Attachment 2 -Protocol for Evaluating Priority PCBs Containing Material before Building Demolition
Managing PCBs−Containing Building Materials
during Demolition:
Guidance, Tools, Outreach and Training
Protocol for Evaluating Priority
PCBs-Containing Materials before
Building Demolition
August 2018
ATTACHMENT 1
This document is a deliverable of the Bay Area Stormwater Management Agencies Association
(BASMAA) project Managing PCBs−Containing Building Materials during Demolition: Guidance, Tools,
Outreach and Training. BASMAA developed guidance, tools, and outreach and training materials to assist
with San Francisco Bay Area municipal agencies’ efforts to address the requirements of Provision C.12.f.
of the Bay Area Municipal Regional Stormwater Permit (referred to as the MRP). Provision C.12.f of the
MRP requires Permittees to manage PCBs–containing building materials during demolition.
We gratefully acknowledge the BASMAA Steering Committee for this project, which provided overall
project oversight, including during the development of this and other project deliverables:
• Reid Bogert, Stormwater Program Specialist, San Mateo Countywide Water Pollution Prevention
Program (BASMAA Project Manager)
• Amanda Booth, Environmental Program Analyst, City of San Pablo
• Kevin Cullen, Program Manager, Fairfield-Suisun Urban Runoff Management Program
• Matt Fabry, Program Manager, San Mateo Countywide Water Pollution Prevention Program
• Gary Faria, Supervisor, Inspection Services, Building Inspection Division, Contra Costa County
• Napp Fukuda, Deputy Director - Watershed Protection Division, City of San José
• Ryan Pursley, Chief Building Official, Building Division, City of Concord
• Pam Boyle Rodriguez, Manager, Environmental Control Programs – Stormwater, City of Palo Alto
• Jim Scanlin, Program Manager, Alameda Countywide Clean Water Program
• Melody Tovar, Regulatory Programs Division Manager, City of Sunnyvale
We also gratefully acknowledge the project Technical Advisory Group, which provided feedback from a
variety of project stakeholders during development of selected project deliverables:
Stakeholder Group Representative(s)
Regulatory – stormwater/PCBs Luisa Valiela and Carmen Santos, U.S. EPA Region 9
Regulatory – stormwater/TMDL Jan O’Hara, San Francisco Bay Regional Water Quality
Control Board
Regulatory – experience with related
program (asbestos management)
Ron Carey and Richard Lew, Bay Area Air Quality
Management District
Industry – demolition contractors Avery Brown, Ferma Corporation
Industry – remediation consultants John Martinelli, Forensic Analytical Consulting
John Trenev, Bayview Environmental Services, Inc.
MRP Permittee – large municipality Patrick Hayes, City of Oakland
MRP Permittee – medium municipality Kim Springer, San Mateo County Office of Sustainability
MRP Permittee – small municipality Amanda Booth, City of San Pablo
Prepared for:
BASMAA
P.O. Box 2385
Menlo Park, CA 94026
Prepared by:
EOA, Inc.
Larry Walker Associates
Geosyntec Consultants
Stephanie Hughes
David J. Powers & Associates, Inc.
iii
TABLE OF CONTENTS
DISCLAIMER ........................................................................................... iv
1. INTRODUCTION ................................................................................................ 1
2. CURRENTLY ESTABLISHED BUILDING MATERIAL EVALUATION
PROTOCOLS ....................................................................................................... 3
2.1 Asbestos Containing Material Evaluation Procedures................................. 3
2.1.1 Asbestos-Containing Materials in Schools Rule ............................. 3
2.2 Lead-Based Paint (LBP) Evaluation Procedures ......................................... 7
2.2.1 LBP Sampling Procedures: Test Kits .............................................. 7
2.2.2 LBP Sampling Procedures: XRF Devices ....................................... 8
2.2.3 LBP Sampling Procedures: Laboratory Testing of Paint Chips .... 10
3. PCBS BUILDING MATERIAL EVALUATION PROTOCOL ........................ 13
3.1 Priority Building Materials to be Tested.................................................... 13
3.2 PCBs Sampling Procedures ....................................................................... 15
3.2.1 Sampling Equipment...................................................................... 16
3.2.2 Sample Collection Frequency ........................................................ 16
3.2.3 Sample Analysis and Preservation ................................................. 18
3.2.4 Quality Assurance and Quality Control ......................................... 19
3.3 Reporting and Notifications ....................................................................... 19
4. REFERENCES ................................................................................................... 21
LIST OF APPENDICES
Appendix A: PCBs Building Material Prioritization Worksheet
Appendix B: Priority Building Materials Photographic Log
iv
DISCLAIMER
Information contained in BASMAA products is to be considered general guidance and is not to be
construed as specific recommendations for specific cases. BASMAA is not responsible for the
use of any such information for a specific case or for any damages, costs, liabilities or claims
resulting from such use. Users of BASMAA products assume all liability directly or indirectly
arising from use of the products.
The material presented in this document is intended solely for the implementation of a municipal
regulatory program required by the San Francisco Bay Area Regional Water Quality Control
Board Municipal Regional Stormwater Permit for the protection of water quality under the Clean
Water Act.
BASMAA prepared the tools and guidance herein to assist MRP Permittees’ efforts to address
the requirements of Provision C.12.f. of the MRP. The project team received input from a variety
of stakeholders during development of the tools and guidance, including regulators (San
Francisco Bay Regional Water Quality Control Board, U.S. EPA, and Bay Area Air Quality
Management District staff), Bay Area municipal agency staff, and industry representatives.
This document does not address other environmental programs or regulations (e.g., PCBs
regulations under the Toxic Substances Control Act (TSCA); federal, state, or local regulations
for hazardous material handling and hazardous waste disposal; health and safety practices to
mitigate human exposure to PCBs or other hazardous materials; recycling mandates; and
abatement at sites with PCBs (or other contaminants). The applicant is responsible for knowing
and complying with all relevant laws and regulations.
The mention of commercial products, their source, or their use in connection with information in
BASMAA products is not to be construed as an actual or implied approval, endorsement,
recommendation, or warranty of such product or its use in connection with the information
provided by BASMAA.
This disclaimer is applicable to all BASMAA products, whether information from the BASMAA
products is obtained in hard copy form, electronically, or downloaded from the Internet
Protocol for Evaluating Priority PCBs-Containing Materials before Building Demolition
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1.INTRODUCTION
The San Francisco Bay Region Municipal Regional Stormwater NPDES permit, referred to as the
Municipal Regional Permit (MRP)1, includes provisions that implement stormwater-related
aspects of the Total Maximum Daily Load (TMDL) for polychlorinated biphenyls (PCBs) in the
Bay. Provision C.12.f. requires that Permittees develop and implement or cause to be developed
and implemented an effective protocol for managing materials with PCBs concentrations of 50
milligrams per kilogram (mg/kg) (equivalent to parts-per-million, or ppm), the target management
level, or greater in applicable structures at the time such structures undergo demolition 2, so that
PCBs do not enter municipal storm drain systems. Applicable structures include, at a minimum,
non-residential structures constructed or remodeled between the years 1950 and 1980 with
building materials such as caulking and thermal insulation with PCBs concentrations of 50 ppm
or greater. Single-family residential and wood frame structures are exempt. Also, a Permittee is
exempt from this requirement if it provided evidence acceptable to the Executive Officer in its
2016/17 Annual Report that the only structures that existed pre-1980 within its jurisdiction were
single-family residential and/or wood-frame structures.3
Permittees are required to develop a protocol by June 30, 2019 that includes each of the following
components, at a minimum:
1.The necessary authority to ensure that PCBs do not enter municipal storm drains from
PCBs-containing materials in applicable structures at the time such structures undergo
demolition;
2.A method for identifying applicable structures prior to their demolition; and
3.Method(s) for ensuring PCBs are not discharged to the municipal storm drain from
demolition of applicable structures.
By July 1, 2019 and thereafter, Permittees are required to:
•Implement or cause to be implemented the PCBs management protocol for ensuring PCBs
are not discharged to municipal storm drains from demolition of applicable structures via
vehicle track-out, airborne releases, soil erosion, or stormwater runoff.
•Develop an evaluation methodology and data collection program to quantify in a
technically sound manner PCBs loads reduced through implementation of the protocol for
controlling PCBs during demolition of applicable structures.
1 The Municipal Regional Stormwater Permit, Order No. R2-2015-0049, was adopted November 19, 2015.
2 Demolition means the wrecking or taking out of any load-supporting structural member of a facility together with
any related handling operations (40 CFR., Part 61, Subpart M).
3 The City of Clayton provided evidence to support an exemption from the requirement.
Protocol for Evaluating Priority PCBs-Containing Materials before Building Demolition
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On behalf of MRP Permittees, the Bay Area Stormwater Management Agencies Association
(BASMAA) is conducting a regional project to assist MRP Permittees to achieve compliance with
Provision C.12.f. The regional project is developing guidance materials, tools, protocols and
training materials and conducting outreach. The goal is to assist Permittees to develop local
programs to prevent PCBs from being discharged to municipal storm drains due to demolition of
applicable buildings. Local agencies will need to tailor the BASMAA products for local use and
train local staff to implement the new program.
This document is the deliverable for Task 3 of the regional project, which is to develop a protocol
for the assessment of prioritized PCBs-containing building materials prior to demolition. The full
scope of work for the regional project is presented in the Project team’s Proposal for Tools,
Protocol, Outreach & Training Work Plan: PCBs Materials Management during Building
Demolition Project (dated January 31, 2017; revised March 2017). If materials are found or known
to contain PCBs, those materials must be managed appropriately and according to all applicable
local, state, and federal requirements. Management of PCBs-containing materials is beyond the
scope of this document.
To establishing the PCBs protocol, current established protocols were evaluated that are widely
accepted in the building demolition industry for other Federal- and State-regulated constituents of
concern. This document provides applicable examples of sampling and evaluation procedures for
building materials potentially contaminated with asbestos-containing material (ACM)4 and lead-
based paint (LBP)5, which are summarized and referenced to provide the foundation for the PCBs
protocol. These components include guidance on sampling frequencies, laboratory sample
analysis, quality assurance and quality control procedures, and reporting.
4 Asbestos-containing material (ACM) means any material or product which contains more than one percent asbestos.
5 Lead-based paint (LBP) is any paint, varnish, shellac, or other coating that contains lead equal to or greater than 1.0 mg/cm2 as
measured by XRF device or laboratory analysis, or 0.5 percent by weight (5,000 ppm or 5,000 mg/kg) as measured by laboratory
analysis.
Protocol for Evaluating Priority PCBs-Containing Materials before Building Demolition
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2. CURRENTLY ESTABLISHED BUILDING MATERIAL EVALUATION
PROTOCOLS
This section presents evaluation protocols for ACM and LBP, which provide a foundation for the
PCBs protocol summarized in Section 3. This section includes guidance on sampling frequencies,
laboratory sample analysis, quality assurance and quality control procedures derived from
regulatory procedures for ACM and LBP.
2.1 Asbestos Containing Material Evaluation Procedures
Asbestos bulk sampling procedures are specified in several Federal regulations, implemented
primarily by the United States Environmental Protection Agency (EPA) as well as the
Occupational Safety and Health Administration (OSHA). The Consumer Product Safety
Commission (CPSC) and the Mine Safety and Health Administration (MSHA) specify additional
regulations and procedures, but these are generally less applicable to evaluation procedures.
The foundational regulations pertaining to asbestos sampling in buildings are the Asbestos Hazard
Emergency Response Act (AHERA; Toxic Substances Control Act [TSCA] Title II) (15 U.S.C. §
2641-2656) as well as the Asbestos School Hazard Abatement Reauthorization Act (ASHARA).
EPA promulgated regulations under AHERA to require inspection of schools for asbestos-
containing building materials, and to perform resultant corrective actions. Furthermore, AHERA
tasked the EPA with developing a plan for accreditation of asbestos inspectors. ASHARA
extended funding for asbestos programs at schools and expanded accreditation requirements to
cover asbestos abatement at commercial buildings other than schools.
Pursuant to AHERA, the Asbestos-Containing Materials in Schools rule (40 CFR Part 763, Subpart
E) details specific requirements for building material inspections at schools, preparation of
asbestos management plans, and implementation of response actions. EPA regulation on asbestos
related to structure demolition is specified in subpart M of the National Emission Standards for
Hazardous Air Pollutants (NESHAP) regulations (40 CFR Part 61, Subpart M).
The following sections summarize the evaluation procedures specified in the Asbestos-Containing
Materials in Schools rule as well as the Asbestos NESHAP regulations. Both OSHA and EPA
worker protection requirements are also discussed.
2.1.1 Asbestos-Containing Materials in Schools Rule
The following sections summarize the inspection, re-inspection, sampling, analysis, and evaluation
procedures specified in the Asbestos-Containing Materials in Schools rule (40 CFR Part 763,
Subpart E).
Protocol for Evaluating Priority PCBs-Containing Materials before Building Demolition
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Evaluation
For each inspection and re-inspection of asbestos-containing building material (ACBM)6, the local
education agency shall have an accredited inspector provide a written evaluation of all friable
known or assumed ACBM. The evaluation shall consider the following:
•Location and amount of material, both in total quantity and as a percentage of the functional
space;
•Condition of the material, specifying:
o Type of damage or significant damage (e.g., flaking, blistering, water damage, or other
signs of physical damage);
o Severity of damage (e.g., major flaking, severely torn protective jackets, as opposed to
occasional flaking, minor tears to jackets);
o Extent or spread of damage over large areas or large percentages of the homogeneous7
area;
•Whether the material is accessible;
•The material’s potential for disturbance;
•Known or suspected causes of damage or significant damage (e.g., air erosion, vandalism,
vibration, water); and
•Preventive measures that could potentially eliminate the reasonable likelihood of
undamaged ACBM from becoming significantly damaged.
The inspector shall classify and give reasons in the written evaluation for classifying the ACBM
and suspected ACBM assumed to be ACM into one of the following categories:
1.Damaged or significantly damaged thermal system insulation ACM;
2.Damaged friable surfacing ACM;
3.Significantly damaged friable surfacing ACM;
4.Damaged or significantly damaged friable miscellaneous ACM;
5.ACBM with potential for damage;
6.ACBM with potential for significant damage; and
7.Any remaining friable ACBM or friable suspected ACBM.
6 Asbestos-containing building material (ACBM) means surfacing ACM, thermal system insulation ACM, or miscellaneous ACM that is
found in or on interior structural members or other parts of a building.
7 Homogenous refers to a substance or area that is uniform in texture, color, and general physical appearance and properties.
Protocol for Evaluating Priority PCBs-Containing Materials before Building Demolition
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Inspection and Re-inspection
Inspect any building that is to be used as a school, prior to such use, by an accredited inspector. In
emergency situations, inspect the building within 30 days of commencement of such use.
For each area of the building, complete the following inspection procedure:
• Visually inspect the area to identify suspected ACBM;
• Touch suspected ACBM to determine friability (Friable material is material that may be
crumbled or pulverized by hand pressure alone. Note that thermal system insulation that
has retained its structural integrity and that has an undamaged protective jacket or wrap
that prevents fiber release shall be treated as non-friable.);
• Categorize all areas into homogenous areas of friable suspected ACBM and non-friable
suspected ACBM;
• Assume that some or all the homogeneous areas are ACBM, and for each homogeneous
area that is not assumed to be ACBM, collect and submit samples for bulk analysis. Do not
sample areas that an accredited inspector assumes to contain ACBM. For uncertain areas,
collect and bulk samples and submit for analysis (see Sampling below);
• Assess friable material in areas where samples are collected, in areas wh ere samples are
not collected but ACBM is assumed to be present, and in areas identified in previous
inspections;
• Record the following information and submit a copy for inclusion in an asbestos
management plan, within 30 days of the inspection:
o An inspection report including the signature, state of accreditation, and
accreditation number of each inspector, as well as the date of the inspection;
o A comprehensive inspection inventory, including the date and locations of samples,
locations of areas assumed to contain friable ACBM, and locations of areas
assumed to contain non-friable ACBM;
o A description of the manner used to determine sampling locations;
o A list of all categorized and identified homogenous areas into surfacing material,
thermal system insulation, or miscellaneous material; and
o Evaluations made of friable material.
Repeat this process as a re-inspection at least once every 3 years after a management plan is in
effect. Reassess the condition of friable known or assumed ACBM previously identified. Identify
any homogenous areas with material that has become friable since the last inspection or re-
inspection and collect and submit samples of the material.
Protocol for Evaluating Priority PCBs-Containing Materials before Building Demolition
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Sampling
Collect samples in a statistically random manner that is representative of each homogeneous area.
•For surfacing material, the number of samples to be collected is as follows:
o Collect at least three samples from each homogenous area less than 1,000 square
feet;
o Collect at least five samples from each homogenous area between 1,000 and 5,000
square feet; and
o Collect at least seven samples from each homogenous area greater than 5,000
square feet.
•For thermal system insulation:
o Collect at least one bulk sample from each homogeneous area that is not assumed
to be ACM;
o Collect at least one bulk sample from each homogeneous area of patched insulation
that is not assumed to be ACM, if the patched section is less than six linear or square
feet;
o Where cement or plaster is used on fittings such as tees, elbows or valves, collect
samples to determine if material is ACM or not;
o If the accredited inspector determines that the thermal system insulation is
fiberglass, foam glass, rubber, or other non-ACBM, samples are not required to be
collected;
•For miscellaneous material, collect bulk samples from each homogeneous area of friable
material that is not assumed to be ACM.
Analysis
Samples should be analyzed by laboratories accredited by the National Bureau of Standards
(NBS). The laboratories must have received interim accreditation for polarized light microscopy
(PLM) analysis under the EPA Interim Asbestos Bulk Sample Analysis Quality Assurance
Program until the NBS PLM laboratory accreditation program for PLM is operational.
Samples should be analyzed for asbestos content by PLM using the “Interim Method for the Bulk
Determination of Asbestos in Bulk Insulation Samples”, found at Appendix E to Subpart E of 40
CFR Part 763. Samples should not be composited.
A homogenous area is considered not to contain ACM only if the results of all samples fro m that
area show asbestos in concentrations of 1 percent or less. An area is considered to contain ACM
if at least one sample from the area shows asbestos in concentrations greater than 1 percent.
Protocol for Evaluating Priority PCBs-Containing Materials before Building Demolition
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Submit the name and address of each laboratory performing the analysis, the date of the analysis,
and the person performing the analysis for inclusion into the management plan within 30 days of
the analysis.
2.2 Lead-Based Paint (LBP) Evaluation Procedures
Lead-Based Paint (LBP) evaluation procedures are codified in various federal and state
regulations.
Title IV of the Toxic Substances Control Act (TSCA) as well as other authorities in the Residential
Lead-Based Paint Hazard Reduction Act of 1992 directs the EPA to regulate lead-based paint
hazards. The primary Federal regulations and guidelines related to LBP evaluation procedures
include:
•The Lead Renovation, Repair and Painting Program (RRP) Rule (40 CFR 745, Subpart E);
•The National Lead Laboratory Accreditation Program (TSCA Section 405(b)); and
•The Housing and Urban Development (HUD) Guidelines for the Evaluation and Control
of Lead-Based Paint Hazards in Housing (2012 Edition) (pursuant to Section 1017 of the
Residential Lead-Based Paint Hazard Reduction Act of 1992, A.K.A. “Title X”)
Furthermore, the California Department of Public Health (CDPH) Title 17, California Code of
Regulations, Division 1, Chapter 8 “Accreditation, Certification, and Work Practices for Lead -
Based Paint and Lead Hazards,” specifies some LBP evaluation procedures as part of the
accreditation program.
The HUD Guidelines provide the most comprehensive procedures for LBP evaluations and are
referenced by many other regulations.
There are three primary methods of performing LBP evaluation: test kits, X-ray Fluorescence
(XRF) devices, and laboratory testing of paint chips. Sampling procedures for each method are
detailed in the following sections.
Under CDPH Title 17, certified Lead Inspector/Assessors are required to use XRF devices or
laboratory analysis, and not test kits.
2.2.1 LBP Sampling Procedures: Test Kits
In 2008, the EPA published the RRP rule, which, among other things, established criteria for lead
test kits for use in LBP evaluation. Lead test kits recognized by EPA before September 1, 2010,
must meet only the negative response criterion outlined in 40 CFR 745.88(c)(1):
Protocol for Evaluating Priority PCBs-Containing Materials before Building Demolition
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For paint containing lead at or above the regulated level, 1.0 mg/cm2 or 0.5% by weight,
a demonstrated probability (with 95% confidence) of a negative response less than or equal
to 5% of the time must be met.
Lead test kits recognized after September 1, 2010, must meet both the negative response and
positive response criteria outlined in 40 CFR 745.88(c)(1) and (2). The positive-response criterion
states:
For paint containing lead below the regulated level, 1.0 mg/cm2 or 0.5% by weight, a
demonstrated probability (with 95% confidence) of a positive response less than or equal
to 10% of the time must be met.
To date, no lead test kit has met both criteria8. However, three lead test kits recognized before
September 1, 2010, exist and are recognized by EPA:
• 3M™ LeadCheck™, manufactured by the 3M Company, for use on wood, ferrous metal,
drywall, and plaster surfaces;
• D-Lead®, manufactured by ESCA Tech, Inc., for use on wood, ferrous metal, drywall, and
plaster surfaces; and
• The Commonwealth of Massachusetts lead test kit, for use only on drywall and plaster
surfaces.
Test kits cannot determine the concentration of lead, only presence or absence at best. For this
reason, test kits are best used by homeowners or other non-professionals as a preliminary
evaluation before using an XRF device or laboratory analysis of paint chips.
There are currently no detailed sampling procedures for test kits that would be applicable to PCBs
evaluation. However, test kit technology may be a useful paradigm for PCBs evaluation if a kit
can be developed to test PCBs at an acceptable concentration that uses a repeatable methodology
to meet the data quality objectives.
2.2.2 LBP Sampling Procedures: XRF Devices
The following sections summarize LBP evaluation procedures for XRF devices, including
description of sampling equipment, collection techniques and frequency, sample analysis, and
quality assurance.
8 US EPA, Lead Test Kits, https://www.epa.gov/lead/lead-test-kits, accessed September 19, 2017.
Protocol for Evaluating Priority PCBs-Containing Materials before Building Demolition
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LBP Analyzers
According to the HUD Guidelines, portable XRF devices are the most common primary analytical
method for inspections in housing because of their versatility in analyzing a wide variety of surface
types, non-destructive measurement, high speed, and low cost per sample. Each XRF device must
have a HUD-issued XRF Performance Characteristic Sheet (PCS), which contains information
about XRF readings taken on specific surface types, calibration check tolerances, and
interpretation of XRF readings.
Collection Techniques and Frequency
HUD Guidelines provide separate sampling techniques for single- and multi-family housing.
However, the general approach to sampling is the following seven-step procedure:
•List all testing combinations of building components and substrates (e.g., wood doors,
metal doors, plaster walls, concrete walls);
•Select testing combinations. A numbering system, floor plan, sketch or other system may
be used to document which testing combinations were tested;
•Perform XRF testing, including calibration;
•Collect and analyze paint-chip samples as needed;
•Classify XRF and paint-chip results;
•Evaluate the work and results to ensure the quality of the inspection; and
•Document the findings in a summary and in a complete technical report.
Because of the large surfaces and quantities of paint involved, and the potential for spatial
variation, HUD Guidelines recommend taking at least four readings per room, with special
attention paid to surfaces that clearly have different painting history. The selection of test locations
should be representative of locations most likely to be coated with old paint or other lead -based
coatings, such as areas with thick paint; areas with worn or scraped off paint should be avoided.
For large buildings with many similar units, HUD Guidelines recommend testing a designated
sample of units to provide 95% confidence that most units are below the lead standard. The sample
size should be carefully chosen using statistical techniques (see HUD Guidelines, Table 7.3).
Sample Analysis
Portable XRF devices expose a surface to X-ray or gamma radiation and measure the emission of
characteristic X-rays from each element in the analyzed surface. The XRF reading is compared
with a range specified in the PCS for the specific XRF device being used and the specific substrate
beneath the painted surface.
Protocol for Evaluating Priority PCBs-Containing Materials before Building Demolition
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When discrepancies exist between the PCS, HUD Guidelines, and the XRF device’s
manufacturer’s instructions, the most stringent guideline should be followed.
Quality Assurance
HUD Guidelines provide several techniques for evaluation of inspection quality.
A knowledgeable observer independent of the inspection firm should be present for as much XRF
testing as possible, especially if they have knowledge of LBP evaluation and/or the paint history
of the facility.
The client should ask the inspector to provide copies of the results as soon as possible, or daily,
allowing for immediate review.
Data from HUD’s private housing lead-based paint hazard control program show that it is possible
to successfully retest painted surfaces without knowing the exact spot which was tested. Therefore,
the client may consider selecting 10 testing combinations for retesting at random from the already
compiled list of all testing combinations, using the XRF device used for the original measurements,
if possible. The average of the 10 repeat XRF results should not differ from the 10 original XRF
results by more than the retest tolerance limit. The procedure for calculating the retest tolerance
limit is specified in the PCS. If the limit is exceeded, the procedure should be repeated using 10
different testing combinations. If the retest tolerance limit is exceeded again, the original
inspection is considered deficient.
Currently XRF technology and methods are not applicable to PCBs building material evaluation,
as the precision is not adequate to provide a concentration that could be relied upon for this
program.
2.2.3 LBP Sampling Procedures: Laboratory Testing of Paint Chips
The following sections summarize LBP evaluation procedures for XRF devices, including the
description of sampling equipment, collection techniques and frequency, sample analysis, and
quality assurance.
Laboratory analysis of paint chip samples is only recommended by HUD for inaccessible areas or
building components with irregular (non-flat) surfaces that cannot be tested using XRF devices,
for confirmation of inconclusive XRF results, or for additional confirmation of conclusive XRF
results.
Unlike XRF analysis, paint chip collection techniques may be more directly applicable to potential
PCBs collection techniques.
Protocol for Evaluating Priority PCBs-Containing Materials before Building Demolition
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Sampling Equipment
Common hand tools can be used to scrape paint chips from a surface; specialized equipment is not
necessary. However, HUD Guidelines recommend that samples should be collected in sealable
rigid containers rather than plastic bags, which generate static electricity and make laboratory
transfer difficult.
Collection Techniques
HUD Guidelines, which are consistent with ASTM E1729, Standard Practice for Field Collection
of Dried Paint Samples for Subsequent Lead Determination, recommend that only one paint chip
needs to be taken for each testing combination, although additional samples are recommended for
quality control.
The paint chip sample should be taken from a representative area that is at least 4 square inches in
size. The dimensions of the surface area must be accurately measured to the nearest 1/16 th of an
inch so that laboratory results can be reported in units of mg/cm2. Paint chip collection should
include collection of all the paint layers from the substrate, but collection of actual substrate should
be minimized. Any amount of substrate included in the sample may cause imprecise results.
Sample Analysis
A laboratory used for LBP analysis must be recognized under EPA’s National Lead Laboratory
Accreditation Program (NLLAP) for the analysis of lead paint; however, States or Tribes may
operate an EPA-authorized lead-based paint inspection certification program with different
requirements.
There are several standard laboratory techniques to quantify lead in paint chip samples, including
Atomic Absorption Spectroscopy, Inductively Coupled Plasma-Atomic Emission Spectroscopy
(ICP-AES), Anodic Stripping Voltammetry, and Potentiometric Stripping Analysis.
For analytical methods that require sample digestion, samples should be pulverized so there is
adequate surface area to dissolve the sample before laboratory instrument measurement. In some
cases, the amount of paint collected from a 4-square-inch area may exceed the amount of paint
that can be analyzed successfully. It is important that the actual sample mass analyzed not exceed
the maximum mass the laboratory has successfully tested using the specified method. If
subsampling is required to meet analytical method specifications, the laboratory must homogenize
the paint chip sample (unless the entire sample will eventually be analyzed, and the results of the
subsamples combined). Without homogenization, subsampling would likely result in biased,
inaccurate lead results. If the sample is properly homogenized and substrate inclusion is negligible,
the result can be reported as a loading, in milligrams per square centimeter (mg/cm2), the preferred
unit, or as percent by weight, or both.
Protocol for Evaluating Priority PCBs-Containing Materials before Building Demolition
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Quality Assurance
Laboratory reference materials processed with the paint chip samples for quality assurance
purposes should have close to the same mass as those used for paint-chip samples (refer to ASTM
methods E1645, E1613, E2051, and E1775).
Reporting
The laboratory report for analysis of paint chip samples should include at a minimum, the
information outlined in the EPA National Lead Laboratory Accreditation Program Laboratory
Quality System Requirements, Revision 3.0, section 5.10.2, Test Reports9. In addition to those
minimum requirements, test reports containing the results of sampling must include specified
sampling information, if available.
9 National Lead Laboratory Accreditation Program: Laboratory Quality System Requirements
https://www.epa.gov/sites/production/files/documents/lqsr3.pdf, accessed September 20, 2017.
Protocol for Evaluating Priority PCBs-Containing Materials before Building Demolition
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3.PCBS BUILDING MATERIAL EVALUATION PROTOCOL
This section presents the evaluation protocol for identifying building materials in structures
constructed or remodeled between the years 1950 and 198010 that may contain a significant mass
of PCBs. Once identified as containing PCBs at concentrations exceeding 50 ppm, these materials
should be properly managed prior to building demolition, to ensure PCBs are not discharged to the
municipal storm drain system.
This protocol is not intended to address all PCBs-containing materials that may disturbed during
building demolition. Additional sampling is likely to be required to comply with EPA and
Cal/OSHA regulations pertaining to the management, removal and disposal of PCBs-containing
materials.
For this program, it is assumed that organizations and staff qualified to sample, test, remediate,
and dispose of PCBs at the building site will coordinate processes for other hazardous building
materials at the building site, to ensure proper sampling, testing, remediation, and disposal or all
statutorily-required hazardous materials handling.
3.1 Priority Building Materials to be Tested
A prioritized list of PCBs-containing materials is provided in Appendix A. Building materials were
evaluated based upon the following criteria:
•Source Material – Does the building material contain PCBs through the original
product manufacturing process or was the building material contaminated (impregnated)
with PCBs from an adjacent building material that already contained PCBs? For the
evaluation, building materials originally manufactured with PCBs at or above 50 mg/kg
were prioritized.
•Concentration – Building materials were evaluated based on readily available existing
data regarding ranges of PCBs concentrations identified in the materials.
•Prevalence – A prevalence factor was assigned based upon best professional judgement
of the prevalence of occurrence of the PCBs-containing materials in buildings, which
ranged from highly prevalent to low prevalence.
•Ease of Removal – Building materials were evaluated based on their attachment to the
building, which ranged from “very easily removed” to “difficult to remove,” under the
assumption that higher ease of removal results in higher feasibility and lower costs for
removing a material before demolition.
10 Single-family residential and wood frame structures are exempt.
Protocol for Evaluating Priority PCBs-Containing Materials before Building Demolition
14
•Flaking/Crumbling – Building materials were evaluated based on their tendency to
flake or crumble during disturbance or demolition, which could lead to a higher
likelihood of entering stormwater as a result of building demolition.
•PCBs Removed by Other Waste Program – This factor addresses materials that are
removed from buildings because of other waste management programs (e.g., Universal
Waste Rule). Fluorescent light ballasts11, polyurethane foam furniture, and Askarel fluid
used in transformers, all of which may contain PCBs, are typically managed during pre-
demolition activities under current regulations and programs that require removal of
universal waste and outdated transformers. For this program it is assumed that those
materials will be evaluated and managed under those existing programs.
Material prioritization was conducted by assigning a score on a scale of 1 to 5 (low to high) for
each criterion. The final score for each material type was calculated as the average of the scores
assigned to the six criteria. The materials given the highest scores through the prioritization
analysis are shown below, along with their typical locations in a building. For this evaluation,
thermal insulation and fiberglass insulation were grouped together as they tend to be co-located
and are typically managed together. The materials listed below (along with typical locations where
they are found) are the materials that should be sampled using the protocols described in Section
3.2.
1.Caulks and Sealants:
a.Around windows or window frames;
b.Around door frames; and
c.Expansion joints between concrete sections (e.g., floor segments).
2.Thermal/Fiberglass Insulation and Other Insulating Materials:
a.Around HVAC systems,
b.Around heaters,
c.Around boilers,
d.Around heated transfer piping, and
e.Inside walls or crawls spaces.
3.Adhesive/Mastic:
a.Below carpet and floor tiles;
11 Fluorescent light ballasts that contain PCBs are not required to be managed under the Universal Waste Rule Program
but are recommended by the EPA to be identified in a pre -demolition survey of a structure and to be managed with
the removal of other required wastes in the abatement process.
Protocol for Evaluating Priority PCBs-Containing Materials before Building Demolition
15
b. On, under, or between roofing materials and flashing.
4. Rubber Window Seals/Gaskets:
a. Around windows or window frames.
Examples of the prioritized PCBs-containing building materials and what they may look like in a
building planned for demolition are provided in Appendix B.
3.2 PCBs Sampling Procedures
Many building materials may contain PCBs. The building owner is responsible for identifying and
handling all hazardous materials in accordance with all applicable laws, including all materials
with 50 ppm or more PCBs. For purposes of obtaining a demolition permit, the City requires a
building owner to sample the limited number of materials shown below:
1. Caulks and Sealants:
a. Around windows or window frames;
b. Around door frames; and
c. Expansion joints between concrete sections (e.g., floor segments).
2. Thermal/Fiberglass Insulation and Other Insulating Materials:
a. Around HVAC systems,
b. Around heaters,
c. Around boilers,
d. Around heated transfer piping, and
e. Inside walls or crawls spaces.
3. Adhesive/Mastic:
a. Below carpet and floor tiles;
b. On, under, or between roofing materials and flashing.
4. Rubber Window Seals/Gaskets:
a. Around windows or window frames.
It should be noted that some materials that are being evaluated for PCBs in this protocol may also
be associated with asbestos, lead, or other hazardous substances. Since this protocol follows pre-
established asbestos management program guidelines and procedures, the sampling frequency,
types of building materials, and surveying techniques overlap with the PCBs survey protocol. If a
Protocol for Evaluating Priority PCBs-Containing Materials before Building Demolition
16
material has been determined to contain asbestos, lead or other hazardous substances and will be
abated under an associated waste program, that material need not be sampled for PCBs under this
program.
3.2.1 Sampling Equipment
Building materials that are planned to be collected for laboratory analysis should be placed in
laboratory-supplied glass jars with Teflon-sealed lids. Samples should be collected with either
factory-sealed or decontaminated equipment that will be used to remove a representative building
material sample (i.e., scissors, tweezers, pliers, spoons, or putty knife).
For sampling equipment (i.e., scissors, tweezers, pliers, spoons, putty knife, etc.) that will be
decontaminated, the following three bucket wash procedure should be performed, which is in
general accordance with standard decontamination procedures defined in SESDPROC-205-R3
(EPA, 2015):
• In the first bucket, mix a residue free cleaning detergent (e.g., Alconox®), with distilled
water to generate the recommended detergent concentration specified in the product
directions;
• Fill the second bucket with distilled water;
• Fill the third bucket with distilled water;
• Clean the equipment in the first bucket with the cleaning detergent, then rinse in the second
and then the third bucket. If the second bucket becomes slightly discolored during the rinse,
change the contents of the second bucket with distilled water. Change the third bucket, if
any dirt or material is observed in the water, since the third bucket needs to stay clean as it
is the final rinse; and
• At the end of cleaning, let the equipment air dry in a clean area before use in sample
collection. The rinse water should then be drummed and sampled for disposal. The planned
disposal facility should be contacted to determine the required sample analysis for the rinse
water characterization and profiling and that the disposal procedures comply with state and
federal regulations.
If disposable sampling tools are used, the above decontamination procedures do not apply.
3.2.2 Sample Collection Frequency
For the four prioritized building materials, the following collection techniques and frequency
should be followed.
Caulking
Three different types of caulking should be evaluated:
Protocol for Evaluating Priority PCBs-Containing Materials before Building Demolition
17
1.Window caulking;
2.Door frame caulking; and
3.Floor and expansion joint caulking.
For each type of caulking material identified, the following number of samples should be collected:
•Collect at least one sample from each homogenous area that contains less than 50 linear
feet of caulking;
•Collect at least three samples from each homogenous area that contains between 50 and
250 linear feet of caulking;
•Collect at least five samples from each homogenous area that contains between 250 and
1,000 linear feet of caulking;
•Collect at least seven samples from each homogenous area that contains between 1,000
and 2,500 linear feet of caulking; and
•Collect at least nine samples from each homogenous area that contains greater than 2,500
linear feet of caulking.
If homogenous caulking material is found throughout the building, samples should be spatially
distributed so as to not collect the required number of samples from one area. In addition, the
width or cross-sectional area of the caulking bead is not relevant for determining the linear footage
to be sampled. It is also recommended that the sampler performing the evaluation inspect the
entire building prior to sample collection to insure proper distribution is performed.
Thermal/Fiberglass Insulation
For thermal/fiberglass insulation:
•Collect at least one bulk sample from each homogeneous area.
Adhesive/Mastic
For each type of adhesive/mastic material identified, the following number of samples should be
collected:
•Collect at least three samples from each homogenous area less than 1,000 square feet;
•Collect at least five samples from each homogenous area between 1,000 and 5,000 square
feet; and
•Collect at least seven samples from each homogenous area greater than 5,000 square feet.
If homogenous adhesive/mastic material is found throughout the building, samples should be
spatially distributed so as to not collect the required number of samples from one area. It is
Protocol for Evaluating Priority PCBs-Containing Materials before Building Demolition
18
recommended that the sampler performing the evaluation inspect the entire building prior to
sample collection to insure proper distribution is performed.
Rubber Window Seals/Gaskets
For rubber window seals/gaskets identified, the following number of samples should be collected:
•Collect at least one sample from each homogenous area that contains less than 50 linear
feet of caulking (of any width or cross-sectional are of bead);
•Collect at least three samples from each homogenous area that contains between 50 and
250 linear feet of caulking;
•Collect at least five samples from each homogenous area that contains between 250 and
1,000 linear feet of caulking;
•Collect at least seven samples from each homogenous area that contains between 1,000
and 2,500 linear feet of caulking; and
•Collect at least nine samples from each homogenous area that contains greater than 2,500
linear feet of caulking.
If homogenous rubber window seals/gaskets are found throughout the building, samples should be
spatially distributed so as to not collect the required number of samples from one area. It is also
recommended that the sampler performing the evaluation inspect the entire building prior to
sample collection to insure proper distribution is performed.
3.2.3 Sample Analysis and Preservation
Samples collected to evaluate building materials for PCBs should be analyzed for Aroclors by
EPA Method 8082/8082A12 by an accredited analytical laboratory. The minimum reporting limit
should be 50 micrograms per kilogram (µg/kg) and the laboratory should be contacted before
sampling to confirm minimum material volume required to meet the reporting limit objectives. A
sample reporting limit of 50 µg/kg is well below the target management level of 50 mg/kg.
Samples should immediately be chilled in an ice cooler and then kept at 4 degrees Celsius (39.2
degrees Fahrenheit) or colder during storage and transportation to the laboratory. Proper chain-of-
custody13 procedures should be followed from the time the samples are collected until they are
delivered to the laboratory for analysis. Holding times for EPA Method 8082/8082A are sample
extraction within 14 days of sample collection and analysis of the extract within 40 days of
12 Provision C.12.f. requires that Permittees develop and implement or cause to be developed and implemented an
effective protocol for managing materials with PCBs concentrations of 50 ppm. EPA Method 8082/8082A is an
acceptable method to quantify PCBs. Analysis of PCBs congeners is not required to meet the permit requirement.
13 Chain-of-custody is the procedure to document, label, store, and transfer samples to personnel and laboratories. For
a detailed list of procedures, refer to the Sample and Evidence Management, Operating Procedure (SESDPROC-005-
R2), January 29, 2013
Protocol for Evaluating Priority PCBs-Containing Materials before Building Demolition
19
extraction. However, PCBs are very stable in a variety of matrices and holding times may be
extended to as long as one year. Once extracted, analysis of the extract should take place within
40 days.
3.2.4 Quality Assurance and Quality Control
For this program, general quality assurance and quality control (QA/QC) procedures will be
utilized. The following checklist should be used by the contractor performing the evaluation:
•QA/QC Checklist:
o Proper specified sampling equipment was used (pre-cleaned or other, stainless
steel);
o Proper decontamination procedures were followed;
o Sampling collection spatial frequency was met;
o A National Environmental Laboratory Accreditation Program (NELAP) laboratory
was utilized;
o Samples were received by the laboratory within proper temperature range;
o Samples were extracted and analyzed within the method holding time for EPA
Method 8082/8082A; and
o Sample reporting limit met data quality objectives.
3.3 Reporting and Notifications
The following considerations are applicable to reporting and notification:
•Assessment results must be submitted to the applicable Permitting Authority by the project
applicant;
•Applicants that determine PCBs exist in priority building materials must follow applicable
federal and state laws. This may include reporting to USEPA, the San Francisco Bay
Regional Water Quality Control Board, and the California Department of Toxic Substances
Control (DTSC). These agencies may require additional sampling and abatement of PCBs.
•Depending on the approach for sampling and removing building materials containing
PCBs, applicants may need to notify or seek advance approval from USEPA before
building demolition. Even in circumstances where advance notification to or approval from
USEPA is not required before the demolition activity, the disposal of PCBs waste is
regulated under TSCA.
•The disposal of PCBs waste is subject to California Code of Regulations (CCR) Title 22,
Section Division 4.5, Chapter 12, Standards Applicable to Hazardous Waste Generators.
Protocol for Evaluating Priority PCBs-Containing Materials before Building Demolition
20
•Building owners and employers need to consider worker and public safety during work
involving hazardous materials and wastes including PCBs.
For further information, applicants should refer to the PCBs in Priority Building Materials
Screening Assessment Applicant Package, BASMAA, July 2018.
Protocol for Evaluating Priority PCBs-Containing Materials before Building Demolition
21
4.REFERENCES
Guidelines for Asbestos Sampling:
o https://www.epa.gov/asbestos/asbestos-laws-and-regulations
Guidelines for Lead-Based Paint Evaluations:
o Environmental Protection Agency (EPA) - Created the Renovation, Repair, and Painting
(RRP) Rule which requires training and certification for anyone working for
compensation in pre-1978 residential structures, day care centers, and schools where
known or assumed lead-based paint is impacted. The EPA website with complete
information on this regulation is https://www.epa.gov/lead/renovation-repair-and-
painting-program.
o California Department of Public Health (CDPH) - Created "Title 17" which includes lead
testing and abatement provisions in residential and public structures in California.
Several important definitions are contained in Title 17 including Abatement, Clearance
Inspection, Containment, Lead-Based Paint.
o Lead Contaminated Dust and Soil, Lead Hazard, and Lead Hazard Evaluation. Title 17
establishes that lead testing be performed using XRF equipment or by paint chip sample
analysis in California. Lead test kits are not accepted. It also establishes testing in
California be performed by a State certified lead inspector/assessor if the testing is related
to a project involving compensation.
o Department of Housing and Urban Development (HUD) - Created the HUD Guidelines
which contain protocols for lead testing and abatement.
EPA Method 8082A – Polychlorinated Biphenyls (PCBs) by Gas Chromatography
o https://www.epa.gov/sites/production/files/2015-07/documents/8082a.pdf
SESDPROC-205-R3, Field Equipment Cleaning and Decontamination, replaces SESDPROC-
205-R2. December 18, 2015
o https://www.epa.gov/sites/production/files/2016-
01/documents/field_equipment_cleaning_and_decontamination205_af.r3.pdf
SESDPROC-005-R2, Sample and Evidence Management, Operating Procedure, January 29, 2013
o https://www.epa.gov/sites/production/files/2015-06/documents/Sample-and-Evidence-
Management.pdf
APPENDIX A
PCBs Building Material Prioritization
Worksheet
Appendix A - PCBs Building Materials PrioritizationCaulking (sealant, plaster)Caulk/sealant/tape/glue0.001 752,0005553554.67Thermal insulationInsulation73,0005554454.67Fiberglass insulationInsulation39,1585454454.50Adhesives/masticCaulk/sealant/tape/glue3,1005353554.33Rubber gasketsGaskets/Rubber84,0005533454.17Wool felt gaskets Gaskets/Rubber688,4985533454.17Cloth/paper insulating material Insulation12,0005434454.17Foam rubber insulation Insulation13,1005434454.17Ceiling tiles coated w/flame resistant sealant Internal nonstructural surface53 110,0005553254.17Backer rodCaulk/sealant/tape/glue99,0001553554.00Roofing/siding materialExternal nonstructural surface030,0005453254.00Paint (complete removal) Paint/pigment/coatings0.00197,0005551354.00Insulating materials in electric cable Electrical0 280,0005534153.83Adhesive tapeCaulk/sealant/tape/glue1,4005313553.67Surface coatingPaint/pigment/coatings2555351353.67Coal-tar enamel coatings Paint/pigment/coatings1,2645351353.67GroutCaulk/sealant/tape/glue9,1005412553.67Cove baseInternal nonstructural surface1705334253.67Plastics/plasticizersElectrical13,0005433153.50GE siliconesCaulk/sealant/tape/glue<1.901.85132553.50GlazingCaulk/sealant/tape/glueUp to 100% liquid PCBs515233353.50Flooring and floor wax/sealantInternal nonstructural surface Maximum likely >50 515233253.33Light ballastLight ballastsMinimum likely <50 49 1,200,0005535113.33Anti-fouling compounds Paint/pigment/coatings59,0005411353.17Polyurethane foam (furniture) Caulk/sealant/tape/glue505215513.17Askarel fluid/cutting oils/hydraulic fluidOils/dielectric fluids450,0005515213.17Fire retardant coatings Paint/pigment/coatings59,0005411353.17Waterproofing compounds Paint/pigment/coatings59,0005411353.17Electrical wiringElectrical145134153.17ConcreteConcrete/stone2.50.00117,0001431453.00Foam rubberGaskets/Rubber1,0921313452.83Soil/sediment/sandSoil/dust0.150.0015811312552.83Brick/mortar/cinder block Concrete/stone1,1001331452.83WoodWood3801333252.83Door frameInternal nonstructural surface1021234252.83Metals surfaces in contact with caulk/sealant Metal surfaces448514481312452.67MaterialMaterial ClassMedian/Average/Single Reported Concentration(ppm)Minimum(ppm)Maximum(ppm)PCBs Removed by Other Waste Program?(Rating values: not removed by other = 5, or removed = 1)Prioritization ScorePCBs Source Material?(Rating values: source = 5, or not source = 1)Concentration (Rating values: 1 to 5, higher value means higher concentration)Prevalence of PCBs Containing Material in Buildings(Rating values: high = 5, medium = 3, or low = 1)Ease of Removal (Rating values: 1 to 5, higher value means easier to remove)Flaking/ Crumbling(Rating values: 1 to 5, higher value means more likely to flake/crumble)August 2018
Appendix A - PCBs Building Materials PrioritizationMaterialMaterial ClassMedian/Average/Single Reported Concentration(ppm)Minimum(ppm)Maximum(ppm)PCBs Removed by Other Waste Program?(Rating values: not removed by other = 5, or removed = 1)Prioritization ScorePCBs Source Material?(Rating values: source = 5, or not source = 1)Concentration (Rating values: 1 to 5, higher value means higher concentration)Prevalence of PCBs Containing Material in Buildings(Rating values: high = 5, medium = 3, or low = 1)Ease of Removal (Rating values: 1 to 5, higher value means easier to remove)Flaking/ Crumbling(Rating values: 1 to 5, higher value means more likely to flake/crumble)AsphaltConcrete/stone1401212452.50CarpetInternal nonstructural surface0.469.71115252.50Stone (granite, limestone, marble, etc.)Concrete/stone1301211452.33Air handling systemAir system0.469.71113152.00August 2018
APPENDIX B
Priority Building Materials
Photographic Log
B-1 August 2018
Appendix B
Priority Building Materials to be Tested for PCBs
Photograph 1
Window Caulking:
Damaged caulking
around a window.
Photograph 2
Window Caulking:
Worn and
potentially friable
caulking around a
window.
B-2 August 2018
Appendix B
Priority Building Materials to be Tested for PCBs
Photograph 3
Door Frame Caulking:
Damaged, friable
caulking on an interior
door frame.
Photograph 4
Floor and Expansion
Joint Caulking:
Joint compound between
flooring segments.
B-3 August 2018
Appendix B
Priority Building Materials to be Tested for PCBs
Photograph 5
Thermal Insulation:
Foam insulation
material in an attic.
Photograph 6
Thermal Insulation:
Damaged floor foam
insulation.
B-4 August 2018
Appendix B
Priority Building Materials to be Tested for PCBs
Photograph 7
Thermal Insulation:
Damaged pipe foam
insulation.
Photograph 8
Thermal Insulation:
Exposed/damaged
pipe insulation.
B-5 August 2018
Appendix B
Priority Building Materials to be Tested for PCBs
Photograph 9
Thermal Insulation:
Damaged pipe
insulation.
Photograph 10
Thermal Insulation:
Exposed pipe
insulation.
B-6 August 2018
Appendix B
Priority Building Materials to be Tested for PCBs
Photograph 11
Adhesive / Mastic:
Friable adhesive on a
cement surface.
Photograph 12
Adhesive / Mastic:
Adhesive beneath a
carpet.
B-7 August 2018
Appendix B
Priority Building Materials to be Tested for PCBs
Photograph 13
Adhesive / Mastic:
Adhesive remnants on
flooring.
Photograph 14
Adhesive / Mastic:
Exposed adhesive on
roofing.
B-8 August 2018
Appendix B
Priority Building Materials to be Tested for PCBs
Photograph 15
Rubber Window
Seal/Gasket:
Grey rubber window
seal/gasket in a wood
type frame.
Photograph 16
Rubber Window
Seal/Gasket:
Off white rubber
window seal/gasket in
an aluminum type
frame.