Design and Bidding of PCB Abatement Projects for Building Materials. Brian McCormack Weston & Sampson

Transcription

1 Design and Bidding of PCB Abatement Projects for Building Materials Brian McCormack Weston & Sampson

2 Design and Bidding of PCB Abatement Projects for Building Materials Brian McCormack P.E. Weston & Sampson

3 My demolition/renovation project has PCB-impacted materials. How do I proceed?

4 So many questions Should I remove PCBs or can I leave in place? Am I dealing with impacted substrate material? How do I mitigate exposure? Do I need EPA approval for what I do? How do I develop a Work Plan or specifications? How do I procure a contractor? How much will it cost? What will be the impact to project schedule?

5 What is the overall project goal? Demolishing/renovating a building Replacing building components Mitigating exposure to remaining PCB materials Adhering to a tight schedule Minimizing overall project costs

6 What are my options under EPA Regulations? Self-Implementing Approach (40 CFR (a)) Prescriptive procedures for sampling and clean-up EPA notification/approval required Performance-Based Approach (40 CFR (b)) Dispose of all waste at TSCA-approved facility Work plan approval from EPA not necessary Risk-Based Approach (40 CFR (c)) Risk exposure assessment EPA notification/approval required

7 Design Decision Matrix Project Goal Self- Implementing Performance- Based Risk-Based Demolition/Renovation Component Replacement Mitigate exposure to remaining PCBs Meet Schedule Minimize Costs

8 Self-Implementing Approach Evaluate completeness of data set. EPA may require additional characterization data (schedule impacts). Correspond with EPA on design intent. Prepare PCB Abatement specification based on SIP. Incorporate approved SIP into bid package. Clearly delineate extent of removal using drawings and details. Include time for verification sampling in sequence of work.

9 Performance-Based Approach Prepare design plans and specifications for bid. Clearly define extent of removal for bulk product and substrate. If extent is well defined, bid work as lump sum. Remove more substrate - save time on verification sampling. Require Abatement Work Plan submittal from contractor. Include time for verification sampling in sequence of work. Specify requirements for containment, monitoring, and waste disposal.

10 Risk-Based Approach Typically used for more complicated projects. Involve Risk Assessor. Collect data sufficient to perform risk assessment. Follow EPA checklist for preparing Risk-Based Cleanup Plans. Include sufficient time in project schedule for Plan approval (can be up to 6-9 months). Incorporate approved Plan into bid specifications package. Clearly define extent of removal and/or encapsulation.

11 Abatement Drawing and Details Provide plans showing full extent of impacted material removal. Include supporting details (e.g., sawcutting and removal of caulked expansion joints, brickwork around windows, etc.).

12 Abatement Specifications Incorporate approved SIP or Risk-Based Plan. Specify requirements for Contractor Work Plan submittal. Specify requirements for Work Area protection, containment, air monitoring, and equipment decon. Provide specifications for encapsulation products (if required). Include requirements for waste handling and disposal. Means and methods are up to contractor, however, specify sequence of material removal, and verification testing where necessary. cleanup,

13 Lessons Learned vacuum clean all surfaces prior to commencing abatement activities... vacuum remove all loose caulk debris and dust work area shall be inspected by Engineer for acceptance prior to commencing next activity

14 Considerations for Public Bid Prequalify contractors experience is key. Has contractor submitted EPA-approved Work Plans? Contractor team includes environmental professionals (sampling, monitoring, documentation). Bid pricing bid item flexibility (additional material removal, adjustment class items, confirmatory sampling). Oversight is very important.

15 PCB Disposal Rule Update PCB-impacted substrate materials can now be disposed of with bulk product waste at state-permitted nonhazardous waste landfills. Simplifies specification language streamlines waste management reduces disposal costs.

16 Contact Information: Brian J. McCormack, P.E. Project Manager Weston & Sampson 5 Centennial Dr. Peabody, MA Mobile: Office: Ext.2329 Fax: mccormackb@wseinc.com Questions?