PCBs: To Test or

Not to Test?

Triumvirate Environmental’ s

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Meet Your PresenterCraig Sasse has been employed at

Triumvirate for over 6 years and has worked

as an environment consultant for over 18

years. He currently specializes in performing

environmental consulting and engineering

services to assess, manage and mitigate

environmental liability. He has worked as a

consultant on numerous PCB-related

projects for organizations and institutions up

and down the east coast.

Building materials,

particularly caulking,

may contain PCBs.

The EPA, under TSCA,

considers PCB-

contaminated building

materials and

“unauthorized use” and

is subject to regulation.

Although testing of building

materials is not required, finding

PCB contamination and conducting

required remediation can

significantly alter projects.

Background1930s

Negative health impact documented

1950s

Widely manufactured and used in industry

Discover that PCBs may affect skin, liver, immune

system and mire

1976

TSCA enacted

Why PCBs Were Used in

Building Material:

Stability

Fire resistance

Durability

Materials Found

to Contain PCBs

Transformers

Caulk

Adhesives

Light Ballasts

Paint

Window Glazing

PCBs Spread

Migration

Volatilization

Impact of Finding PCBs

Public school buildings where

PCB contamination is found

has been widely publicized.

The health risks from PCBs to

children has prompted the EPA

to prioritized PCB management

in schools.

The private sector undergoes

far less scrutiny and publicity

but still has to manage the

same underlying issues.

Examples:

NY Public School

Sampling prompted by concerned citizens first identified

contamination in caulking.

Hundreds of building with the potential for PCBs to be present

Working with the EPA, Management continues with ballast

removal anticipated to be completed by the end of 2016

Lexington Public School

Contamination discovered in the air

Sampling identified many materials and surfaces with PCBs

Due to health concerns and costs a new school building was constructed in 2014 and the old building demolished.

Changing PCB Landscape

2012: EPA Provides TSCA Reinterpretation

“Remediation Waste” to “PCB Bulk Product”

Accelerated Clean Ups

Competing

Interests

Owner/ManagerConstruction

IndustryConsultants

Regulators Attorneys

Pre-Construction

Assessment Approaches

Sample All Suspect Materials

Assume Contamination

Ignore the Possible Dangers

A key first step is to get

educated about the issue.

Find a knowledgeable

person to assist with your

organization and develop a

tailored strategy for

management.

Steps to TakeDiscovering the best course of action for your organization

Inventory Suspect Buildings

Are your buildings of the PCB pedigree?

When were they constructed or

renovated?

Do you have potential PCB

containing equipment at your

buildings.?

Best Practices for Staff

Know who may be working near these

materials

Custodians may need to adjust

cleaning techniques - use HEPA vacuums

and damp wiping.

Pre-Construction

Reviews

Will work disturb suspect material?

Know the consequences if

sample results come back positive

Include stipulations in the bid

PCBs: Community

School System

Case Study

PCB identified by others in caulking for

more than 50 buildings

Negotiated with EPA to prioritize efforts to

assess

Comprehensive inventory and prioritization

Focus efforts to reduce exposures by

abatement, encapsulation and

BMPs

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