020890 PCB Abatement Procedures.pdf

Robert C Weaver Federal Building, Granite Façade Repairs, Phase 2 Washington, DC Project Number # VDC00213

PCB ABATEMENT PROCEDURES 020890-1

SECTION 020890 – PCB ABATEMENT PROCEDURES

PART 1 - GENERAL

1.1 DESCRIPTION OF WORK:

This section identifies the precautions and procedures required in the handling and disposal of small PCB items and lighting lamps that may contain or be classified as hazardous materials. It applies to the identification, removal, packaging, and transport of hazardous materials and Universal Wastes. It is possible that Polychlorinated Biphenyl (PCB) will be encountered during work activities.

A. For all caulking/waterproofing removal projects in buildings constructed prior to 1979, assume PCB contamination above 50 ppm. Testing of waste materials is not mandatory, but if no testing is conducted the waste must be classified per EPA as "PCB Bulk Waste". The project team has the option to test caulking, waterproofing materials, and waste generated for PCB content in accordance with 40 CFR 761. If the materials yield PCB levels below 50 ppm they can be disposed of as standard construction debris.

B. Manufacturers have labeled fluorescent light ballasts and electrical capacitors produced after1978 to indicate "NO PCB's". However, prior to 1978 the small electrical items such as capacitors and fluorescent light ballasts with dielectric fluid were not labeled to indicate the presence of polychlorinated biphenyl (PCB) content, and therefore all unmarked capacitors and ballasts shall be presumed to contain PCB’s. In many buildings, the light ballasts will have been replaced due to renovation or through attrition and it may not be possible to determine the percentage of replacement. Therefore, all unmarked ballasts will be considered to contain PCB’s and shall be managed as such.

C. Fluorescent and high intensity discharge lamps must be managed as Universal Waste and sent to a recycler or as Hazardous Waste if materials are not sent to a recycler. In addition, lamps that are broken or crushed must be managed as hazardous waste unless otherwise stated in local regulations.

D. The following procedures have been developed to assure proper recycling/disposal of small PCB items such as PCB ballasts:

Ballast Handling

1. Intact PCB-containing ballasts can be removed with a gloved hand and should also be immediately placed in a storage container.

2. Non intact, non PCB-containing ballasts should be handled with a gloved hand

3. Non intact, PCB-containing ballasts should not be handled by building personnel

4. Intentional breaking or dismantling of ballasts is prohibited

Ballast Storage

1 Each ballast container should be labeled properly.

2 In DC and VA the PCB ballast labels must read “hazardous waste PCB-containing ballasts” and the date the first ballast was placed in the container.

3 In MD PCB ballast labels must include “Universal Waste- PCB ballasts” and the date the first ballast was placed in the container.

4 Waste ballast containers should consist of closable container capable of containing spills of ballast dielectric fluid.

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5 Storage containers of ballasts should be placed in a designated accumulation point(s). The accumulation point(s) should be:

6 Located indoors 7 Isolated from foot traffic 8 Not near floor drains or other potential escape routes to environment 9 Storage of PCB ballasts in MD should not exceed one year. Use the dated labels as indicators of time onsite.

10 PCB-containing ballasts are a hazardous waste in VA and DC. Facilities with small quantities are considered Categorically Exempt Small Quantity Generators (CESQG) and have no limit on storage time but have a limit of generating less than 220 lbs per month with a max accumulation limit of 2,200 lbs at any given time. ( it is recommended that building dispose of all hazardous waste at least annually)

11 All damaged and/or leaking light ballasts are to be handled as hazardous waste using the procedures outlined herein.

12 A representative sample of all fluorescent and high intensity discharge lamps must be tested by the toxicity characteristic leaching procedure (TCLP) test to determine if they must be managed as hazardous (greater than 0.2 milligrams of mercury per liter of leachate). Lamps that are not adequately tested must be managed as hazardous.

E. The following procedures have been developed to assure proper handling and recycling of mercury containing lamps:

Lamp Handling

1 Lamps should be GENTLY removed from fixtures intact 2 Handle carefully and prevent breakage 3 Any break in a lamp will allow mercury vapor to escape 4 Lamps should not be leaned against walls during bulb replacement 5 Lamps should be immediately transported to storage container

Lamp Storage

1. Lamps should be packed in container with a label that includes “Universal Waste- Lamps” and the date the first bulb was placed into the container

2. Container must be sealed and be able to reasonably contain broken lamps. Acceptable storage containers include:

Original shipping box with seams sealed with tape

Recycling shipping box with seams sealed with tape

Metal, plastic, or Fiberboard drum with sealable lid

All stored lamps should be sealed in storage containers (lid closed or box fully taped up).

3. Storage containers of waste lamps should be placed in a designated accumulation point(s).

The accumulation areas should be:

Isolated from foot traffic

Dedicated to lamp storage

Managed in a manner to minimize risk of lamp breakage

4. Storage of waste lamps CANNOT exceed one year

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1.2 SCOPE OF SERVICES

A. General: This section indicates all work necessary to remove small PCB items in accordance with current environmental regulations. (It is the responsibility of the contractor to ensure that their standard operating procedures comply with applicable regulations and this document all discrepancies should be discussed with Contracting Officer)

1. Requirements: Refer to the Environmental Hazards Report in the Appendix

2. Work Area: The work area includes all sealant materials within the stone façade areas being removed.

B. Related Work Specified in Other Sections: Section 015950, "Safety and Health" applies to all work covered by this section.

1.3 QUALITY ASSURANCE:

A. Contractor Qualifications: The Contractor shall be a firm of established reputation, or if newly organized, whose personnel have previously established a reputation in the same field. To be considered, the Contractor shall maintain a regular work force that is commonly engaged in the removal, packaging and transporting of PCB items and lamps. Personnel shall have performed this work on previous projects in order to demonstrate experience.

B. Sampling for PCB’s:

1 Perform Prealteration Assessments for PCB as required and provide reports.

2 If contamination is restricted to the light fixture, the entire fixture should be treated as PCB contaminated.

3 If surfaces below the light fixture are suspected of being contaminated, the contractor is responsible for proper clean-up of the area. The Contractors plan of action and procedures must be submitted to and accepted by the Contracting Officer (CO) prior to beginning work.

4 Wipe samples shall be collected following the EPA Field Manual for Grid Sampling of PCB Spill Sites to Verify Cleanup. Wipe samples are to be analyzed by a qualified laboratory accredited by the American Industrial Hygiene Association (AIHA) for organic materials analysis. The surfaces shall be cleaned to 10 micrograms of PCBs per 100 square centimeters of surface or less.

1.4 REFERENCES:

A. Code of Federal Regulations (CFR): Occupational Safety and Health Act (OSHA):

29 CFR 1910, OSHA, General Industry Standards 29 CFR 1926, OSHA, Construction Industry Standards 29 CFR 1910.120, OSHA General Industry, Hazardous Waste Operations Requirements

Environmental Protection Agency (EPA):

40 CFR 260-265, Resource Conservation and Recovery Act 40 CFR 300-399, EPA Comprehensive Environmental Response Compensation & Liability Act 40 CFR 761, Toxic Substances Control Act

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Department of Transportation (DOT):

49 CFR 171-180, DOT Hazardous Material Regulations 49 CFR Part 178, DOT Shipping Container Specification

B. State and Local Regulations:

1 Applicable state and local regulations may apply. Of particular note will be the requirements for licenses and permits, transportation and disposal of hazardous and or universal waste.

1.5 SUBMITTALS:

See Appendix A, GSA PCB Ballasts and Mercury Lamp Removal Project Control Checklist

A. Initial Contractor Submittals for PCB and lamp removal information: Items 1.5.A.1.a c may be submitted after bid receipt, but are required for approval by the CO prior to award.

1. Contractor Qualification Information:

a. Name and location of at least 2 PCB and/or mercury lamp removal projects performed by the Contractor; include names and telephone numbers of contract representatives.

b. Name and experience record of superintendent and foreman assigned to this project.

Include evidence of knowledge of applicable regulations. The supervisory personnel shall have a valid 40-hour OSHA Hazardous Waste Operation (HAZWOPER) certificate.

c. Name and experience record of personnel who will be assigned to this project. All personnel shall have a minimum of hazardous waste awareness training, and those personnel working with damaged, leaking ballasts, or cleaning contaminated surfaces shall hold valid 40-hour HAZWOPER training certificates.

B. Post Award Submittals for PCB and mercury lamp removal: Items 1.5.B.1 3 are to be submitted after the award, but are required to be approved by the contracting officer or his/her designated representative prior to starting work.

1. Plan of Action: Submit a detailed plan of the procedures proposed for complying with the regulations and requirements and this specification, the location and configuration of work areas where ballasts and/or lamps will be removed, and the waste storage locations. The waste storage shall either be a designated restricted access area, or an area isolated temporarily by use of plastic sheeting and signage. Include any other methods proposed to prevent accidental exposure and/or contamination to unrestricted areas of the building. The plan shall also identify the maximum number of debris-filled drums allowed on-site, the sequencing of removal work, and shall review the interface of other trades in the performance of work. Identify methods used to assure the safety of building occupants and visitors to the site, and the location of approved incineration or recycling facilities the contractor is intending to use. Expand upon the packaging of removed PCB items and mercury lamps. Obtain Contracting Officer approval of the plan prior to the commencement of work.

2. Contingency Plan: A contingency plan for responses to a suspected release of PCBs or mercury, such as leaking ballasts, etc. should be prepared. This should include notification of the CO, environmental testing, and clean up of any contamination resulting from contractor activities. The contingency plan shall include environmental sampling performed by an entity meeting the requirements specified in (40 CFR 761.130(e), & 761.120) compliance with all other environmental an OSHA standard applicable to the handling storage and proper disposal of PCB waste.

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3. Recycling/Disposal Plan: A plan that describes the methodology to be used and provides information on how the contractor is to proceed with activities outlined in the scope of work.

The plan must include, but not be limited to, the location of the EPA permitted recycling, treatment or disposal facility accepting waste, qualifications of transporters, methods of transport, and a description of the methods to be employed to prevent release to the environment. The contractor shall explain the method for documenting proper PCB disposal to the contracting officer or his designated representative.

C. During Work Submittals: Items 1.5.C.1 3 below are to be submitted to the contracting officer or his designated representative as work progresses at the time specified.

1. If leaking ballasts are encountered, submit proof of notification to the US EPA and local jurisdictions if items, waste, and/or debris will be stored for a period exceeding 30 days.

2. PCB and Mercury Sampling: In the event of a release episode, the contractor shall submit:

a. Laboratory Qualification Information: Submit proof of qualifications of testing laboratory. Accreditation by the American Industrial Hygiene Association (AIHA) for organic materials analysis shall be the minimum proof of compliance. This submittal must be approved by the Contracting Officer prior to beginning any testing.

b. Submit results of any sampling conducted during the project.

3. Packaging, Transport and Incineration of PCB Containing Materials:

a. Recordkeeping of all PCB items and mercury lamps generated from a GSA facility must be accurate, thorough and complete, since GSA remains ultimately responsible for their generated waste until its final EPA approved destruction. To insure compliance with EPA regulations (40 CFR Part 761 and 40 CFR 260-265) and to take every precaution against improper/incomplete destruction, tracking records are required as follows:

1) Provide tracking documentation for each container of PCB and/or PCB contaminated substance(s) by forwarding copies of all manifests and continuation sheets (information of contents of each PCB container) to:

GSA, Contracting Officer, Attn: Contract Number, 301 7th Street, SW, Washington, DC, 20407.

2) Each container shall be properly labeled prior to placing the PCB item or mercury lamp in the container. A properly labeled container shall have painted on it, or securely attached to it (in addition to other requirements) the following GSA required information:

a) A unique container serial number as follows:

Each drum to be filled with PCB or mercury items or waste will have a serial number that is a combination of the GSA Building number, the container number, and content painted on the drum.

Example: drum number (001) generated from the Main State Department building = DC0046ZZ 001BAL.

b) The initial date the container was filled.

b. Contents of the PCB container. Liquids shall not be mixed with solids.

c. The name of the Company and person filling the container and the GSA contract number.

d. Description of container contents (i.e., contaminated rags/poly, light fixtures, etc.). All communication relating to these containers must reference the container serial number(s).

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4. Provide the Contracting Officer with an itemized list of all PCB/mercury waste containers along with copies of all manifest(s) and continuation sheets prior to any container being removed from the job site.

5. Shipping Manifest Forms: Signed and completed Shipping Manifest Forms shall be used for the transportation of PCB (IAW 40 CFR Part 761) or mercury (IAW 40 CFR Parts 260-265).

Each manifest is to be assigned a unique number. Each party who controls the waste shall sign this form, and each party shall retain a copy as responsibility for the waste is transferred to the next party. Provisions of legible copies of manifests are to go to the Contracting Officer.

6. Certificates of Destruction: Provision of Certificates of Destruction (CD) to the Contracting Officer, as well as a method to ensure that the incineration facility destroys the PCB and mercury materials. Provide a signed copy of the manifests and CD within 30 days of the facilities receipt of material.

D. Final Submittals: Items 1.5.D.1 below is to be submitted to the contracting officer or his designated representative at the completion of work for each work area.

1. Summary Report: Copies of any sampling results and all narrative reports performed as part of this contract.

1.6 CONTRACTOR RESPONSIBILITY:

A. The Contractor shall assume full responsibility and liability for compliance with all applicable Federal, State, and local regulations pertaining to the protection of his workers, visitors to the site, and persons occupying areas adjacent to the site. The Contractor is responsible for providing medical examinations and maintaining medical records of personnel as required by regulations.

The Contractor shall hold the government harmless for failure to comply with any applicable safety or health regulation on the part of himself, his employees, or his subcontractors.

1.7 PROJECT/SITE CONDITIONS:

A. Means of Egress: Establish and maintain emergency and fire exits from the work area.

B. Use of Existing Facilities: Use of existing toilets, showers, and/or other similar facilities for decontamination areas is prohibited.

C. Maintenance of Existing Equipment: See contract drawings for requirements, if any.

D. Environmental Conditions to be Maintained: This project shall not affect the delivery of normal environmental conditions (heat, light, air conditioning) to the occupants of the building.

E. Access to Work Area: The following personnel shall have unrestricted access to the work area:

1. GSA Contracting Officer

2. GSA Environmental Management Branch

3. GSA Contract Monitoring Personnel

4. GSA Authorized Inspection Personnel

5. OSHA Inspectors

6. EPA Inspectors

7. Local Building or Health Officials

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1.8 SEQUENCING/SCHEDULING: See contract drawings for any specific requirements.

PART 2 - PRODUCTS

2.1 EQUIPMENT:

A. Equipment such as waste containers and personal protective equipment (including respirators and disposable protective clothing) used in the execution of this contract shall comply with the applicable Federal, State, and local regulations.

2.2 MATERIALS:

A. Absorbent materials used for lining drums shall be produced for that purpose. Any alternative materials/items proposed by the Contractor shall be submitted for review prior to use.

B. Containers for storing and transporting lamps shall be produced for that purpose. Any alternative containers proposed by the Contractor shall be proven effective in preventing breakage during packaging and transport, and shall be submitted for review prior to use.

PART 3 - EXECUTION

3.1 PREPARATION:

A. Isolate the work area for the duration of the work so as to prevent unauthorized access. Designate the area off limits using appropriate signage, to all but authorized personnel. Maintain a log of all persons visiting the work site.

B. Post warning signs and labels as required by this contract, 29 CFR 1910, 40 CFR 761, 40 CFR 260-265, and as directed by the Contracting Officer.

3.2 WORK PROCEDURE:

A. General Procedures: Perform all PCB/mercury related work in compliance with the general safety and health provisions and in conformance with 29 CFR 1910, 29 CFR 1926, and 40 CFR 761, and 40 CFR 260-265 respectively. If a conflict arises, the more stringent application shall apply until the contracting officer or his designated representative makes a determination.

B. Coordination of Work of all Trades: Coordinate the work of all trades to assure that their work is performed in accordance with the applicable regulations and that the work/control area remains separate from the remaining work areas.

3.3 PCB ITEM/MERCURY LAMP REMOVAL:

The following is a basic outline of the minimum steps that will be taken during the removal. The procedures and plan of action submitted for approval by the contractor shall address these points:

A. Place a minimum of two layers of 6 mil plastic on the floor beneath the work area and beneath the stored waste disposal drums.

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B. Pour a significant (minimum three inch layer) amount of oil absorbent in a DOT 17 H drum labeled as containing PCB. Mercury lamps should be stored intact within the packaging containers.

C. Remove the lamps and light ballast from the light fixture and place the items directly into its respective container. If the ballast is labeled "NO PCBs", dispose of it with the normal construction debris. Note: many ballast contain Diethylhexyl phathatlate (DEHP), while DEHP is a listed hazardous waste under RCRA in its pure form, once it is in a light ballast it no longer meets the definition of hazardous under RCRA (40 CFR 261.33, part 261 appendix VII, section 268.34, and 268.43) If disposing of 1,500 or more ballasts at once it may be necessary to handle waste stream differently contact project manager or NCR Safety Environment & Fire Protection at 202-708-5236.

D. PCB resistant gloves and disposable clothing shall be worn when handling the fixtures and tools should be cleaned upon the completion of each shift.

E. Properly dispose of any light fixture, which held an unlabeled, leaking ballast as PCB contaminated material.

F. Alternately layer the ballasts and absorbent material until the drum is full, carefully checking to assure that the last layer will be absorbent material.

G. Place all used, disposable protective clothing and plastic in the drum.

H. Label the drum with a DOT label with the following minimum information:

Date of materials were placed in the drum.

Materials in the drum, i.e. "75 two tube light ballasts."

Name address and phone number of the generator, or owner of the light ballasts.

Container identification no. (ex: DC0093ZZ 001BAL)

I. Record the weight of each container (in kilograms) and enter it on the manifest. Provide a total count of lamps, distinguishing the counts by the various lengths.

J. The contractor shall obtain the EPA Generator Identification Number (if building does not currently possess), make EPA notifications, complete the hazardous waste manifest form, and have the materials managed and recycled or disposed of appropriately.

K. Transport the containers to the appropriate EPA approved incinerator or recycling facility.

3.4 FIELD QUALITY CONTROL:

A. Site Inspection and Stop Work Orders: While performing this work, the Contractor shall be subject to onsite inspection by agency officials or agency contracted inspection services. Work shall also be subject to inspection by OSHA and EPA inspectors and/or local building or health officials. If found to be in violation by one of these officials, the Contractor shall cease all work immediately. Until the violation is resolved, standby time required to resolve the violation shall be at the Contractor's expense.

B. One complete set of equipment (such as respirators and disposable clothing) required for entry to the work area shall be made available within 2 hours of request by the Contracting Officer for inspection of the work area. Such requests will only be made during the contractor's working hours.

3.5 CLEANUP AND DISPOSAL:

A. Permits and Notifications: Secure necessary permits in conjunction with PCB removal, hauling and disposition and provide timely notification of such actions, as may be required by federal, state, PCB ABATEMENT PROCEDURES 020890-9 regional, and local authorities. Notify the Regional Office of the United States Environmental Protection Agency and provide copies of the notification to the Contracting Officer 10 days prior to the commencement of the work.

B. Housekeeping: Essential parts of PCB control are housekeeping and cleanup procedures. Maintain all surfaces on the work area free of accumulations of debris to prevent further dispersion. Give meticulous attention to restricting the spread of debris, keep waste from being distributed over the general area or to other areas in the building. The blowing down of the work area with compressed air is forbidden. Post appropriate hazard warning signs. In all possible instances workmen shall cleanup their own areas. Equip personnel engaged in cleaning up scrap and waste with necessary personal protective clothing.

C. Disposal of PCB Containing Materials: Collect and dispose of all PCB ballasts and contaminated waste, rags, scrap, debris, bags, containers, equipment, and PCB contaminated clothing in properly labeled PCB disposal drums. Waste PCB containing materials that are not to be recycled shall be transported to an incineration site. The contractor will provide the Contracting Officer with a copy of all manifests and continuation sheets resulting from the incineration of the PCB containing waste. In some instances, a temporary holding area can be established upon approval by the Contracting Officer for properly packaged PCB waste.

D. Approval of Final Cleanup: The Contracting Officer or his designated representative will inspect the work area in concert with the government's industrial hygienist for approval of the PCB removal.

Visual observation of potential contamination, dust or debris is not permitted on any surface in or around the work area. The Contracting Officer's Representative will approve final cleaning and restoration of the work area.

END OF SECTION 020890

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APPENDIX A - GSA PCB & MERCURY LAMP PROJECT CONTROL CHECKLIST

020890 Contractor Submittal Punch List

PROJECT

PROJECT NUMBER _

DATE REVIEWED

REVIEWER

A. Initial Contractor Submittals: To be submitted with Bid:

1. Contractor Qualification Information

a. Record of firm’s experience, including names and addresses of purchasers of service, location

REVIEWED APPROVED

of work, and dates of performance (Section 1.5.A.1.a) _

b. Name of Superintendent: (Sect. 1.5.A.1.b)

1. Record of experience

2. Record of training (HAZWOPER)

c. Names and experience record of employees: (Section 1.5.A.1.c)

1. Record of experience

2 Record of training (HAZWOPER / Hazardous Waste Awareness)

B. Post Award Submittals: To be submitted prior to beginning work:

1. Plan of Action (Sect. 1.5.B.1 3)

a. Work plan for ballast removal

b. Scheduling/sequencing of work

c. Interface of other trades in work schedule

d. Methods used to ensure safety of building occupants and visitors

2. Contingency plan for responses to suspected release or spill

3. Incineration of waste, location of site, and permit from Owner and regulatory authority

C. During-Work Submittals: To be submitted during work. (Items below are to be submitted to the contracting officer or his designated representative as work progresses)

1. a. Notification of EPA if leaking PCB items are to be accumulated/stored (Section 1.5.C.1)

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b. Notification of local jurisdiction if leaking PCB items are accumulated/stored (Section 1.5.C.1) DC / VA / MD

2. Laboratory Qualification

Information (to be submitted before any sampling) (Section 1.5.C.2.a&b)

a. Name and location of firm

REVIEWED APPROVED

b. Proof of current accreditation of firm by AIHA

c. Results of wipe and/or air sampling (Section 1.5.C.2.b)

3. Packaging, transport and incineration of small PCB items and lamps:

(Section 1.5.C.3) a1. Hazard waste manifests a2. Drum labeled with

PCB container serial number

Initial date container filled

b. contents of container

c. name of company and person filling container and GSA contract no.

d. container contents description

4. Itemized list of containers with manifest(s) prior to site removal

5. Shipping manifest forms

6. Certificates of Destruction

D. Final submittals: Item 1.5.D.1 is to be submitted to the contracting officer or his designated representative upon the completion of work:

1. Summary report

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Table 1 TSCA Disposal Requirements for Fluorescent Light Ballasts

PCB

Capacitor

PCB Potting

Material

Labeling, Transportation and

Manifesting for Disposal

Disposal

Reference in §761

Disposal Options

“No PCBs” label

Not regulated under TSCA N/A Not regulated under TSCA

None < 50 ppm Not regulated under TSCA N/A Not regulated under TSCA

Intact and non-leaking or none

> 50 ppm Is a PCB bulk product waste.

No labeling is required.

Manifesting is required for disposal in accordance with §761.62(a); is not required under §761.62(b); may be required under §761.62(c).

.50(b)(2)(ii)

.62(a)-(c)

TSCA Incinerator, TSCA/RCRA Landfill, Alternate Destruction Method, Decontamination (§761.65(d) storage approval may be required), Coordinated approval, State approved landfill (leach test required), Risk-based approval

Intact and non-leaking

< 50 ppm No labeling or manifesting required

.50(b)(2)(i)

.60(b)(2)(ii)

As municipal solid waste 40 CFR

761 subpart D options

Leaking < 50 ppm or

50 ppm

Disposal as PCB bulk product waste. No labeling is required.

Manifesting is required for disposal in accordance with §761.62(a); may be required under §761.62(c).

.62(a) or (c) TSCA Incinerator TSCA/RCRA

Landfill Alternate Destruction Method Decontamination (§761.65(d) storage approval may be required) Coordinated approval Risk-based approval