U. S. Environmental Protection Agency

Greener Cleanups Best Management Practices:
PCB Cleanups

PCB Information and Reference Series
Fact Sheet

Core

Land & Elements Air &
icosystems	Atmospherel

December 2022

The goal of this fact sheet is to help owners, operators, contractors, and regulators
implement Greener Cleanup Best Management Practices (BMPs) at PCB cleanup
sites. This fact sheet contains case studies and a toolkit, including a list of common
BMPs used at PCB cleanup sites.

What is a Greener Cleanup?

The U.S. Environmental Protection Agency's (EPA) Principles for Greener Cleanups
(Greener Cleanups) establishes policy for EPA and its partners to evaluate cleanup
actions comprehensively to ensure protection of human health and the
environment, and to reduce the environmental footprint of cleanup activities to the
maximum extent possible. Cleanups and any associated environmental footprint
reduction should be consistent with statutes and regulations governing EPA cleanup
programs and should not compromise cleanup objectives, community interests, the
reasonableness of cleanup timeframes, or the protectiveness of the cleanup actions.
The environmental footprint can be assessed qualitatively or quantitatively, and the
Principles should be considered and can be implemented at any phase of a cleanup.
Five core elements can be addressed during a Greener Cleanup:

~	Total energy use and renewable energy use.

~	Air pollutants and greenhouse gas emissions.

~	Water use and impacts to water resources.

~	Materials management and waste reduction.

~	Land management and ecosystems protection.

Consensus Standard

EPA worked with federal and state partners and ASTM International (ASTM) to
develop a consensus-based standard of greener practices for contaminated site
cleanup, the Standard Guide for Greener Cleanups (Standard Guide). The Standard
Guide provides a framework to reduce the environmental footprint of cleanups
while maintaining the cleanup objectives and ensuring protectiveness of the
remedy. The Standard Guide includes BMPs organized by core element, phase of
the remedy, and remedial technology. EPA analysis of PCB cleanup completion
reports identified that 22 of these BMPs are frequently used at PCB cleanups.
These 22 BMPs are listed at the end of this fact sheet.

Greener Cleanups, Environmental Justice, and Climate Change

Many BMPs help address Environmental Justice concerns such as access to clean
air and water. For example, if a cleanup site is in a non-attainment area for air
pollution, BMPs that reduce air pollutants during cleanup can be prioritized.
Additionally, several BMPs reduce greenhouse gas emissions from site activities.
Many other BMPs improve a site's resilience to extreme events caused by climate
change and can be found in the Interstate Technology & Regulatory Council
(ITRC) Sustainable, Resilient Remediation Guidance.

EPA 530-F-22-005

Polychlorinated
Biphenyls (PCBs)

PCBs were

manufactured between
1929 and 1979 and used
extensively in many
applications such as
coolants in hydraulic
systems and as dielectric
fluids in electrical
equipment. Most
manufacturing,
processing, distribution
in commerce, and use of
PCBs was banned under
the Toxic Substances
Control Act after 1979.
However, PCBs may
still be present in
products and materials
produced before 1979
(including oil used in
motors and hydraulic
systems) or in excluded
manufacturing
processes, as defined in
Title 40 of the Code of
Regulations Section
761.3, and can still be
released into the
environment, where
they do not readily break
down.

PCBs have been identified
as probable human
carcinogens and cause a
variety of non-cancer
health effects.1


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u. s. epa	PCB Greener Cleanups Fact Sheet	December 2022

PCB Greener Cleanups

The PCB Program regularly requires cleanup completion reports to document compliance with the PCB
cleanup approval and regulations. ASTM guidance on reporting Greener Cleanups recommends
documenting Greener Cleanup BMPs in a completion report. EPA reviewed 50 PCB cleanup completion
reports documenting Greener Cleanup BMPs since 2015. EPA analysis found that BMPs from the
Standard Guide have been implemented from all cleanup categories to address all core elements of EPA's
Principles for Greener Cleanups, as shown below. Case studies highlighting some PCB Greener Cleanups
follow, as well as a list of 22 frequently used BMPs at PCB Cleanups.

Residual Solid
and Liquid
Waste

Sampling and
Analysis

Project
Management

and Team
Management

Power and
Fuel

Site
Preparation
and Land
Restoration

Materials

Surface and
Stormwater

Buildings

Vehicles and
Equipment

Figure 1 - Boxes represent each cleanup activity category in the ASTM Standard Guide. Implementation of BMPs from these categories
directly affects the Core Elements of EPA's Principles for Greener Cleanups in the center circle.

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u. s. epa	PCB Greener Cleanups Fact Sheet	December 2022

Case Studies

Boeing Everett Plant, Everett, Washington:

The Boeing Company successfully demonstrated that Greener Cleanup BMPs were feasible at a small dig-
and-haul transformer substation PCB and volatile organic compound cleanup under tight time
constraints.

The PCB cleanup was conducted as part of preparing the site for new commercial use by Boeing to
construct the 777x composite wing plant, a $1 billion project with up to 1,700 construction personnel
involved. The PCB cleanup was a small part of the overall work on-site and relatively straightforward.
Cleanup activities spanned two days and included removal and disposal of concrete slabs over two vaults,
and underlying soil contaminated by historical PCB transformer leaks. The figure below depicts one of
the vaults.

Despite the small size of the cleanup, Boeing Everett was the first PCB cleanup site in the national PCB
program to implement Greener Cleanups. Nine BMPs were implemented, including:

^ Established green requirements as evaluation criteria in the selection of contractors and
including language in requests for proposals, contracts, etc.

S Covered inactive areas of the cleanup to control dust, rather than spraying water.

S Used dedicated materials for sampling, rather than disposable materials and equipment.

S Selected products that are environmentally preferable - s uch as products packed in
reusable/recyclable containers and drums to reduce packaging waste.

S Used a local laboratory to minimize impacts from transportation and avoid shipping
samples out of state.

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u. s. epa	PCB Greener Cleanups Fact Sheet	December 2022

Case Studies

Martin State Airport, Middle River, Maryland:

Lockheed Martin Corporation removed two localized areas of PCB contamination in soil at the Martin
State Airport to a level of less than or equal to 25 milligrams per kilogram, suitable for a low-occupancy
area. The airport is bounded on the east and west by creeks that are tidal tributaries of the Chesapeake
Bay, and the cleanup site is in the southeastern portion of the airport. Lockheed Martin implemented 11
Greener Cleanup BMPs, a few of which are described below:

S Implemented an idle reduction plan.

•f Used drilling methods which minimized the generation and disposal of cuttings;
specifically, direct-push technology - rather than a rotary auger or Rotasonic drill rig -
was used to significantly reduce drilling time, avoid generating drilling fluids, and
eliminate/reduce drill-cutting that would require characterization and disposal.

•S Used local staff and equipment and product vendors with production and distribution
centers near the site when possible to minimize transportation impacts.

Used biobased products - specifically, a biodegradable erosion control blanket with grass
seed was used to restore the excavated area.

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U. S. EPA

PCB Greener Cleanups Fact Sheet

December 2022

Case Studies

Hoyt Island, Norwalk, Connecticut:

This cleanup of PCB bulk product waste and PCB remediation waste (contaminated soil) occurred at the
remains of a former residential structure on the northern portion of a three-acre wooded island located in
the Long Island Sound. The island currently serves as a bird sanctuary. The black flashing tar (sealant)
on a fireplace chimney contained PCBs and asbestos which also
impacted the soil. The sealant was removed, and contaminated
soils were excavated and taken off site for disposal. The
Norwalk Land Trust designed the cleanup in consideration of
the intended use of the island as a bird sanctuary and potential
for impacts to other ecological receptors. The primary goal was
for remediation activities to have minimal impacts to the natural
surrounding soils and vegetation. To this end, an array of
Greener Cleanup BMPs were implemented, a few of which are
described below:

S Reused on-site clean materials - the non-impacted
building masonry and site soils were used for island
restoration.

S Restricted traffic to confined corridors to minimize
soil compaction and land disturbance - the equipment
was offloaded on the island near the work zone, and
work zone pathways were predetermined to reduce the
amount of vegetation clearance and soil compaction.

S Restored and/or maintain ecosystems in ways that
mirror natural conditions - the soils were regraded to
reduce erosion during reestablishment of native plants,
and remediation was scheduled to prevent interference
with migratory bird nesting season.

Durbin Inert Debris Landfill, Irwindale, California:

Vulcan Materials Company (Vulcan) removed PCB contaminated soils from this site in 2019. Excavation
necessitated decontamination of the excavator, including the sprockets, track shoes, track links/chains,
track rollers, excavator bucket, and the side plate of the track system. Vulcan applied for and was
approved by EPA Region 9 to use an alternate decontamination method that did not rely on petroleum-
based solvents. Instead, the decontamination was carried out by first scraping large debris off the
components, then using high pressure wash with Alconox, a biodegradable detergent, to remove any
remaining dust and soils, and finally performing a high-pressure rinse with tap water. The
decontamination method was validated as effective through wipe sampling. Through this alternate
decontamination method, Vulcan was able to implement a Greener Cleanup BMP to protect water and
impacts to land and ecosystems.

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u. s. epa	PCB Greener Cleanups Fact Sheet	December 2022

Toolkit: How to Implement Greener Cleanups

BMP Opportunity
Assessment

Identify potentially applicable BMPs

BMP Process

The ASTM Standard Guide is a tool that includes
a process to enable the user to identify, prioritize,
select, implement, and document the use of BMPs
to reduce the environmental footprint of cleanup
activities. The process includes the following
steps:

1.

2.

BMP Opportunity Assessment

Determine which BMPs are potentially
applicable to the project's cleanup phase
without regard to other factors that will
ultimately influence the decision to use a
particular BMP. A list of 22 frequently
used BMPs at PCB Cleanups is included in
this Fact Sheet.

BMP Prioritization

Prioritize BMPs based on their ability to
reduce the environmental footprint of the
cleanup activity and based on interested parties' |
concerns.

4.

5.

BMP Prioritization

Prioritize BMPs with greatest potential in
reducing the environmental footprint

BMP Selection

Select applicable BMPs after additional
considerations

BMP Selection

Select the specific BMPs that will be
implemented. Selection considerations may
include regulatory requirements, cleanup
objectives, community concerns, corporate
social and environmental responsibility
priorities, feasibility, effectiveness, reliability,
short-term risks, costs, and local ordinances.

BMP Implementation

Implement the selected BMPs or document
the rationale for not implementing any selected BMPs
BMP Documentation

BMP Implementation

Implement applicable BMPs and document
rationale for any not implemented

Record Steps 2-4 in a completion report.

Additional Information:

ASTM Standard Guide for Greener Cleanups (E2893-13)

BMP Documentation

Document the BMP process

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PCB Greener Cleanups Frequently Used BMPs1	December 2022

Buildings

S Reuse existing structures for treatment, storage, or sample management. For example, use an existing rock wall
and vegetation as a buffer to impede potential sediment transport in stormwater runoff.

Materials

S Select products that are environmentally preferable. Explore the GSA Sustainable Facilities tool at

https://sftool.gov/ for products with sustainable raw materials consumption, manufacturing processes, packaging,
distribution, recycled content and recyclability, maintenance needs, and disposal procedures.

S Decontaminate equipment with environmentally preferable methods such as steam cleaning. Search for cleaning
products that meet EPA's Safer Choice Standard at https://www.epa.gov/saferchoice/products.

S Use biobased or biodegradable products such as biodegradable seed matting; control erosion and sedimentation
with fabrics containing agricultural by-products, straw wattles, and straw; use oils made from algae, soybeans, or
waste/by-products from forestries, plant nurseries, or food processing; and use biodegradable staples.

Power and Fuel

S Use gravity flow to transfer water after subsurface extraction or to discharge treated water.

Residual Solid and Liquid Waste

S Reuse or recycle recovered product and materials (for example, cardboard, plastics, asphalt, concrete, etc.) in
accordance with the PCB regulations: https://www.ecfr.gov/title-40/chapter-l/subchapter-R/part-761

S Salvage uncontaminated items for recycling, resale, donation, or reuse.

S Recycle or reuse un-used or uncontaminated equipment, materials, or infrastructure.

Sampling and Analysis

S Use dedicated materials and sampling equipment instead of disposable materials and equipment.

Project Planning and Team Management

S Use local staff, contractors, and subcontractors to minimize resource consumption.

S Use a local laboratory to minimize impacts from transportation.

S Contract with a laboratory that uses green practices.

Site Preparation and Land Restoration

S Select pre-existing, native, and non-invasive vegetation for site restoration to minimize use of water and soil
amendments and preserve biodiversity and related ecosystem services.

S Use biodegradable covers to protect land surfaces, redirect traffic, and preserve healthy plants.

S Restore and/or maintain ecosystems in ways that mirror natural conditions, such as grading surfaces to pre-
construction conditions, restoring disturbed wetland areas, backfilling an excavation immediately to restore
stormwater runoff and/or infiltration, and scheduling site activities to not interfere with migration patterns.

S Minimize clearing of trees and other vegetation, for example, by pre-determining the work zone pathways
and locating equipment loading areas as close to the work zone as possible.

S Cover waste piles, areas where active work is not performed, and filled excavations with biodegradable fabric to
control erosion, reduce the use of water for dust suppression, and/or serve as a substrate for ecosystems.

S Reuse on-site or local clean materials when possible. For example, wood waste for compost, rocks for drainage
control, uncontaminated building masonry or crushed concrete for backfill, topsoil from a local source.

S Pre-plan and restrict work zone paths and traffic corridors to minimize soil compaction and land disturbance.

Surface and Stormwater

S Capture rainwater for tasks such as wash water, irrigation, dust control, constructed wetlands, or other uses.
Vehicles and Equipment

S Implement an idle reduction plan.

S Use retrofitted engines that use ultra-low or low sulfur diesel or alternative fuels, or filter/treatment devices to
achieve Best Available Control Technology (BACT) or Maximum Achievable Control Technology (MACT).

1 BMPs were adapted from the ASTM Standard Guide for Greener Cleanups (E2893-13) and reports submitted to the EPA.


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U. S. EPA

PCB Greener Cleanups Fact Sheet

December 2022

References:

EPA Principles for Greener Cleanups, https://www.epa.gov/greenercleanups/epa-principles-greener-cleanups.

ASTM E2893-16, Standard Guide for Greener Cleanups, ASTM International, West Conshohocken, PA,
2016, www.astm.org.

ITRC. 2021. Sustainable Resilient Remediation SRR-1. Washington, D.C.: Interstate Technology & Regulatory
Council, SRR Team, www.itrcweb.org.

Contact your EPA Regional PCB Coordinator

If you have concerns about PCB contamination or need more information,
consult your EPA Regional PCB Coordinator at
http: //www, epa. gov/pcbs/program-contacts
and your state environmental agency.

EPA recommends that you make decisions about appropriate action
after thoughtful consideration of all available information
and all legal requirements.

EPA Region 1 (CT, MA, ME, NH, RI, VT) Tel: 617-918-1527
EPA Region 2 (NJ, NY, PR, U.S. Virgin Islands) Tel: 212-637-
3759

EPA Region 3 (DE, DC, MD, PA, VA, WV) Tel: 215-814-2177
EPA Region 4 (AL, FL, GA, KY, MS, NC, SC, TN) Tel: 404-
562-8512

EPA Region 5 (IL, IN, MI, MN, OH, WI) Tel: 312-886-7890

EPA Region 6 (AK, LA, NM, OK, TX) Tel: 214-665-6796 EPA

Region 7 (IA, KS, MO, NE) Tel: 913-551-7504

EPA Region 8 (CO, MT, ND, SD, UT, WY) Tel: 303-312-6446

EPA Region 9 (AZ, CA, HI, NV, American Samoa, Guam,

Northern Mariana Islands) Tel: 415-972-3360

EPA Region 10 (AK, ID, OR, WA) Tel: 206-553-2899

vvEPA

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