What You Need to Know about Managing PCBs in Construction Materials – An Emerging Environmental Issue
One hundred million dollars: that’s the estimated average potential environmental clean-up liability for a typical large academic research institution1 – all from a single emerging environmental issue – polychlorinated biphenyls, commonly known as PCBs. PCB-containing building products, commonly in use during the 1960’s and early 1970’s, now pose a potential expensive problem for owners of buildings constructed during that period.
PCBs are a familiar environmental hazard. Excessive or repeated exposure to elevated levels of PCBs has been reported to be associated with a variety of environmental and human health effects2.
A study published in 2004 found that 1/3 of buildings in Greater Boston contained caulking with high levels of PCBs3, well above allowable limits set by the U.S. Environmental Protection Agency (EPA). Based on data provided by the National Institute for Occupational Safety and Health (NIOSH), the “peak” production years for PCB–laden caulking were from the 1960’s through the early 1970’s4. Buildings constructed or renovated during this period are at risk for having PCB-laden caulking. U.S. Census Bureau figures for this time frame indicate that construction of private and public educational buildings totaled approximately $335.8 billion5.
Some PCB-containing building products (primarily caulking materials) must be removed and disposed of as hazardous waste which adds to the cost of remediation. Additionally, all building components that were in contact with the caulking may require further, more invasive cleaning and restoration efforts. U.S. environmental regulations classify PCB products containing greater than 50 parts per million as “unauthorized”, making their continued use illegal. These remediation requirements, especially the removal of surrounding “contaminated” materials, can be costly and disruptive. Based on experiences from prior projects, EH&E estimates that abatement costs associated with the removal and disposal of PCBs as required by the EPA average $15 - $18 per square foot per building. Costs may vary based on window and/or façade construction and the concentration of PCBs found at the building.
The “discovery” of PCBs in building materials occurs during indoor air quality studies or once a façade restoration or weatherization project has been contracted. These discoveries result in costly project change orders that impact the project timeline and that significantly increase the costs associated with the project. Public relations and occupant concerns are also very real challenges that must be carefully managed once PCB products are found in buildings.
In September 2009, EPA issued guidance to building owners and school administrators on reducing the potential for exposure to PCBs emanating from contaminated caulk in buildings constructed and renovated from 1950 to 1978. By issuing this guidance, the EPA has put the real estate industry and building managers on notice regarding the presence of these compounds and may have established a new “duty of care” for people and entities responsible for buildings. Although the guidance is reasonable at face value, it can inadvertently trigger some very onerous remediation burdens if management procedures are not appropriately initiated. Before considering implementation of this guidance, owners and managers should carefully consider the financial and legal implications of their actions, as they can significantly impact:
- Discovery and occupant / tenant notification,
- Reporting to public regulatory agencies,
- Investment and property valuation,
- Corporate financial disclosure and reporting, etc.
EH&E recommends the following proactive steps for all construction projects on buildings constructed and / or renovated from 1950 to 1978:
Perform a Pre-Test Risk Assessment
By carefully evaluating the age, type, and renovation history of the existing structure, an assessment can be made of what materials in the structure should be tested for PCBs, or whether material testing is required at all. This assessment can often save the owner time and money by limiting or eliminating the need for expensive testing.
Carefully Design the Materials Testing Protocol
If materials testing is warranted, a review of the testing protocol and the results by a knowledgeable expert can potentially save the owner a great deal of time and money. The experience of the University of Massachusetts on a project provides a useful illustration of this point. Random testing results from a large multi-wing facility were initially interpreted as requiring remediation of all caulking. Subsequent evaluation of the results by EH&E showed that in fact, two wings of the structure were built at a later period and test results actually indicated no remediation was necessary in these areas. The review saved the university approximately $2.5M. EH&E scientists and engineers have pioneered new screening and testing protocols that can rapidly provide useful information that can help guide less costly and invasive testing protocols.
Get Help with Remediation Project Design
When remediation of PCB–contaminated materials is warranted, EH&E recommends a knowledgeable review of the remediation approach prior to implementation. Regulatory requirements call for removal of all PCB–containing materials and the removal or encapsulation of PCB-contaminated materials. Building masonry that comes in contact with caulking will often become contaminated to various degrees based on the porosity of the material. Carefully analyzing the extent of the contamination can often make a significant difference in removal or encapsulation effort and cost. Wholesale removal of sections of a façade may be avoided by accurately determining the extent of PCB penetration, which can significantly reduce the cost of remediation. Furthermore, alternative project designs, that still comply with regulatory guidance, may then be negotiated with major savings of time and project costs.
Keep Building Occupants and Regulators Informed
Should testing determine that building materials require removal, keep tenants and regulators in the loop. Inform regulators of your activities and share both the testing protocol and the final remediation plans. Keep tenants informed of the precautions in place to protect them from exposure during the remediation process.
PCB-containing building materials represent a newly discovered and significant liability for building owners and contractors. The regulation-driven remediation efforts can dramatically impact the cost of renovation or demolition, easily costing millions of dollars for a single project and have major impacts on the scheduling of projects. Building owners must educate themselves on both the legal implications and on the best ways to minimize their risk and the overall costs to remediate.
This article is an excerpt from a white paper published by EH&E. The complete white paper is available at: http://www.eheinc.com/PCB_construction.htm.
- Based on an average of 10 million square feet and $15 per square feet of remediation cost, estimating that 60% of building stock is potentially vulnerable based on age of construction and rehabilitation practices.
- Agency for Toxic Substances and Disease Registry (ATSDR). ATSDR. 2000.Toxicological Profile for Polychlorinated Biphenyls. Atlanta, GA: Agency for Toxic Substances and Disease Registry.
- Herrick RF, McClean MD, Meeker JD, Baxter LK, Weymouth GA. 2004. An Unrecognized Source of PCB Contamination in Schools and Other Buildings. Environmental Health Perspectives 112(10):1051–1053.
- National Institute for Occupational Safety and Health (NIOSH). Current Intelligence Bulletin: Polychlorinated Biphenyls (PCBs). PCB Manufacture and Sales Monsanto Industrial Chemicals Company, 1965 Through 1975 (Thousands of Pounds).http://www.cdc.gov/niosh/78127_7.html#table3 Accessed December 2007.
- U.S. Census Bureau data on construction of public and private educational facilities, 1964 – 1975, values have been adjusted in terms of constant 2006 dollars. Statistics compiled by Margaret M. Parks, Maximilian P. Chang from data available at http://www.census.gov/const/C30/oldtc.html.
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