In 2012, several school renovation projects were hindered by caulk. The reason: PCBs.
In Connecticut, the towns of Southington and Fairfield discovered PCBs in the window caulking of their middle school and high school, respectively. In both cases, the discovery led to an unexpected increase in cost. The clean-up can also be confusing, since PCBs leach from caulk into surrounding porous building materials, including masonry, wood, and concrete. In October, the USEPA issued a reinterpretation of PCB Bulk Product Waste, specifically to address this issue.
PCBs, short for Polychlorinated Biphenyls, were commonly used in electrical equipment and building materials, until Congress banned manufacture of the toxic chemical in 1979. PCBs were used in caulk to impart flexibility, and can still be present in buildings constructed or renovated in the 1950s through the 1970s. The USEPA states that caulk containing PCBs at levels ≥ 50 parts per million (ppm) must be removed. When disposed, the caulk is to be managed as PCB Bulk Product Waste.
Now, here’s the tricky part. Because PCBs in caulk are known to contaminate adjacent building material, any surrounding building material that is coated by ≥ 50 ppm PCB-containing caulk is also considered PCB Bulk Product Waste if the caulk is still attached to the building material at the time of designation for disposal. To quote the EPA: “if your abatement plan states that you intend to dispose of the PCB caulk and any contaminated building materials together and the PCB caulk becomes separated from the adjacent contaminated building materials during remediation, you may still dispose of all the materials as a PCB Bulk Product Waste.” The plan is what’s important, not what happens between the building and the dumpster. If the caulk and building material are disposed of separately, then the building material is managed as a PCB Remediation Waste. The respective disposal options are outlined here.
With all the nitty gritty of disposal regs, it is easy to lose sight of the big picture: how to minimize exposure to PCBs, especially in schools. Air monitoring in affected schools can determine the inhalation exposure. Diligent housekeeping can minimize ingestion exposure. Encapsulation is effective at very low levels. Ultimately, all PCB-containing caulk should be removed.
Have you discovered PCBs in caulk during renovations, or gotten tangled up in disposal questions? Leave a comment below, or feel free to contact me at Sszymanski@repsg.com. Happy 2013!