CHENOWETH LAB ADDITION (ROOM 219)
HEALTH & WELLNESS CENTER & ELECTRICAL UPGRADES
Prepared For:university of massachusetts
ENVIRONMENTAL HEALTH & SAFETY118 DRAPER HALL
40 CAMPUS CENTER WAY
AMHERST, MASSACHUSETTS 01003
February 1, 2011
PREPARED BY:ATC Associates, Inc.
73 William Franks Drive
West Springfield , MA 01089
Final Completion Report February 1, 2011
Chenoweth Lab Addition (Room 219)
University of Massachusetts
Amherst, Massachusetts
TABLE OF CONTENTS
1.0 INTRODUCTION…………………………………………………………..1
2.0 CHARACTERIZATION SAMPLING……………………………………..2
3.0 ABATEMENT ACTIVITIES………………………………………………2
4.0 PCB WIPE SAMPLING……………………………………………………4
5.0 WASTE DISPOSAL………………………………………………………..5
APPENDICES
Appendix A EPA Approved PCB Clean Up and Disposal Plan (6/25/10)
Appendix B PCB Analytical Results – Source Sampling
Appendix C PCB Confirmatory Wipe Sample Summary Report (Table 1.0)
Appendix D PCB Laboratory Results – Confirmatory Wipe Samples (9/21/10)
Appendix E PCB Laboratory Results – Confirmatory Wipe Samples (9/27/10)
Appendix F Waste Disposal Documentation
Page i
Final Completion Report February 1, 2011
Chenoweth Lab Addition (Room 219)
University of Massachusetts
Amherst, Massachusetts
1.0 INTRODUCTION
ATC Associates Inc. (ATC) has prepared this Final Completion Report for polychlorinated biphenyl (PCB) removal and disposal activities conducted at Chenoweth Labs (Room 219) at the University of Massachusetts at Amherst (“Site”).
Work was performed to support the Health and Wellness Center and Electrical Upgrade Renovation Project on behalf of Nault Architects Inc., the architect for the Project.
Investigations of glazing compound on five (5) windows to be replaced at Room 219 determined the material to contain PCB at levels in excess of applicable regulatory levels. Abatement specifications for these materials were prepared by ATC and distributed to the General Contractor, Souliere & Zepka Construction.
The abatement specifications included direction for abating, storing and disposing of PCB window glazing compound at the Site. Abatement and waste management activities occurred from September 14, 2010 to October 26, 2010.
This Final Completion Report provides concise documentation of the work completed. This document should be maintained by the building owner until the building is demolished. This report provides:
· Characterization sampling analytical results, accompanying analytical chains of custody, and field and laboratory quality control/quality assurance checks;
· A summary of abatement activities;
· Confirmation sampling analytical results, accompanying analytical chains of custody, and field and laboratory quality control/quality assurance checks; and
· Copies of waste disposal documentation and certificates of disposal issued by the disposer.
The window glazing compound was considered a PCB bulk product waste as defined under 40 CFR 761.3 and has a no authorized use limitation under EPA Regulations. The glazing compound was removed and disposed of in accordance with 40 CFR 761.62. The window frame adjacent to the window glazing compound was decontaminated via an alternative standard under 40 CFR 761.61(a) (4) which is based on visual removal and post decontamination surface wipe sampling.
Prior approval from the United State Environmental Protection Agency (EPA) was required for completion of the work. Refer to Appendix A for the PCB Clean Up and Disposal Plan submitted and approved by the EPA Region I Office dated June 25, 2010.
2.0 CHARACTERIZATION SAMPLING
This section provides a summary of Site characterization sampling activities, analytical results, and accompanying laboratory quality control/quality assurance checks.
2.1 Initial Source Sampling
On March 24, 2010, ATC collected two (2) samples of window glazing from Room 219 for PCB analysis. All samples were transported under chain of custody to New England Testing Laboratory, Inc. (NETLAB) for extraction by EPA Method 3540C (Soxhlet Method) and analysis of PCB via EPA method 8082.
PCBs were detected at or above 50 parts per million (ppm) in both glazing samples (CH-01 and CH-02). 50 ppm is the TSCA regulatory threshold for a PCB Bulk Product Waste as defined by 40 CFR 761. Therefore, the glazing compound was required to be removed and disposed in accordance with TSCA.
There was also one (1) sample collected on the exterior vent caulking (CH-03) which was also subject to be removed and replaced as part of the renovation work. The analytical result indicated the caulking was not at or above the associated TSCA defined level of 50 ppm that would characterize this material as a PCB Bulk Product Waste. The vent caulking was a different color and textured as compared to the window glazing compound and its use was different from the uses where the glazing compound was found to contain PCB’s. Furthermore,
there was no evidence of a spill or release of PCB oil at this location. Therefore, the detectable concentration of PCB’s in the caulking was most likely a result of the manufacturing process and the material is considered an “Excluded PCB Product” under 40 CFR 761.3 (iii).
Refer to Appendix B for a copy of the PCB laboratory analytical results.
3.0 ABATEMENT ACTIVITIES
This section provides a summary of PCB abatement site activities.
3.1 Window Glazing Abatement
PCB window glazing compound was removed from the five (5) window units at Room 219 on September 15, 2010. The following work activities were adhered to as outlined in the approved PCB Cleanup and Disposal Plan dated June 25, 2010:
· Prior to masking and sealing operations which designated the PCB containing material removal work area, windows, doors, openings, ducts, drains, and vents were masked and sealed with a minimum of one layer of six mil polyethylene sheeting. Voids in the walls, ceiling, or roof systems were sealed with fire retardant spray foam. In addition, the exterior sides of the windows were also sealed with one layer of six mil polyethylene sheeting for the duration of the entire remediation project.
· Full enclosure procedures were implemented for the work site. The work area entrances outside the actual enclosure were posted with warning signs and barricade tape. The work area was completely isolated from other parts of the building which included the interior and exterior sides of the window, so as to prevent PCB containing dust or debris from passing beyond the isolated area. All surfaces within 20 feet to each side of the window units to be abated were HEPA vacuumed and wet wiped prior to the installation of plastic sheets. Floors were masked and sealed with two layers of six mil plastic sheeting with a minimum overlap of two feet at seams and up the walls. Walls were covered with two layers of six mil polyethylene sheeting arranged so each layer overlaps on the outside of the respective layer of floor polyethylene sheeting that has been run up the wall.
· A Decontamination Chamber was constructed directly attached to the enclosure and the containment was then placed under negative pressure after masking and sealing was completed.
· The containment remained up during all phases of the remediation project and was not torn down until clearance criteria were met.
· DOT-approved steel container was used for the collection of PCB wastes generated during the work activities in accordance with 40 CFR 761.65.
· The remaining glazing compound on the frame was removed using a combination of mechanical and physical means and disposed of in the same drum. All containers were properly labeled and marked in accordance with 40 CFR 761.40.
· Upon completion of removal activities, the frames were visually inspected for the presence of any residual glazing compound. If residual glazing compound was observed, then additional cleaning was performed.
· Containerized waste was removed from the work area through the decontamination chamber.
· All tools and equipment were removed from the work area and decontaminated in the decontamination chamber. Cloth, mops and other cleaning aids were disposed of as PCB containing waste material.
· The Contractor then cleaned the window frame using a double wash/rinse to meet the cleanup standards under 40 CFR 761.61(a) for non-porous surfaces. Precautionary measures were implemented to contain any runoff resulting from the cleansing and to dispose of wastes generated during the cleansing.
· After completion of the cleaning by the Contractor, ATC personnel performed PCB clearance wipe sampling. A minimum of three samples per window and a field blank were collected per 40 CFR 761.123 Standard Wipe Tests for spills of high-concentration PCBs on solid surfaces. All samples were collected and transported to the laboratory to be extracted/analyzed using EPA Methods 3540C/8082. The clearance criteria established was ≤ 10 µg / 100 cm2 for each wipe sample. If laboratory results exceeded this standard, the entire window would be recleaned using a double wash/rinse and the clearance wipe sampling was repeated.
· All PCB containing glazing compound, window panes/glass and associated wastes were disposed of as PCB Bulk Product Waste in accordance with 40 CFR 761.62.
· All containers were properly labeled and marked in accordance with 40 CFR 761.40
· Upon completion of the work, the PCB bulk product waste was transported under manifest, off-site for disposal to a TSCA approved landfill.
4.0 PCB WIPE SAMPLING
This section summarizes the post remediation testing performed to ensure compliance with the approved PCB Clean Up and Disposal Plan dated June 25, 2010:
4.1 Confirmatory Wipe Sampling
A total of three (3) wipe samples per window unit were collected upon completion of the remediation work. The samples were collected from the remaining non-porous window frames where the PCB-containing glazing compound was removed.
Wipe samples were collected per standard wipe test protocols in accordance with 40 CFR § 761.123 utilizing the applicable procedures identified in Wipe Sampling and Double Wash/Rinse Cleanup as Recommended by the Environmental Protection Agency PCB Spill Cleanup Policy (June 23, 1987 Revised and Clarified on April 18, 1991). A one-use template was used to delineate the 100 cm2 sampling area.
ATC’s initial sampling performed on September 15, 2010 indicated all fifteen (15) samples collected to yield results above 10µg / 100 cm2. Refer to Appendix C (Table 1.0) for a summary of the PCB wipe sample results and Appendix D for a copy of the PCB Laboratory Report (dated 9/21/10).
Based upon those results, the Contractor then initiated a 2nd cleaning of the window frames and containment area.
On September 22, 2010, ATC collected a 2nd set of wipe samples from the five (5) window units after re-cleaning was completed by the Contractor. Results indicated all fifteen (15) sample to yield None Detected. Refer to Appendix C (Table 1.0) for a summary of the PCB wipe sample results and Appendix E for a copy of the PCB Laboratory Report (dated 9/27/10).
The subsequent data indicated that the remaining window frames did not contain residual PCB limits above the associated laboratory detection limits and the abatement work considered complete.
4.2 Laboratory QA/QC
All laboratory PCB was performed in accordance with EPA preparation and analytical methods. Samples were analyzed for PCBs following EPA Method 3540C for Soxhlet extraction and Method 8082 for analysis. ATC reviewed the Report of Analytical Results and concluded that all data is usable.
5.0 WASTE DISPOSAL
PCB containing waste generated at the Site included window glazing compound and associated materials. Waste was placed into a DOT-approved steel container that was double lined with 6 mil polyethylene sheeting inside the work area and transported to the on-Site waste storage container.
A total of five (5) kilograms of PCB containing waste was transported from the Site on October 21, 2010. The material was transported utilizing a Uniform Hazardous Waste Manifest from the site to ENPRO Services of Vermont, Inc. located in Williston, Vermont for final disposition. The associated shipping and disposal documents are included in Appendix G.
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APPENDIX A
EPA APROVED PCB CLEAN UP AND DISPOSAL PLAN (6/25/10)
APPENDIX A
APPENDIX B
PCB ANALYTICAL RESULTS – SOURCE SAMPLING
APPENDIX B
APPENDIX C
PCB CONFIRMATORY WIPE SAMPLING SUMMARY REPORT
(TABLE 1.0)
APPENDIX C
TABLE 1.0CHENOWETH HALL (ROOM 219)
PCB CONFIRMATORY WIPE SAMPLE SUMMARY REPORT
SAMPLE # / DATE COLLECTED / MEDIA / LOCATION / RESULTS
(Ug/cm2) / AROCLORS / DETECTION LIMIT
CH-01 / 09/15/10 / Wipe Sample / Field Blank / None Detected / - / 1.0
CH-02 / 09/15/10 / Wipe Sample / Window Unit No. 1 / 21.6 / 1254, 1262 / 1.0
CH-03 / 09/15/10 / Wipe Sample / Window Unit No. 1 / 21.3 / 1254, 1262 / 1.0
CH-04 / 09/15/10 / Wipe Sample / Window Unit No. 1 / 10.9 / 1254, 1262 / 1.0
CH-05 / 09/15/10 / Wipe Sample / Window Unit No. 2 / 13.6 / 1254, 1262 / 1.0
CH-06 / 09/15/10 / Wipe Sample / Window Unit No. 2 / 13.8 / 1254, 1262 / 1.0
CH-07 / 09/15/10 / Wipe Sample / Window Unit No. 2 / 20.1 / 1254, 1262 / 1.0
CH-08 / 09/15/10 / Wipe Sample / Window Unit No. 3 / 22.7 / 1254, 1262 / 1.0
CH-09 / 09/15/10 / Wipe Sample / Window Unit No. 3 / 42.8 / 1254, 1262 / 5.0
CH-10 / 09/15/10 / Wipe Sample / Window Unit No. 3 / 74.0 / 1254, 1262 / 5.0
CH-11 / 09/15/10 / Wipe Sample / Window Unit No. 4 / 170 / 1254 / 10.0
CH-12 / 09/15/10 / Wipe Sample / Window Unit No. 4 / 12.6 / 1254, 1262 / 1.0
CH-13 / 9/15/10 / Wipe Sample / Window Unit No. 4 / 15.0 / 1254, 1262 / 1.0
CH-14 / 09/15/10 / Wipe Sample / Window Unit No. 5 / 68.0 / 1254 / 5.0
CH-15 / 09/15/10 / Wipe Sample / Window Unit No. 5 / 11.4 / 1254, 1262 / 1.0
CH-16 / 09/15/10 / Wipe Sample / Window Unit No. 5 / 16.6 / 1254, 1262 / 1.0
CHLR-01 / 09/22/10 / Re-Wipe Sample / Field Blank / None Detected / - / 1.0
CHLR-02 / 09/22/10 / Re-Wipe Sample / Window Unit No. 1 / None Detected / - / 1.0
CHLR-03 / 09/22/10 / Re-Wipe Sample / Window Unit No. 1 / None Detected / - / 1.0
CHLR-04 / 09/22/10 / Re-Wipe Sample / Window Unit No. 1 / None Detected / - / 1.0
CHLR-05 / 09/22/10 / Re-Wipe Sample / Window Unit No. 2 / None Detected / - / 1.0
CHLR-06 / 09/22/10 / Re-Wipe Sample / Window Unit No. 2 / None Detected / - / 1.0
CHLR-07 / 09/22/10 / Re-Wipe Sample / Window Unit No. 2 / None Detected / - / 1.0
CHLR-08 / 09/22/10 / Re-Wipe Sample / Window Unit No. 3 / None Detected / - / 1.0
CHLR-09 / 09/22/10 / Re-Wipe Sample / Window Unit No. 3 / None Detected / - / 1.0
CHLR-10 / 09/22/10 / Re-Wipe Sample / Window Unit No. 3 / None Detected / - / 1.0
CHLR-11 / 09/22/10 / Re-Wipe Sample / Window Unit No. 4 / None Detected / - / 1.0
CHLR-12 / 09/22/10 / Re-Wipe Sample / Window Unit No. 4 / None Detected / - / 1.0
CHLR-13 / 09/22/10 / Re-Wipe Sample / Window Unit No. 4 / None Detected / - / 1.0
CHLR-14 / 09/22/10 / Re-Wipe Sample / Window Unit No. 5 / None Detected / - / 1.0
CHLR-15 / 09/22/10 / Re-Wipe Sample / Window Unit No. 5 / None Detected / - / 1.0
CHLR-16 / 09/22/10 / Re-Wipe Sample / Window Unit No. 5 / None Detected / - / 1.0
APPENDIX D