement alternative is anticipated to have a positive impact towards compliance with comparison criteria because relatively large portions of the PCB Caulk are removed and replaced with caulk that does not contain PCBs. However, this alternative does not address any PCB Caulk that may be present in other locations and, therefore, will not be remediated when the windows are replaced. This alternative would likely have some degree of positive impact on the indoor air quality, with regard to PCBs, because a discrete volume of PCB Caulk is removed and disposed. The results of post-remedial wipe sampling for the Pilot School Building evaluated under this alternative were below the comparison criteria. As indicated by the post-remedial and post-recleaning air-sampling results, PCB air concentrations fell below the applicable comparison criteria after a detailed custodial cleaning of the work areas after installation of new windows was performed. This alternative will largely prevent any further contamination of outside soil by eliminating PCB Caulk, but does not address any existing soil contamination that may be present. 4.5.2.3 Long-Term Effectiveness and Permanence

By removing PCB Caulk from windows and the window systems and replacing the removed caulk with new caulk that does not contain PCBs, residual risk is believed to be largely eliminated from those areas




because the source has been removed. However, if PCB Caulk is still present in other locations, the potential underlying risk of exposure through direct contact, ingestion, or inhalation still exists at these locations, although overall risk will have been reduced. Evaluation of new non PCB-containing caulk through annual sampling pursuant to the five-year, long–term monitoring program will provide additional information relative to long-term effectiveness. 4.5.2.4 Reduction of Toxicity, Mobility or Volume Through Treatment

The window replacement alternative is an irreversible treatment process that involves removal and replacement of window systems and removing all associated PCB Caulk, replacing the removed caulk with new caulk that does not contain PCBs. Any PCB Caulk removed will be taken off-site for proper disposal. The total volume of PCB Caulk is reduced by removing the portion impacted by the work. However, this alternative will have no affect on the mobility, toxicity, or volume of the remaining PCBs if any PCB Caulk should remain in other locations. This alternative addresses the preference for using treatment as a principal element because the risks are addressed by removing and replacing PCB Caulk associated with the windows and window systems. 4.5.2.5 Short-Term Effectiveness

When implementing this alternative, no increased risk to the community (i.e., the school population and general public) or adverse impact to the environment would be expected. The possibility of a small additional risk to the community through inhalation does exist if dust from remediation activities is not adequately controlled. This risk can be minimized by observing good housekeeping practices and utilizing appropriate dust control and suppression measures when implementing this alternative. Workers can be readily and adequately protected from contaminants during the implementation of this alternative through the use of appropriate personal protection equipment (PPE) and controlling any dust that may be generated during the process. Proper PPE for this type of work is readily available and relatively inexpensive. 4.5.2.6 Ease of Implementation

The window removal and replacement alternative is considered to be relatively difficult to implement in the interior of schools because it is a major capital improvement project; however, it can be implemented in a particular school in a reasonable timeframe with appropriate planning and resources. Through procedures described in the CAFO, the City would obtain prior approval from the USEPA to implement this remedial alternative during window replacement projects. The effectiveness of this alternative can be readily monitored through the course of the work. Work must be performed when students and school faculty are not present (e.g., evenings, summer break, weekends, holidays, etc.). For this reason, shorter implementation timeframes provide more opportunities to implement the remedy with a reduced likelihood of disrupting normal school activities. This alternative, however, is thought to have a moderate potential to disrupt normal school activities because of the intrusive nature of the remedy. The disruption for this alternative is anticipated to be equal or exceed the disruption expected for PCB Caulk removal and replacement and the light fixture and ballast removal/replacement alternatives. Of the remedial alternatives evaluated that focus on PCB Caulk, window removal and replacement has the highest risk of adverse impacts to the surrounding soil. However, significant adverse impacts to the environment are not anticipated because this alternative would be implemented with appropriate controls to prevent migration of contaminants.




4.5.2.7 Cost

The capital cost to implement this remedy is relatively high, and is more expensive than the other alternatives being evaluated for PCB Caulk as this work is part of capital improvement projects. Operations and maintenance costs are expected to be moderate. Since only PCB Caulk associated with window replacement is being removed, any non-window PCB Caulk would need to be evaluated and managed. This alternative is not expected to be implemented unless part of a window replacement project and therefore direct comparison to patch and repair, remove and replace and encapsulation is not appropriate. 4.6 PCB Light Fixture and Ballast Replacement

4.6.1 Description

Removal and replacement of PCB Light Ballasts and Fixtures involves removing all light fixtures containing ballasts with PCBs and then installing new light fixtures with non-PCB ballasts. Leaking ballasts are removed from the fixture and drummed and incinerated at a U.S. EPA-approved TSCA permitted high temperature incinerator. If a ballast is not labeled “No PCB”, it is assumed to be a PCB ballast and is removed, drummed, and recycled/incinerated at a U.S. EPA-approved TSCA permitted ballast recycling facility. Fixtures impacted by leaking PCB oil are disposed of as PCB remediation waste. Non-impacted fixtures can be disposed of as recycle, C&D, or ACM waste, as appropriate. 4.6.2 Assessment


The light fixture and ballast replacement alternative offers the most protection to human health and the environment because the source of contamination is removed in its entirety. As discussed in the RIR, the removal and replacement of PCB light ballasts and fixtures generally had the most pronounced effect in terms of lowering PCB levels in air. Because all impacted light fixtures and PCB ballasts are removed, there is no further ongoing risk associated with direct contact, ingestion or inhalation. The remediation of PCB light fixtures and ballasts is not expected to adversely affect the environment. 4.6.2.2 Compliance with Comparison Criteria

Implementation of light fixture and ballast replacement alternative is anticipated to have a positive impact towards compliance with comparison criteria because a source of PCBs in the air is being removed. This alternative would likely have the greatest degree of positive impact on the indoor air quality with regard to PCBs as compared to the other alternatives being evaluated. The results of post-remedial wipe and air sampling for the Pilot School Building evaluated under this alternative were below the comparison criteria. Refer to Section 1.2.4 for applicable comparison criteria. This alternative does not address any existing soil contamination that may be present. 4.6.2.3 Long-Term Effectiveness and Permanence

This remedial alternative is thought to offer a high level of long-term effectiveness. By removing all PCB light ballasts and fixtures, any residual risk will be eliminated because the underlying source has been removed. As a result, the risk of direct contact, ingestion, or inhalation of PCBs from the PCBs in the




light fixtures has been significantly reduced, if not eliminated entirely, and no additional controls are necessary. 4.6.2.4 Reduction of Toxicity, Mobility or Volume Through Treatment

The removal and replacement of PCB light ballasts and fixtures alternative is an irreversible treatment process that would remove all light fixtures containing PCB ballasts and then installing new light fixtures with non-PCB ballasts. The total volume, toxicity and mobility of ballast related PCBs are essentially eliminated by their removal and off-site disposal. This alternative addresses the preference for using treatment as a principal element because the risks are addressed by removing and replacing all of the PCB light ballasts and fixtures. 4.6.2.5 Short-Term Effectiveness

When implementing this alternative, no increased risk to the community (i.e., the school population and general public) or adverse impact to the environment would be expected. The possibility of a small additional risk to the community through inhalation and direct contact does exist if remediation activities are not adequately controlled. This risk can be effectively minimized by observing good housekeeping practices and utilizing control measures when implementing this alternative. Workers can be readily and adequately protected from contaminants during the implementation of this alternative through the use of appropriate engineering controls and PPE. Proper PPE for this type of work is readily available and relatively inexpensive. 4.6.2.6 Ease of Implementation

The removal and replacement alternative is considered to be relatively difficult to implement in the interior of schools because it is a major capital project; however, it can be implemented in a particular school in a reasonable timeframe with appropriate planning and resources. Through procedures described in the CAFO, the City would obtain prior approval from the USEPA to routinely implement this remedial alternative. The effectiveness of this alternative can be readily monitored through the course of the work. If more action is needed, additional work can readily be performed. Work will need to be performed when school is not in session (e.g., summer break, weekends, holidays, etc.) For this reason, shorter implementation timeframes provide more opportunities to implement the remedy with a reduced likelihood of disrupting normal school activities. This alternative, however, is thought to have a moderate potential to disrupt normal school activities because the scope of the remedy is greater than the alternatives which address PCB Caulk, with the exception of window replacement. 4.6.2.7 Cost

The capital cost to implement this remedy is relatively more expensive than the other alternatives being evaluated, with the exception of window removal and replacement. These relatively higher capital costs associated with these capital improvement projects may potentially be offset by lower operation and maintenance costs associated with the new equipment. Because all the PCB light ballasts and fixtures are being removed, any light ballasts and fixtures will be non-PCB light ballasts and fixtures which on this basis do not require any special PCB-related training, handling, or disposal.




4.7 Best Management Practices

4.7.1 Description

The Best Management Practices (BMPs) are a set of protocols that, when implemented, help to mitigate exposure to PCB Caulk through the use of regular inspections, stringent cleaning methods, and maintaining essential building systems (i.e., HVAC systems). The BMPs also include measures and practices that may be used to protect PCB Caulk from accidental damage and to identify areas with deteriorating PCB Caulk requiring further action on an ongoing basis during school maintenance activities. The BMPs are being modified to include the currently proposed remediation of deteriorated PCB Caulk by patch and repair, remove and replace, or encapsulation remedies. 4.7.2 Assessment


The BMPs offer a satisfactory reduction in the risk of direct contact and ingestion when surfaces that may contain dust containing PCBs are regularly and thoroughly cleaned. This is supported by the results of the pre-remedial wipe samples that consistently indicated PCB concentrations in dust to be lower than the applicable comparison criteria. There would be a reduction in risk of direct contact with in-situ PCB Caulk because the preventive maintenance element of the BMPs would reduce the overall volume and damaged volume of caulk through removal or encapsulation. The BMPs as a stand-alone remedial measure have not been shown to adequately reduce the inhalation risk based on the results of the Pilot Study pre-remedial air sampling which were often above the applicable comparison criteria. However, when the BMPs were coupled with the PCB light fixture and ballast removal alternative, a positive effect on indoor air quality was observed, as demonstrated by the 2010 post-remedial air sampling at P.S. 199M, P.S. 178X/176 and P.S. 309K. The BMPs do not address existing soil contamination but contain provisions intended to minimize further soil impacts from any renovation or construction activities. 4.7.2.2 Compliance with Comparison Criteria

Because the BMPs call for PCB Caulk inspection and response to damaged caulk, a positive impact regarding the PCB concentration in the caulk is anticipated over time because the BMPs call for removing deteriorated PCB Caulk and dust that may contain PCBs from surfaces. Although not considered as a part of this evaluation (see Section 2.4 above), to the extent that the BMPs require remediation of deteriorated PCB caulk, further positive impacts are anticipated. The BMPs are not expected to significantly impact the existing concentrations of PCBs in soil, but would mitigate further soil impacts from any future renovation or construction activities impacting exterior caulk, and to the extent exterior PCB Caulk is maintained on an on-going basis. 4.7.2.3 Long-Term Effectiveness and Permanence

Through the use of effective cleaning and routine maintenance, the BMPs would reduce the risk of direct contact, ingestion, and, to an extent, inhalation because PCBs present in dust and deteriorated caulk would be removed, repaired, or encapsulated. The BMPs, as currently proposed, provide adequate controls with respect to direct contact and ingestion. The risk of inhalation is not fully addressed because




PCB Caulk remains in service. When the BMPs are coupled with the PCB light fixture and ballast removal alternative, a positive effect on indoor air quality is anticipated. 4.7.2.4 Reduction of Toxicity, Mobility or Volume Through Treatment

This alternative provides reduction in toxicity through treatment, and a slight reduction in the mobility and volume is anticipated to the extent that cleaning and inspections result in the removal of fugitive dust or PCB Caulk. Because only a slight amount of PCB Caulk is anticipated to be eliminated through cleaning, there is no significant reduction in volume with this aspect of the alternative. As the BMPs are being modified to include the currently proposed remediation of deteriorated PCB Caulk by patch and repair, remove and replace, or encapsulation remedies, this alternative does address the preference for using treatment as a principal element of the remedy. 4.7.2.5 Short-Term Effectiveness

Implementing this alternative would not be expected to increase the risk of exposure to the community (i.e., the school population and general public), workers, or the environment. This alternative would be an on-going event with no completion date. 4.7.2.6 Ease of Implementation

BMPs are currently in place and relatively routine to implement. The effectiveness of this alternative will be monitored through periodic inspections and audits. If inspection results indicate more action is needed, additional work can be performed. All the necessary tools, equipment, services and specialists are already in place or readily obtainable. This alternative will not cause any disruption to school activities. 4.7.2.7 Cost

The BMPs are currently being implemented as a part of good general housekeeping within the school buildings, so there is only an incremental additional cost associated with implementing this alternative. 4.8 Soil Removal in Outside Exposure Areas

4.8.1 Description

Outside exposure areas are defined as the soil immediately adjacent to and within 10 feet of the school building façade. The remedial investigations identified surface soils with PCB concentrations above the applicable comparison criteria (1 ppm) at each of the Pilot School Buildings. The soil contamination is the likely result of degradation of exterior caulk over time and/or historical exterior modernization activities conducted prior to the implementation of adequate methodologies to prevent PCB Caulk from being dispersed to soil adjacent to the building in Relevant Schools. In accordance with 40 CFR 761.61, the permanent remedy to address any existing soil contamination involves excavation of impacted soil in all areas where PCB concentrations are greater than 1 ppm. Soil sampling is required after completion of modernization projects that have impacted exterior PCB Caulk during construction activities. Soil samples are collected from 0 – 2 inches bgs every 20 feet in three rows from the building at 0.5 feet, 3 feet, and 8 feet. All soil samples in the first row are analyzed for total PCBs and if all analytical results are below 1 ppm, then no further action is required. If one or more soil samples in the first row contain PCBs in an amount greater than or equal to 1 ppm, then all soil




samples in the second row are analyzed. If one or more soil samples in the second row contain PCBs in an amount greater than or equal to 1 ppm, then all soil samples in the third row are analyzed. If one or more soil samples in the third row contain PCBs in an amount greater than or equal to 1 ppm, then further delineation will be performed. For a complete description of soil sampling procedures, refer to Appendix J. Where soil sampling documents the presence of soils with total PCB concentrations above the applicable comparison criteria of 1 ppm, unless the area is well vegetated and inaccessible to the public and school children, a geotextile overlaid by a four-inch thick layer of wood chips/mulch is placed to isolate the soil pending remediation. Remediation is performed by removing and disposing off-site the top two (2) feet of soil from PCB-impacted areas. Post-excavation samples are collected from the base of the excavation at a minimum frequency of one sample per 400 square feet or one sample per 20 linear feet. Sidewall samples are also collected once every 20 linear feet. Additional excavation and post-excavation confirmatory soil sampling may be necessary if the initial post-excavation soil sample results indicate PCB concentrations in the remaining soil are greater than 1 ppm. After all PCB-impacted soil has been removed the excavation is backfilled with environmentally clean fill material. If PCB concentrations in post-excavation samples are greater than 1 ppm, but less than 10 ppm, at a depth greater than two feet, the excavation may be backfilled and properly compacted. Any areas where PCB concentrations in the soil exceed 1 ppm after excavation should be included in a deed restriction in accordance with 40 CFR 761.61(a)(8) and all applicable state and local regulations. If PCB concentrations in soil exceed 10 ppm and cannot be removed by further excavation, the USEPA will be contacted for further coordination. 4.8.2 Assessment


Excavation of PCB-impacted soil offers the greatest protection to human health and to the environment because the PCBs in soil are removed and disposed of. Since soil impacted with PCBs is removed and replaced with environmentally clean soil, there is no remaining risk associated with direct contact, ingestion, or inhalation. 4.8.2.2 Compliance with Comparison Criteria

Full compliance with the applicable comparison criteria is expected from soil samples collected after the remediation has been performed. Remediating outside areas is not anticipated to have a significant impact on the levels of PCBs found in the interior caulk, air, or surfaces. 4.8.2.3 Long-Term Effectiveness and Permanence

By removing all soil with concentrations at or above the comparison criteria, the risks of direct contact, ingestion, or inhalation of PCBs from the soil will essentially be eliminated and no additional controls will be necessary. 4.8.2.4 Reduction of Toxicity, Mobility or Volume Through Treatment

Remediating the outside area reduces the total volume, toxicity, and mobility of PCBs by removing impacted soil for off-site disposal. This alternative addresses the preference for using treatment as a principal element because the risks are addressed by removing and replacing the contaminated soil.




4.8.2.5 Short-Term Effectiveness

When implementing this alternative, there is a need to control dust and disturbed soil adequately to prevent the risk of inhalation or direct contact to the community (i.e., the school population and general public). This risk can be contained by using good housekeeping practices and implementing adequate dust suppression, soil stockpiling, and storm water management measures when implementing this alternative. Workers can be readily and adequately protected from PCBs during the implementation of this alternative through the use of appropriate personal protection equipment and implementing other health and safety measures. The equipment needed to implement this alternative is readily available and relatively inexpensive. It is expected that there will be no significant adverse impacts to the environment associated with implementing this alternative. 4.8.2.6 Ease of Implementation

This alternative is moderately easy to implement and, with appropriate planning and resources, can be implemented in a particular school in a reasonable timeframe (e.g., considering investigation, design, approvals and summer implementation). Through procedures described in the CAFO, the City would obtain prior approval from the USEPA to routinely implement this remedial alternative. The effectiveness of this alternative can be monitored through the course of the work and confirmed by post-excavation confirmatory sampling. If sampling results indicate more action is needed, additional work can be performed at that time. 4.8.2.7 Cost

The cost to implement this remedy is relatively expensive but has low operation and maintenance costs. Because all soil with concentrations of PCB at or above the comparison criteria is removed, any remaining soil does not require any special training, handling or disposal if disturbed. Work must be performed when school is not in session (e.g., summer break, weekends, holidays, etc.) in non-winter periods, so short implementation cycles provide more opportunities to implement the remedy with a reduced likelihood of disrupt normal school activities. This alternative has a moderate potential to disrupt normal school activities because of the time it would typically take to complete.




5.0 PROPOSED PILOT PREFERRED REMEDY

The purpose of this Feasibility Study (FS) is to evaluate the remedial alternatives to address PCB Caulk, outside exposure areas, and PCB light ballasts and fixtures with consideration of the methods and products utilized, affects of remedial alternatives on post-remediation PCB concentrations, reducing human exposure to PCB sources, short-term and long-term effectiveness, cost, labor requirements, length of implementation, potential to disrupt normal school activities, and other relevant factors in primary, transitory and outside exposure areas (defined in Section 1.2.5). As part of the RIR, this Feasibility Study (FS) has been prepared to present the results of an evaluation of the potential remedial actions to address PCB Caulk and present the proposed Pilot Preferred Remedy based on the Pilot Study results completed to date at these five Pilot School Buildings.

This proposed Pilot Preferred Remedy has been selected following the analysis of several alternatives to address a broad range of factors encompassing statutory requirements and other fundamental considerations with the goal of selecting the most appropriate remedial alternatives. The proposed Pilot Preferred Remedy, as supported by the companion Remedial Investigation Report, is as follows:

• The Pilot Study evaluated five (5) remedial alternatives with respect to interior caulk: (1) Patch and repair of caulk at P.S. 178X/176; (2) Encapsulation of caulk at P.S. 309K; (3) Removal of all caulk and replacement with new non PCB-containing caulk at P.S. 199M; (4) Window frame and caulk removal and replacement with new window frames and non PCB-containing caulk at P.S. 183Q; and (5) Best Management Practices at all Pilot School Buildings. Based on the current data, each of these alternative remedial approaches has been shown to be effective at reducing potential exposures to interior PCB caulk in the Pilot School Buildings. Accordingly, the alternative remedial approaches implemented at each Pilot School Building for interior caulk should remain in place and continue to be evaluated pursuant to the USEPA-approved long-term monitoring plan.

• The Pilot Study determined that the replacement of PCB light ballasts and associated fixtures is a successful remedial measure for lowering PCB levels in indoor air where concentrations exceed the USEPA air guidance values. Light fixture replacements were implemented at P.S.309K, P.S. 178X/176, and P.S. 199M as supplemental remedial measures, and at P.S. 3R as the primary remedial measure. Light fixture replacement is effective where a supplemental remedy is necessary, and also as a primary remedial measure. Accordingly, the Pilot Preferred Remedy includes light fixture replacement at the Pilot School Buildings. Light fixture replacement will be implemented at P.S. 183Q in accordance with the Greener, Healthier Schools for 21st Century and Energy Savings Performance Contracting (ESPC) program.

• PCB contamination of soil encountered in Outside Exposure Areas at P.S. 199M, P.S. 178X/176 and P.S. 309K was successfully mitigated through the process of delineation, excavation, and off-site disposal. The PCB contaminated soil identified in the outdoor exposure areas at P.S. 183Q and P.S. 3R should be excavated and disposed utilizing these same protocols. Create a Soil Remediation Plan for USEPA approval and remediate soils above 1 ppm by excavation and off-site disposal, and obtain confirmatory post-excavation soil results. Backfill with clean fill and reestablish surface features. Exterior caulk at the Pilot School Buildings should be periodically inspected and be repaired to the extent it becomes damaged or deteriorated.




This proposed Pilot Preferred Remedy offers a reasoned approach to efficiently manage PCB Caulk, PCB light ballasts and associated fixtures, and contaminated surface soils in Outside Exposure Areas, at the Pilot School Buildings. This proposed Pilot Preferred Remedy is subject to USEPA review and possible modification prior to approval. In addition, the Pilot Preferred Remedy is subject to modification based on the results of ongoing and future Pilot Study activities to be reported in Supplemental Reports to this RIR.




6.0 REFERENCES

1. NYCDOH 2009. Fact Sheet: PCBs in Building Caulk, NYC Department of Health and Mental Hygiene, August 2009.

2. NYS OGS 2009. Standard Specification Section 028433 Abatement Of PCB Containing Caulk-Sealant Materials, New York State Office of General Services, updated October 15, 2009, (Http://www.Ogs.State.Ny.Us/Dnc/Generalinfo/Masterspecmf04/Html/028433.Htm).

3. NYSED 2007. Protocol for Addressing Polychlorinated Biphenyls (PCBs) in Caulking Materials in School Buildings, New York State Education Department June 18, 2007 press releases (http://www.emsc.nysed.gov/facplan/HealthSafety/PCBinCaulkProtocol-070615.html)

4. SCA 2011. Draft Best Management Practices for PCB Caulk in New York City School Buildings, June 15, 2011.

5. TRC 2011. Interim Remedial Investigation Report, June 15, 2011.

6. U.S. EPA Not Dated. PCBs in Caulk – QA. (http://www.epa.gov/pcbsincaulk/caulk-faqs.pdf)

7. U.S. EPA 1989. Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA, October 1989 by the EPA Office of Emergency and Remedial Response.

8. U.S. EPA 1990. Fact Sheet: The Feasibility Study: Detailed Analysis of Remedial Action Alternatives¸ March 1990 by the EPA Office of Emergency and Remedial Response.

9. U.S. EPA 2009. Public Health Levels for PCBs in Indoor School Air. Last updated on Friday, September 25, 2009 (http://www.epa.gov/pcbsincaulk/maxconcentrations.htm).

10. U.S. EPA 2009b. EPA model “PCB Exposure Estimation Tool” This Excel model was last revised on October 2, 2009 by the EPA Office of Research and Development National Center for Environmental Assessment.

11. U.S. EPA 2010a. Consent Agreement and Final Order, Docket Number TSCA-02-2010-9201, U.S. EPA January 19, 2010.

12. U. S. EPA 2010b. PCBs in Caulk in Older Buildings. Last updated on Friday, February 12, 2010 (http://www.epa.gov/pcbsincaulk/#testing).

13. U.S. EPA 2010c. Proper Maintenance, Removal, and Disposal of PCB-Containing Fluorescent Light Ballasts, A Guide for School Administrators and Maintenance Personnel, issued December 29, 2010 (http://www.epa.gov/epawaste/hazard/tsd/pcbs/pubs/ballasts.htm).

final pcb pilot study feasibility study 01-31-12 changes

Documents