A typical building walkthrough by Environmental Works, Inc. (EWI) as part of a request for proposal (RFP) at a former federal compound in northeast Kansas City last September turned into a very atypical day. During the walkthrough, a group of EWI scientists led by Nick Godfrey, National Program Manager-Due Diligence, discovered numerous piles of dismantled florescent light ballasts in 26 rooms of the building with most of the ballasts likely containing polychlorinated biphenyls (PCBs).
“The piles of opened PCB-containing ballasts and spilled internal components were distributed everywhere throughout the interior of the building,” said Godfrey, who served as Project Director and Lead Consultant.
According to the Environmental Protection Agency (EPA), PCBs are a group of man-made chemicals that are either oily liquids or solids and are colorless to light yellow. PCBs were used in making electrical transformers, capacitors and other heat transfer devices from the 1930s to late 1970s and can be found at extremely high concentrations in older fluorescent light fixtures. The ballast contains a small transformer, a capacitor and potting material (insulation), all of which contain PCBs. These components are not accessible unless the ballast is disassembled. PCBs are particularly toxic to children but are also harmful to adults. They are considered probable human carcinogens. A number of studies show that exposure to PCBs adversely affects the reproductive system, immune system and nervous system.
Fluorescent light ballasts such as those discovered in piles by Godfrey’s team also contain copper. It is assumed that the ballasts were broken open by opportunists looking to strip and sell the valuable metal.
“Generally, the ballasts appeared to have been removed and transferred to centralized locations, then opened and dismantled and placed into piles throughout the first floor and basement level,” Godfrey said.
Following the discovery, EWI was contacted by the property owner, the Hardesty Renaissance Economic Development Corporation (HREDC), for regulatory guidance. Godfrey contacted the EPA Region 7 PCB Coordinator, who in turn requested documentation and informed him of the owner’s obligations under the Toxic Substance Control Act (TSCA). EPA regulations implementing the TSCA prohibit the use of building materials manufactured with PCBs at levels greater than or equal to 50 ppm (parts per million), including the continued use of such materials that are already in place. The manufacture of PCBs was prohibited in 1979.
EWI was subsequently contracted by HREDC to conduct a PCB investigation following EPA guidance to determine the contents and associated concentrations of PCB-impacted materials. Led by Yvonne Huff, Senior Project Manager, EWI’s Investigation and Remediation Department in Kansas City spent over a week in October 2019 sampling suspected sources of PCBs, including the potting material that surrounded the ballasts and underlying concrete and flooring materials.
Many of the samples of potting materials and surrounding loose debris came back showing concentrations of PCBs in the 1000s and ranging up to 16,000 ppm.
A plan for the removal and disposal of the PCB-containing materials, as well as remaining intact fluorescent light fixtures and three large transformers that were also disassembled, was drafted and submitted by EWI and approved by HREDC and the EPA. Remediation and removal started in earnest on Aug. 10 and was completed in early September.
Huff and Godfrey coordinated the massive cleanup, while Wyatt Walls, Associate Scientist in I/R, served as the on-site project manager during the removal process. A team of up to five technicians a day from EWI’s Field Services Department in Kansas City performed the removal and disposal.
“The material was everywhere,” Huff said. “As you clean each area, you’re picking up the broken ballasts and other debris around them because the potting material is in little broken pieces. It’s hard to estimate how much time it takes to pick up these things by hand.”
All of the waste from the piles was considered toxic PCB waste. Because the power to the building was disconnected, the waste had to be hauled up from the basement and through the first floor to cubic yard boxes positioned near the front of the building. The majority of work was completed with mid-day temperatures hovering around 90 degrees in a building with no working windows or central air.
Once the piles were picked up and removed, the crew from EWI moved on to the second story, where intact fluorescent lights and ballasts were removed. According to Huff, the second story of the building is a warehouse-type space and the ceiling was too elevated to reach by ladder. So, EWI adjusted on the fly and built scaffolding to reach the lights. The lights in each of three stairwells were also elevated and had to be removed using a 20-foot ladder.
“It took an entire day to get those lights,” Huff said. “The crew would have to do a little bit then take a break due to the heat and humidity inside the building.”
Once all PCB-containing materials were removed, EWI vacuumed below the leaking ballast spill sites with high efficiency particulate air filter (HEPA)-equipped vacuums. EWI then took samples of the concrete, and “everything came back clean,” said Huff.
“The EPA allowed us to do the cleanup, wash and rinse the concrete, then collect samples to verify that the room is safe for residential occupancy,” she added.
Huff acknowledged that the PCB removal was a huge undertaking for the client but said that “it could have been much worse if the PCB oil leached into the concrete. Then you’re looking at taking out and replacing concrete floors.”
“It’s a significant project for the client,” Godfrey said. “They’re trying to revitalize an underutilized part of town. It’s a noble cause.”
In total, EWI removed 10 cubic yard boxes and six drums of hazardous waste from the building. This did not include the intact ballasts, fluorescent lights and three large transformers, which will be properly disposed pending analytical results.
EWI also conducted air monitoring in the building, produced a roofing deficiency report, completed asbestos inspections of the building and roof, and conducted lead-based paint inspections and reporting as part of the comprehensive project.
Team members from across EWI assisted in the completion of the project, including regulatory and waste management specialists, engineers, environmental scientists, licensed inspectors and remediation team members.
“This may have been the first time the EPA has seen vandalism of PCB-containing materials to this extent in our region,” said Godfrey.